Should retailers (or manufacturers) treat consumer-returned merchandise differently than inventoried products?
Generally, retailers may dispose of items returned from consumers and those from inventoried stock either separately or together. A retailer who chooses to handle them separately may take advantage of the household hazardous waste exclusion for the items returned from households. The inventoried stock must be managed as described in the response to question #4. Because only items generated in a household (as defined in 40 CFR 261.4 (b)(l)) are eligible for the household hazardous waste exclusion, the retailer must be certain that items returned from other regulated sources, such as businesses and commercial facilities are not mixed with those from households. The items returned from sources other than households should be handled with the inventoried stock in accordance with the hazardous waste regulations. If a retailer does not wish to segregate these items, then all items must be handled as described in question #4.
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- Should retailers (or manufacturers) treat consumer-returned merchandise differently than inventoried products?
