What are the regulations concerning recyclers, refurbishers or dismantlers?
Under Virginia’s current regulatory applications, e-waste devices that are managed as commercial products for rebuilding, reuse, or remanufacture by component substitution or replacement rather than disposal would not be considered waste under RCRA. However, if the units are broken apart or disassembled (“demanufactured”) into individual components, unit subsystems, or discrete component devices (e.g. capacitors, batteries, transformers, relays, switches, CRTs, motherboards, frame components, etc.), RCRA issues will have to be evaluated on a case-by-case basis. Any waste components or subassemblies subsequently generated and disposed of will require evaluation under the TCLP criteria and should be managed accordingly. Management of e-waste may also be subject to regulation under the Virginia Solid Waste Management Regulations under certain conditions applicable to MRFs. This is an evolving area of the regulations and changes are expected during the next year.
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- What are the regulations concerning recyclers, refurbishers or dismantlers?
