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Looking into legality of electronics recycling

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    kss is offline Metal Recycling Entrepreneur
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    Looking into legality of electronics recycling

    I was starting to poke around on what it would take for me to be able to collect electronics on a larger scale, legally (like advertising to schools, businesses, etc). I have concluded that doing things legally is nearly impossible for small operations. This discourages competition and encourages less recycling overall.

    I understand that things need to be recycled properly, and am 100% willing to put in time/training/effort to make sure that everything is done right and responsibly, but after looking into what all would be required today, it seems impossible for any non-existing, very profitable, businesses to operate in this market legally. Have a look at everything that would be required for me to legally collect and recycle electronics in my area.


    1) get local permit to designate my garage as a legal place of business (required to provide proof that business is operating and properly zoned, for the next hurdle) (few hundred bucks)
    2) get state permit allowing me to collect and recycle covered electronic devices. This requires R2/Esteward certification (few hundred bucks)
    3) get R2 certified is $2000/annually, and requires 2 inspections that cost $1400/day per inspection (each inspection can last 3-10 days), so that is $6200-$30000 right there
    4) to get R2 certified, you need to be RIOS certified, which starts at $2500
    5) to get RIOS certified, it asks if you are an ISRI member? Not sure if that is required but it would not surprise me, cant find a price on that either but I am sure there is one.


    So there is in total, there are 5+ certifications/memberships, all which cost money, and all which themselves have hundreds of pages of requirements, inspections, approvals, etc. Additionally you would have to spend $10,000 at least, possibly $30,000+, plus invest a ton of time and effort to actually qualify and pass the requirements for each certification.

    It can't be possible that everyone on here is going through all this. Is it just that not all states/areas require this much stuff to legally be allowed to take apart computers and mail them off? Is there some loophole Im missing that says you only need to do all this if you are processing XXXX tons/month? Is everyone just doing it illegally and everything is fine (this seems the most likly but seems unreasonable). By doing it illegally I mean that in my state, to legally collect waste/electronics, and to recycle/take apart electronics, you need a permit. This permit requires numerous certifications.

    Since I am not actually doing any recycling (like melting down, or shredding, or chemical extraction), and just collecting and disassembling devices, I would have thought all this was not needed but the permit says:

    PROCESSING OF WASTE ELECTRONICS
    The approval herein granted is limited to the processing by disassembling,mechanical processing (by sizing, shaping, separating and volume reductiononly), and associated storage prior to reuse or recycling at the processing ortransfer facility, of uncontaminated and source-separated electronic devices.

    I was wondering if me sending the stuff, to a place with a certification, was good enough to qualify for the permit, but I do not know that it is. It say the permit is specifically for disassembling and processing of electronics, and that disassembling/processing without the permit is unlawful.



    I am just wondering if any of the larger players here (specifically ones that are e-steward, R2/RIOs certified, etc) have any input on the matter, or advice, or pointers on how to legally collect the devices and items that are being sent to them.



    edit: I have noticed, 2 of the local places that DO take electronics waste, do not have this permit (the state publishes a list of who has the permits online), 1 other local place does. I am wondering how the 2 places that purchase electronics waste do so without this permit at a large scale without getting in trouble. So, there must be a loophole or exception that I have not found yet.... I am assuming.
    Last edited by kss; 06-28-2020 at 03:39 PM.

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