Q. Does e-waste need to be managed as RCRA hazardous if it’s sent out for recycling? Or can it be managed as Universal Waste?

A. Electronic waste (e-waste) is considered a hazardous waste because it contains hazardous substances which can include lead, mercury, beryllium, thallium, cadmium, and PCBs, among others. Consequently, it must be managed as a hazardous waste when recycled. E-waste is not considered a universal waste under the RCRA rules. Some states, however, have designated it a universal waste. Such states would include: Arkansas, California, Colorado, Connecticut, Louisiana, Maine, Michigan, Nebraska, New Hampshire, New Jersey, Rhode Island, and Vermont. Note that in some of these states, the e-waste/universal waste may be limited to cathode ray tubes (CRTs).