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Appliances & Electronics
Appliances Electronics
This area covers environmental issues related to retail sales and services of appliances and electronics. The main issues related to appliances and electronics are recycling and disposal requirements (some appliances may contain components which are considered hazardous waste), refrigerants (which can be ozone depleting substances (ODS)), hazardous materials transportation (primarily batteries) and environmental retail product requirements.

Compliance Considerations


Some appliances and electronics may contain hazardous components which may need to be managed as hazardous waste. EPA safe disposal of household appliances has information on environmental concerns for appliance disposal. State and local governments may also regulate the recycling and disposal of non-hazardous appliances and electronics. Because of the complexity of federal and state hazardous waste regulations combined with state and local requirements for recycling and disposal, retailers should make sure that they understand the requirements and use experienced and qualified waste services providers.

Hazardous Waste


Some appliances contain hazardous components, such as refrigerants, oils, mercury, polychlorinated biphenyls (PCBs), or other hazardous materials. Appliances manufactured before 1979 may contain PCB capacitors. PCB wastes​ are regulated by the EPA under the Toxic Substances and Control Act.  Appliances manufactured before 1995 can contain chlorofluorocarbons (CFCs) as refrigerants, which are subject to special management requirements for removal under the Clean Air Act (CAA), and may also be considered hazardous waste. Appliances manufactured before 2000 can contain mercury switches and relays, which may be considered hazardous wastes. Because of the potentially hazardous materials in appliances and electronics, it is important to use a recycler or waste services provider that is qualified to handle appliances and electronics. Depending on the jurisdiction, there may be certification, training, or other requirements for recyclers or waste services providers that handle appliances or electronics.

Electronic or E-Waste

E-WasteSome electronics may also be considered hazardous waste, including older electronics such as cathode ray tube (CRT) which contain lead, computer monitors, and TVs. Some electronics or components may be considered universal waste, such as batteries and appliances or electronics that are considered mercury-containing equipment (e.g., thermostats, pressure gauges, and mercury switches). Some electronic wastes being recycled may be exempt from hazardous waste regulations if they meet the criteria for exclusions based on scrap metal, circuit boards, or precious metals content.  EPA has more information on their recyclin​g page.​

While there is no federal mandate to recycle e-waste, many states have mandatory electronics recycling programs (e.g., landfill bans), so state regulations must be consulted (state electronic waste rules and electronics recycling laws at the state level). These regulations are tracked in the CRC's eWaste Matrix. EPA encourages the reuse and recycling of small electronics and provides guidance on regulations related to e-waste.

Hazardous Waste Regulations

Some important considerations for retailers that relate to waste appliances and electronics are below.

Reuse and Recycling exemption: Appliances and electronics that are considered hazardous waste and sent for disposal (for example, to a landfill) count towards the facility's generator status (as a large, small, or conditionally exempt generator) and must be properly manifested and managed as hazardous waste. However, appliances and electronics sent for reuse or refurbishment prior to reuse generally are not considered hazardous waste and would not be included in the calculation of generator status.  

State Laws: State laws may require more stringent management for appliances and electronics; for example, California and Oregon have landfill bans on appliances and many other electronics. In addition, some states have more stringent requirements for hazardous waste.  However, some states allow electronics to be managed as universal wastes.

Household Exemption and "take back" programs: Used appliances and electronics generated by households are not considered hazardous waste and are not regulated under federal and many state regulations. Under federal regulations, the household hazardous waste exemption continues to apply after household wastes are collected and consolidated. However, many states cut off the household hazardous waste exemption at the point the waste is collected by another entity, such as a retailer who collects the household waste as a service for customers.  

Recyclers: There are federal requirements under the Clean Air Act for refrigerants to be recovered from appliances prior to dismantling or disposal. Depending on the state, there may be additional requirements, such as certification, for companies that recycle appliances or electronics. As a result, it is important to use a qualified company to handle appliance and electronics recycling.

The CRC hazardous waste page has more detail.

Hazardous Material Transportation

The Department of Transportation Pipeline and Hazardous Material Safety Administration (PHMSA) has specific requirements for shipping hazardous materials, including lead acid batteries and lithium batteries either in equipment or separately. The rules include requirements for communication (e.g., marking, labeling, documentation), packaging, emergency response information, and training. Hazardous materials transported across national borders may also be subject to international requirements, such as the International Air Transportation Association's (IATA) restrictions on the acceptable charge of lithium batteries. CRC has a fact sheet addressing Frequently Asked Questions (FAQs) about lithium batteries.


Refrigerants that are ozone depleting substances (ODSs), and as of January 1, 2017, ODS substitutes, are managed under the federal Clean Air Act (CAA). CAA requirements cover handling and the reuse and disposal of ODS and substitute refrigerants, as well as sales of products containing or made with refrigerants. Prior to disposal of a refrigerated appliance, the refrigerant must be recovered (not vented to the atmosphere) and properly recycled or disposed.

There are also federal requirements under Section 608 of the CAA related to servicing appliances such as air conditioning units and refrigeration equipment that are designed to prevent refrigerants from being released. For example, technicians must maximize the recovery and recycling of refrigerants, cannot vent refrigerants to the air, and must be certified. Owners and operators of appliances must comply with recordkeeping and reporting requirements. EPA has more information on their Section 608 Refrigerant Recycling Rule page. States also impose requirements related to the repair and servicing of air conditioning and refrigeration units.

There are bans and labeling requirements on the sale of products that contain or are made with ODSs. Starting in 2015, products made with or containing class II substances, chemicals with an ozone-depletion potential of less than 0.2 and including all HCFCs (found in products such as refrigerators and water heaters), must have a warning label. EPA's fact sheet and product label page provide more information.


The reuse of appliances and electronics, where feasible, can reduce regulatory requirements and be beneficial environmentally.  There are also many organizations that accept donations of older equipment for reuse.

For waste appliances, EPA runs a program called "RAD" ​or Responsible Appliance Disposal, which has resources and partners for proper appliance disposal.

Another resource for recycling electronics is the National Center for Electronics Recycling​.

Some retailers who sell appliances and electronics run "take-back" programs where they take back used electronics or appliances and recycle them for customers. Some even offer discounts or other incentives to buy a new product at the store when bringing in an item for recycling. While this is beneficial from a sustainability standpoint, it can affect a retailer's hazardous waste generator status so it is important to understand all of the requirements that may apply to a take-back program.

There are voluntary environmental product standards for appliances related to sustainability and environmental performance. At the federal level these include Energy Star​ for energy efficiency (Energy Star resources for retailers) and Water Sense for water conservation. The Association of Home Appliance Manufacturers (AHAM) has created sustainability standards for a number of appliances, such as refrigerators, humidifiers and toasters.

Leading Practices & Case Studies

Last Update: 2/8/2017 8:00:00 AM