2014 DSW Rule Fails to Sufficiently Incentivize Recycling

On December 10, the U.S. Environmental Protection Agency (EPA) signed a final version of the 2011 proposed revisions to the Definition of Solid Waste (DSW) rule. Unfortunately, the final rule fails to provide adequate regulatory relief for manufacturers wishing to do the right thing by recycling valuable secondary materials.

“IPC is disappointed that the DSW rule provides insufficient incentives to promote recycling of secondary materials and maintains many onerous and unnecessary requirements proposed in 2011,” said Fern Abrams, IPC director of regulatory affairs and government relations. Abrams continued, “The rule retains significant and unnecessary regulatory burdens.”

Although EPA has substituted a verified recycler provision for the more burdensome subtitle C regulations proposed in 2011, IPC remains concerned that the requirements could prove too onerous to encourage additional facilities to recycle secondary materials.

The most critical and important benefits of the 2008 DSW rule are undercut by the more burdensome and unnecessary provisions signed last week. The 2008 DSW rule had the potential to save industry, including electronics manufacturers, approximately $95 million per year while simultaneously providing an environmental benefit by reducing waste.

According to John Hasselmann, IPC vice president of government relations, “This issue has a significant effect on our members and we hope EPA will continue to look for opportunities to reduce the regulatory disincentives to recycling.”

Since 2007, IPC has advocated for a DSW rule that would promote and incentivize recycling of secondary materials. Wastewater treatment sludge from electroplating operations, predominately from the metal finishing and printed board industries, represents one of the United States’ largest potential sources of recoverable metals.

A pre-publication copy of the rule is available.  Visit IPC’s website for more information on the DSW rule.