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Frequent Questions
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How are products selected for
designation in the CPG?
-
How does EPA evaluate the products?
-
Who is required to buy recycled content
products?
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What is an affirmative procurement
program?
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Are items designated in the CPG
"environmentally preferable" products?
-
What is the difference between
postconsumer and recovered materials?
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How do we know if products contain the
recovered content claimed by the manufacturer?
-
How do I get my company added to EPA's
list of manufacturers, suppliers, and vendors?
-
How do I propose a product for
designation?
-
How are the CPG requirements
enforced?
Q: How are products selected for designation in the CPG?
A: EPA reviews a broad list of potential products made from recovered materials. EPA compiles this list through various sources of publicly available information and includes items previously researched and still under consideration by EPA.
Q:
How does EPA evaluate the products?
A: RCRA requires EPA to consider several criteria when determining which items it will designate, including the availability of the item; the potential impact of procurement on the solid waste stream; the economic and technological feasibility of producing the item; and other uses of the recovered materials used to produce the item. EPA also considers comments from end users, manufacturers, distributors, the general public, and other interested parties through a formal rulemaking process to designate items.
Q:
Who is required to buy recycled content products?
A: The RCRA requirement to buy products containing recovered materials applies to procuring agencies that spend more than $10,000 a year on that item. Procuring agencies are federal, state, and local agencies, and their contractors, that use appropriated federal funds. For example, if a county agency spends more than $10,000 a year on an EPA-designated item and part of that money is from appropriated federal funds, then the agency must purchase that item made from recovered materials. Agencies may elect not to purchase designated items when the cost is unreasonable; inadequate competition exists; items are not available within a reasonable period of time; or items do not meet the agency's reasonable performance specifications.
Q:
What is an affirmative procurement program?
A: Within one year after EPA designates an item in the CPG, RCRA section 6002(i) requires each procuring agency purchasing more than $10,000 of that item, or functionally equivalent items, in a fiscal year, to establish an affirmative procurement program for that item. For more information, download a summary of requirements for affirmative procurement programs (PDF) (8 pp, 146 K, About PDF)
Q:
Are items designated in the CPG "environmentally
preferable" products?
A: Generally, yes. The Executive Order 13423 Implementing Instructions define "environmentally preferable products" as products that have a lesser or reduced effect on human health and the environment when compared to other products and services that serve the same purpose. Multiple attributes may be considered when purchasing environmentally preferable products, including energy use, conservation of resources, and others. Items designated in the CPG reflect one attribute, recycled content, although some products can address other attributes as well.
Q:
What is the difference between postconsumer and recovered
materials?
A: Postconsumer material means a material or finished product that has served its intended use and has been diverted or recovered from waste destined for disposal, having completed its life as a consumer item. Recovered material means waste materials and byproducts that have been recovered or diverted from solid waste, but does not include materials and byproducts generated from, and commonly reused within, an original manufacturing process. Postconsumer material is a subset of recovered material.
Q:
How do we know if products contain the recovered content
claimed by the manufacturer?
A: It is the responsibility of the procuring agency, as part of its affirmative procurement program, to obtain estimates and certifications of recovered materials content and, where appropriate, reasonably verifying these estimates and certifications.
Q:
How do I get my company added to EPA's list of
manufacturers, suppliers, and vendors?
A: If your company produces a designated item with recovered material content within the ranges recommended by EPA in its RMAN, send a letter to Anthony Carrell, Office of Solid Waste (name changed to Office of Resource Conservation and Recovery on January 18, 2009), US Environmental Protection Agency, at 1200 Pennsylvania Avenue, NW (Mail Code 5306P), Washington, DC 20460. Include publicly available information that substantiates the recovered material content of your product.
Q:
How do I propose a product for designation?
A: See the Suggest a Product page.
Q:
How are the CPG requirements enforced?
A: RCRA does not authorize EPA or any other federal agency to enforce the provisions of section 6002 and the guidelines. The requirements to purchase EPA-designated products and other products with energy or environmental attributes are enforced through (1) annual reporting to the Office of Federal Procurement Policy and Office of the Federal Environmental Executive, (2) inclusion of green purchasing on the OMB environmental stewardship scorecard, and (3) agency annual compliance monitoring of implementation of the green purchasing requirements.
