E-scrap Recyclers and Recovered Materials Processors

Do I need a permit to start an e-waste recycling facility?

No. At present time, facilities that collect used or discarded electronics for recycling do not require a permit. This material is a "recovered material". TCA 68-211-802 defines recovered materials as follows: "Recovered materials means those materials which have been diverted or removed from the solid waste stream for sale, use, reuse or recycling, whether or not requiring subsequent separation processing. Such recovered materials are not solid waste."

Are there State guidelines for operating an e-waste recycling facility?

Yes. While there is not a specific permit required currently for e-waste recycling facilities, the state still maintains an oversight responsibility for these types of operations. The department's Division of Solid Waste Management (the Division) evaluates facilities handling materials that have been source separated from the waste stream to see if they meet the TCA 68-211-802 definition of a "recovered material processing facility." "A recovered materials processing facility means a facility engaged solely in the storage, processing and resale or reuse of recovered materials. A recovered materials processing facility is not a solid waste processing facility."

The Division uses the following guidelines to determine if a facility is a recovered materials processing facility rather than a solid waste processing facility:

  • There must be a viable end-market mechanism that is being utilized.
  • There must be no speculative accumulation of the waste; storage must be for less than one-year.
  • There must be minimal processing before shipment to an end-user or manufacturer.
  • The waste is pre-sorted before arriving at the facility.
  • If the e-waste facility meets these guidelines, the Division does not require a permit for operation.

What are the primary challenges for recovered materials processing?

If the viable end-market disappears in the future, a recovered materials processing facility may be forced to dispose of stored materials. These materials would then be evaluated for hazardous waste characteristics and further solid waste processing prior to disposal. Materials stored for more than one year will be considered speculative accumulation and have no viable end-market value.


David Sutton


This Page Last Updated: February 25, 2021 at 2:13 PM