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THE COLLECTION AND RECYCLING OF USED COMPUTERS USING A REVERSE

DISTRIBUTION SYSTEM

A PILOT PROJECT

WITH STAPLES, INC.

EXECUTIVE SUMMARY

FROM THE FINAL REPORT TO THE

U.S. ENVIRONMENTAL PROTECTION AGENCY

Developed by:

Product Stewardship Institute, Inc.

137 Newbury Street

Boston, MA 02116

(617) 236-4855

www.productstewardship.us

June 2005

http://www.productstewardship.us/

Product Stewardship Institute, Inc. FINAL June 2005

EXECUTIVE SUMMARY1

PROBLEM STATEMENT

Used electronic products are one of the fastest growing waste problems in the world. A study by

the National Safety Council found that only 11-15 percent of computers were being reused or

recycled in 1998, and that electronics recycling is still unavailable or very expensive in many

United States cities and towns. Lead is found in the cathode ray tubes (CRTs) in televisions and

computer monitors. Electronic components contain other toxic substances, including cadmium

and phosphorous in CRTs, lead solder and copper on circuit boards, mercury in laptop displays,

lithium batteries, and brominated flame retardants in the plastic housing. These toxic materials

can be released to the environment from waste management or recycling practices, making it

imperative that discarded electronics are handled safely with regard to human health and the

environment. In addition, reusing and recycling electronics creates economic value, saves

resources and energy, and creates more jobs than disposal.

GOAL STATEMENT

The goal of the project was to collect and recycle unwanted electronics from Staples’ retail and

commercial customers using its existing product distribution network, and to evaluate whether

this approach represents a sustainable business model for Staples.

PROJECT CONCEPT

Since retailers are a direct connection to consumers of electronics, they are considered logical

points for consumer education, and potential take-back sites for used products. Many retailers

already manage used electronic products from returns, lease exchanges, and the replacement of

their own equipment at a cost that could be reduced or eliminated through a national electronics

management system. A few companies have even conducted voluntary take-back pilot projects

from retail customers. However, none of the financial models for calculating costs for a national

collection, transportation, and recycling infrastructure had considered the cost savings from

backhauling used electronics by reversing the existing distribution system.

This project tested this collection model in the northeast, using Staples’ product delivery

networks around the Killingly, Connecticut, distribution center (for retail products), the Putnam,

Connecticut, fulfillment center (for commercial products), and the North Reading and Sharon

transportation hubs in Massachusetts. Staples collected all brands of used computers at retail

stores located in Maine, Massachusetts, New Hampshire, Rhode Island, and Connecticut, and

from commercial customers in Massachusetts, New Hampshire, and Connecticut. The collected

equipment was backhauled by Staples’ carriers and consolidated at its distribution and

fulfillment centers, then transported via Staples’ trucks to Envirocyle, an electronics recycler, in

Hallstead, Pennsylvania.

1 The full report (including this Executive Summary) is available at

http://www.productstewardship.us/pilot_takeback_staples.html and www.plugintoecycling.org.

http://www.productstewardship.us/pilot_takeback_staples.html

http://www.plugintoecycling.org/

Staples Pilot Project –Final Report to U.S. EPA Executive Summary

Product Stewardship Institute, Inc. - 3 - FINAL June 2005

COLLABORATIVE PROJECT/PARTNERS

This project evolved from a joint meeting in April 2003 between representatives of Staples, Inc.

(headquartered in Framingham, MA), the Product Stewardship Institute, Inc. (Boston, MA), and

the U.S. Environmental Protection Agency/New England (Boston, MA). After PSI evaluated

Staples’ potential financial exposure and showed how costs could be contained, the company

contracted with PSI to design a pilot project for recovering computer equipment from its

customers. PSI and Staples enrolled in EPA’s “Plug-In To eCycling” pilots, which added

government financial and technical support, promoted cost-sharing incentives for manufacturers

and recyclers, and brought greater recognition for Staples.

Prompted by a January 2004 Plug-In To eCycling press event at the annual Computer Electronics

Show, the project gained the support of 10 manufacturer partners (see Table 1). Each partner

signed a memorandum of understanding (MOU) that committed these companies to pay for the

cost of recycling their brand of computer equipment and a share of the cost of recycling non-

participant brands, including equipment manufactured by companies no longer in business, up to

a $10,000 cap. Additional partners included a recycler and five state agencies.

Table 1. Project Partners

Staples, Inc.

Product Stewardship Institute, Inc.

U.S. Environmental Protection Agency/New England and Headquarters

Envirocycle, Inc.

Connecticut Department of Environmental Protection

Maine Department of Environmental Protection

Massachusetts Department of Environmental Protection

New Hampshire Department of Environmental Services

Rhode Island Department of Environmental Management

Apple Computer, Inc.

Brother International Corp.

Dell

Epson America, Inc.

HP

Intel

Lexmark International, Inc.

Panasonic

Sharp Electronics Corporation

Sony Electronics, Inc.

TIMEFRAME

The pilot collections ran for six weeks, from May 29 through July 11, 2004.

PRODUCTS ACCEPTED

The pilot project accepted computer equipment, including computer processing units (CPUs),

computer monitors, laptops, large peripherals (e.g., printers, multi-fax devices, facsimile

machines, desktop copiers, scanners), and small peripherals (e.g., keyboards, mice, speakers,

cables).



GENERAL OPERATIONS

Retail Operations

Computer equipment was collected at no charge at a cross-section of 27 Staples retail stores in

five states: Maine (10 stores), Massachusetts (8 stores), New Hampshire (5 stores), Connecticut

(3 stores), and Rhode Island (1 store). Equipment was shipped in the same manner as returns

(using reverse distribution) to the distribution center (DC) in Killingly, Connecticut.

Commercial Operations

Computer equipment was collected at no cost from 14 commercial customers in three states that

receive direct delivery of goods at their place of business by Staples’ trucks or common carrier.

Staples either picked up the equipment upon delivery of new products, as part of Staples’ typical

process for returning products that are defective, damaged, or otherwise unwanted, or scheduled

a separate pick up. Other equipment was “live loaded.” Gaylords were transported back (using

reverse distribution) to the fulfillment center (FC) in Putnam, Connecticut, or consolidated at

either the Sharon or North Reading, Massachusetts, transportation hubs for a line haul the next

day to the FC. Staples also took advantage of space on Envirocycle trucks from loads that were

being hauled from other electronics collection events in Massachusetts and Connecticut back

down to the Envirocycle facility.

Transportation to Recycler

When a tractor-trailer load of equipment accumulated at either the DC or FC, Staples’ trucks

transported the computers to Envirocycle in Hallstead, Pennsylvania. Typically, when Staples

had more than 22 pallets collectively at the DC and FC, it arranged for joint shipment of

commercial and retail mixed material to Envirocycle.

PROJECT RESULTS

Data Collection

The pilot project collected data that enabled Staples to understand the degree to which the

reverse distribution collection approach could be part of the company’s sustainable business

model, and how it could be implemented on a national scale. The retail and contract customer

satisfaction surveys helped PSI to evaluate the program from the users’ perspective. The data

collected will enable Staples to make adjustments and improvements to any future program

expansion that it plans to undertake, in which case there will be an ongoing need for data systems

to track equipment shipments, costs, and customer satisfaction.

Materials Collected: Units and Weights

PSI collected data in three ways for the retail and commercial collections:

(1) Data provided by Envirocycle, which combined retail and commercial loads;

(2) Data tabulated from surveys filled out by customers at the retail locations; and

(3) Data tabulated from surveys filled out by commercial clients.



The total number of units of computer equipment collected was 4,522, weighing 107,360

pounds, and costing $7,983.10 to recycle (see Table 2). Although Staples advertised that it would

only accept computer equipment, an additional 735 units of audio/visual and other equipment

were collected, bringing the total number of units collected to 5,257. The non-computer related

units represented approximately 14 percent of the total number of units collected. The total

weight of all material collected was 115,028 pounds, costing $8,519.86 to recycle, for an average

cost per pound of 7.4 cents, and an average weight per unit of 21.88 pounds. Between 38% and

50% of monitors, CPUs, and large peripherals returned by customers was manufactured by

companies that were not partners in the pilot project.

Table 2. Staples/PSI Pilot Project – Collection Summary/All Equipment

* $4.00/monitor; no charge for CPUs; $.07/pound for all other products

Product Number Of Units Pounds Cost*

Computer Monitors 1,642 62,396 $6,568.00

CPUs 1,076 24,748 $0

Small Peripherals 649 10,386 $727.00

Printers/MFDs/Fax/Desktop Copiers/Scanners

1,089 8,843 $619.01

Laptops 66 987 $69.09

SUBTOTAL — COMPUTER EQUIPMENT 4,522 107,360 $7,983.10

Audio/Visual Equipment 645 4,516 $316.12

Other 90 3,152 $220.64

TOTAL – ALL EQUIPMENT 5,257 115,028 $8,519.86

Retail Customer Surveys at Retail Locations

As part of the retail customer survey results that PSI tabulated (see Table 3), 1,351 retail

customers (81%) said they brought equipment from their home and 308 retail customers (19%)

said the equipment was from their business. Some of the customers operated a small business, or

were municipal officials and school employees, while the vast majority were residents. Table 3

also indicates that the vast majority of equipment came from storage, most people are willing to

pay a fee to recycle their computers, and a significant number of people heard about the program

through a store flyer or display.

Table 3. Staples/PSI Pilot Project Retail Survey Data

Equipment From Equipment Willing To Pay A Recycling

Fee In The Future Heard About The

Program From

Home Office Being Used

From Storage Yes No

Store Flyer

Store Display Other

1351 308 529 1095 1008 507 260 483 845



Contract Customer Surveys at Commercial Locations

Data from the 14 contract customers that participated in the pilot project were parsed into the

following categories:

Equipment type collected by business and by brand.

Equipment type collected by business.

Equipment type collected by major brand.

There were 636 units of equipment collected, totaling 13,226 pounds, at a recycling cost of $752.

Customer Satisfaction

PSI developed a Retail Customer Satisfaction Survey and a Contract Customer Satisfaction

Survey, which it administered by phone to a limited number of pilot project participants.

Retail Customers

Customer responses were overwhelmingly positive, and they wanted the program to

continue. From an operational perspective, the program was easy to implement.

Customers that brought in equipment did not want to dispose of it in the garbage but were

looking for an opportunity to recycle it. Staples provided that opportunity. Many cited

environmental reasons (e.g., toxics) for why they did not want to put it in the garbage. Others

stored the equipment in belief that there was still value to it.

Most customers were willing to pay a fee for the recycling service. (Even so, it must be kept

in mind that those who participated in the recycling program are a subset of all those who

have computers that need to be recycled. Those participating in recycling programs would

be more likely to pay to participate than those who are not motivated to recycle their

equipment.)

Contract Customers

Each company believed that Staples provided a valuable service and made it easy to collect

the equipment. All wanted to see the program continue; the average need for service per

company was estimated to be 1 or 2 times per year.

The program cleared out space where the computers used to be stored, so employees were

happy with the result. Employees were unaware of recycling options.

Most of the companies contacted said that they would be willing to pay to recycle their

equipment in the future, since most understood that they were actually required to safely

manage their products. However, almost all said that they would only use Staples for this

service if their price was competitive with alternative options. With that said, many thought

there was an added value to ordering supplies from the same company that took back the

used computer equipment.



Several companies wanted to receive a certificate of data destruction to ensure that

confidential information was wiped clear off the computers. Since this assurance was only

possible for recycled, and not reused, equipment, Staples did not offer reuse.

PROMOTION/ADVERTISING AND CUSTOMER EDUCATION

Staples took a cautious approach to promotion of the recycling program to keep from getting

inundated with equipment. This allowed the company to remain under budget, keep its focus on

the operations, develop buy-in from the whole Staples team, and develop a clear picture of what

will be required to successfully roll this program out nationally. By design, Staples promoted the

program slowly and ramped it up slowly. It never fully contacted all the media outlets, and kept

the program low-key throughout the six weeks. Much of this focus was on an in-store flyer, store

display, and banner. Six newspapers in Massachusetts, five papers in Maine, and one trade

publication ran stories about the program.

PROJECT COSTS

The cost of collecting, transporting, and recycling 115,028 pounds of retail and commercial

equipment collected in this pilot project was $93,432, or 19.9 cents per pound (see Table 4).

Table 4. Pilot Project Costs by Phase and Funding Source.

* Envirocycle’s recycling costs for this pilot project (7.4 cents per pound, on average) were approximately one-third the market rate (about 20 cents per pound). Bolded items have been used to calculate the cost per pound.

Who Paid Project Phase Cost

U.S. EPA Project Implementation/Evaluation $46,541

Staples Project Design $17,000

Handling/Collection – Retail (northeast region) $1,870

Transportation to DC and Envirocycle (northeast region) $11,355

Delivery of Pallets – Commercial (northeast region) $72

Pallet Pick Up/Delivery To FC and Envirocycle – Commercial (northeast region)

$1,044

Promotion, Staff training, Administrative Staff $7,030

Manufacturers Recycling $8,520*

TOTAL COST $93,432

Retail Collection Costs

Staples internal cost for the 27 retail collections includes the cost of handling the computer

equipment in the store, transporting to the DC, and transporting to Envirocycle in Pennsylvania.

Staples treated retail returns of used electronics in the same manner as it treated other returns,

and shipped equipment in its own trucks to the DC. Staples hauled 377 pallet loads of computers

(equal to 17.14 trailer loads), at a handling cost of $4.96 per pallet and a cost to ship them to the

Killingly DC of $9.67 per pallet. Staples also incurred costs of $450 per trailer load to transport

to Envirocycle from the DC, equal to $20.45 per pallet. The total cost, therefore, to collect and

transport 377 retail pallet loads to Envirocycle through the DC was $13,225.16, or $35.08 per



pallet (see Table 5). The cost to collect and transport this retail equipment to Envirocycle prior to

recycling was 8.9 cents per pound. Adding to that the average price per pound to recycle the

equipment of 7.4 cents per pound, the total cost to collect, transport, and recycle retail equipment

in this pilot project was 16.3 cents per pound. If Staples had to pay the market recycling rate

(estimated at 20 cents per pound delivered at the facility gate), this total cost would equal about

28.9 cents per pound.

Table 5. Pilot Project Retail Collection Cost: Handling, Shipping, and Transportation

Cost Type Per Pallet

Cost Per Pound

Cost

Handling $ 4.96 1.26 cents

Shipping to Distribution Center $ 9.67 2.45 cents

Transport to Envirocycle $20.45 5.19 cents

TOTAL COST $35.08 8.90 cents

Staples and PSI used the following assumptions:

• 1 system = 3 units

• 6 systems = 1 pallet (Gaylord)

• 22 pallets = 1 trailer load

1 unit = 21.88 pounds (from Table 2)

1 pallet = 393.84 pounds

To calculate the following:

• $771.76/trailer load

• $ 35.08/pallet

• $ 5.85/system

• $ 1.95/unit

Costs in the New England corridor, however, are lower than the company’s nationwide average

given the northeast’s proximity to the DC and short transit times to stores. The national average

cost to ship a pallet of computer equipment from the store to the DC is estimated to be $28.53

per pallet (see Table 6). Therefore, if the pilot was expanded nationally, the cost to handle each

pallet and transport it to a qualified recycler through one of the company’s four DCs would be

$53.94, or 13.7 cents per pound. This cost assumes that the handling cost is $4.96 per pallet, and

that a qualified recycler will be within a 250-mile radius from a DC, which was the distance from

the Killingly DC to Envirocycle in this pilot project. Since Staples will seek to find a recycler at

a closer distance, this 13.7 cents per pound figure should be considered an upper amount.

Adding to that the average price per pound to recycle the equipment of 7.4 cents per pound, the

total cost to collect, transport, and recycle retail equipment nationally would be 21.1 cents per

pound. However, if Staples paid the market recycling rate (estimated at 20 cents per pound

delivered at the facility gate), this total cost would equal about 33.7 cents per pound.

Table 6. Average National Estimated Retail Collection Cost: Handling, Shipping, and Transportation

Cost Type Per Pallet

Cost Per Pound Cost

Handling $ 4.96 1.26 cents

Shipping to Distribution Center $28.53 7.24 cents

Transport to Qualified Recycler (<250 miles) $20.45 5.19 cents

TOTAL COST $53.94 13.69 cents

As Table 6 indicates, in a national effort, there would be a marked difference in cost from the

northeast pilot project. The cost to recycle in other regions of the country would vary from the

national average depending on the distance to the DC from a retail location and the distance from



the DC to a qualified recycler. There are four Staples’ DCs in the country – in Connecticut,

Maryland, Indiana, and California.

Commercial Collection Costs

Staples also calculated its internal costs for collecting 636 units of equipment from 14 contract

customer locations. Based on the data in Table 7, the full cost to collect and transport 35.33

pallet loads to Envirocycle through the FC would be $1,116, or $31.59 per pallet. Using an

estimated weight of 21.88 pounds per unit (393.84 pounds per pallet) of equipment collected

(from Table 2), the cost to collect and transport this commercial equipment to Envirocycle prior

to recycling is 8.0 cents per pound. Adding to that the average price per pound to recycle the

equipment of 7.4 cents per pound, the total cost to collect, transport, and recycle commercial

equipment was 15.4 cents per pound. At an estimated market recycling rate of approximately 20

cents per pound, this total cost would equal about 28 cents per pound.

Table 7. Pilot Project Contract Collection Cost: Handling, Shipping, and Transportation

Cost Type Cost

Per Pallet Cost

Per Pound Cost

Delivery of Pallets $72 $2.04 0.52 cents

Pallet Pick Up/Delivery To FC $324 $9.17 2.33 cents

Transport to Qualified Recycler (<250 miles)

$720 $20.38 5.17 cents

TOTAL COST $1,116 $31.59 8.02 cents

Staples and PSI used the following assumptions:

• 1 system = 3 units

• 6 systems = 1 pallet (Gaylord)

• 22 pallets = 1 trailer load

1 unit = 21.88 pounds (from Table 2)

1 pallet = 393.84 pounds

To calculate the following costs:

• $694.98/trailer load

• $ 31.59/pallet

• $ 5.27/system

• $ 1.76/unit

Recycling Costs

The 10 participating manufacturers contributed a total of $8,519.86. Envirocycle offered the

following discounted rates for equipment processing as project partner: $4.00 per monitor; no

charge for CPUs; and $.07 per pound for large peripherals, small peripherals, laptops, and non-

computer equipment.

Other Costs

Promotion, staff training, and administrative staff costs were estimated to be approximately

$7,030. Staples did not believe that storage space for used electronics was a factor that added

cost to the project. Backhaul opportunities on Staples’ trucks are frequent, and the equipment

was treated as a "cross dock shipment" when it got to the DC, where it went immediately into a

trailer with equipment from the FC for shipment to Envirocycle. The time taken by Staples’

technical and managerial staff to plan and implement the pilot project was not estimated.



REGULATORY ISSUES

Federal Guidelines

Under federal regulations, any unwanted electronic equipment containing a cathode ray tube

(CRT), including computers and televisions, is currently considered a hazardous waste under

federal regulation (40 CFR Part 260). Hazardous waste regulations do not apply to household

sources of electronics, or to businesses that generate under 7-8 CRTs per year. States can have

more stringent regulations governing the handling of electronics, and there is no one set of

standards that applies to all states. Therefore, the result is a patchwork of regulations that must be

considered when setting up a program to accept used electronics. This situation might be

alleviated to some degree when the federal regulations for CRT electronics are finalized, as

expected in the fall of 2005, and adopted by the states. The proposed rule is available on the PSI

website, at http://productstewardship.us/pilot_takeback_staples.html. In the interim, the U.S.

EPA has provided guidelines for the safe management of materials (available at

http://www.epa.gov/epaoswer/osw/conserve/plugin/pdf/guide.pdf) for its “Plug In” partners who

collect electronic equipment for the purpose of recycling.

Pilot States Regulations

States have some ability to streamline regulations for electronics product stewardship efforts, and

PSI worked with Staples and state agency officials to identify and comply with the states’

regulatory interpretations. None of the state regulations added significantly to the cost and

complexity of this project. To standardize the handling procedures for all Staples facilities and

associates in the five pilot states, Staples adopted the general guidelines for universal waste

handling, transport, and storage.

PILOT PROJECT BENEFITS

There were numerous benefits to conducting this pilot project, many of which should be

considered when evaluating a national expansion. Each of the following benefits is discussed in

greater detail in the full document, as are the key lessons learned.

Solves a Pressing Environmental Need

Provides a Known Collection Location and Education Opportunity

Creates Good Will

Demonstrates Collaborative Problem Solving

Provides One Stop Shopping

Offers Staples a Promotional Opportunity

Offers Manufacturers a Promotional Opportunity

Establishes Staples as a Brand Leader

Provided an Impetus for Other Retailers to Engage

Enabled Data/Information Sharing

http://productstewardship.us/pilot_takeback_staples.html

http://www.epa.gov/epaoswer/osw/conserve/plugin/pdf/guide.pdf



KEY LESSONS LEARNED

Program was Logistically Feasible: It is feasible for a retailer to take back unwanted

computer equipment at a retail store, or from businesses, using a reverse-logistics collection,

transportation, and recycling model.

Program was Successful. Staples staff, retail customers, and contract customers were

enthusiastic about the program and want it to continue. Over 57.5 tons of equipment was

collected in six weeks from both retail and commercial customers at a cost that was

competitive with other electronics collections.

Staples’ Customers are Environmentally Aware. Retail and commercial customers are

savvy about environmental concerns from electronic wastes. Few questioned the need for

collection.

Staples Customers are Willing to Pay for Computer Recycling (Note: This should not be

used as a reason to charge in the long-term, since there are still a significant number of

people who will not pay. But it can provide funds to start or supplement a program.)

There is a Backlog of Equipment. There is a significant backlog of equipment that needs to

be collected initially from customers, particularly among businesses, making a simple “back

haul” of equipment difficult for a “first time” recycling effort.

Computers Returned from Non-participating Companies were Significant. A significant

percentage of computer equipment returned to the collections came from those that did not

contribute financially to recycling costs.

Manufacturer MOUs Were Time Consuming to Negotiate. Most manufacturers wanted to

change some aspect of the standard MOU, and a few wanted individualized agreements that

were much different from the basic template.

Communication Miscues were Costly. Communication between the recycler and the

Project Team resulted in missed data gathering opportunities and extra time and cost to

extrapolate data (e.g., leaving one company out of the brand sort).

Commercial Collections were Unique. Whereas retail collections followed a noticeable

pattern, Staples needed to arrange contract customer collections individually owing to a

variation in pick up locations and equipment quantities and types. Over time, models should

evolve within these collections, making contract customer service delivery easier.

A Little Promotion can go a Long Way. Taking a low-key promotional approach worked

well for Staples employees and management, even if additional customers could have

benefited by the initial pilot.

Expect Business Equipment. There was a small, but significant, segment of retail customers

who brought equipment used for business, including municipal offices.

Recyclers were Staples Shoppers. Most of those interviewed who returned equipment to

retail stores said that they typically shop at Staples. Few people came into the store only

because of the recycling program, largely owing to the focus on in-store promotion.



Data Quality was Not High. Allowing retail and contract customers to fill out their own

data sheets did not provide high quality data.

Beware of Municipal Regulations During Outreach. Some municipalities would not allow

Staples to advertise using a banner on the exterior of the store.

RECOMMENDATIONS

Whether to expand this computer recycling project nationwide is a decision for Staples

management. However, from the data developed from this project, there appears to be little

doubt that there is a clear need, and opportunity, to expand the collections both at retail outlets

and contract customer locations. The computer recycling service was well received; there are

numerous benefits to expansion; and Staples’ internal costs were reasonable. In addition, any

costs incurred by Staples could be offset by a fee charged to customers, many of whom are

willing to pay to recycle, and/or by manufacturers’ contributions. Adding computer recycling

service to Staples’ growing environmental products and services will solidify Staples’ position as

a company that not only provides quality office products and services, but one that cares about

the company’s impact on the environment and the community served by its retail stores.

Expanding this recycling service would further enhance Staples’ image as a sustainable business.

Those seeking electronics collection service, however, should not place an over-reliance on retail

take-backs, since these programs are undertaken at a company’s discretion. If Staples, for

example, decides to end the program, for whatever reason, this might pull the plug on recycling

if this were the only, or most significant option, available to consumers. Therefore, while the

Staples pilot project should be understood as a significant opportunity for Staples and other

retailers, these retail programs need to become part of a more comprehensive collection and

recycling infrastructure. Listed below are specific recommendations that Staples should consider

in expanding computer recycling services to other areas of the country, or making it permanent

in the five New England states that were part of the pilot project. Each is discussed in more detail

in the full document.

Program Logistics

Treat Used Computers Like A Return. Typical retail product returns are brought to a

customer service representative, who records vital information directly into a computer

database and takes possession of the product. Used computers should follow a similar

procedure, which will ensure quality data, reduce the likelihood of equipment breakage, and

provide a greater level of service. Staples could handle computer returns from businesses at

the point at which orders are placed.

Charge a Recycling Fee. Until a state or national financing system comes into existence,

charge a fee to collect and recycle computer equipment from both retail and commercial

customers. The fee charged to customers will need to be competitive with other recycling

services, particularly among commercial customers, although there is an added value in

having one company – Staples – provide office supplies and recycling services (on the

backhaul) to these commercial customers. Providing a tangible community benefit, as it did



in a separate pilot project for retail customers in the Northwest, would add to the acceptance

of the retail fee.

Recover the Full Recycling Cost in the Recycling Fee. Do not rely on a cost share from

manufacturers in setting the recycling fee owing to the large percentage of computers

collected from non-participating manufacturers. There is a question as to whether

participating manufacturers will continue to cover the costs imposed by manufacturers that

are not taking responsibility for their fair share, and put themselves at a competitive

disadvantage.

Expand the Limit on Equipment Allowed per Retail Customer. Instead of restricting

residents to one computer system, consider expanding the limit on retail customers to 4 or 6

units per customer, as was successfully demonstrated in Staples’ Northwest pilot project.

Some limit will be needed if Staples will want to discourage business equipment.

Identify Business Equipment. Since some states may require that equipment from

businesses be identified and treated differently from equipment from households, ask a

question on the in-take survey as to the origin of the equipment of those entering retail stores.

Phase Collections — Cleanout and Maintenance. Before a maintenance program can be

put in place, anticipate that a large initial amount of material will be generated in areas

without past collections. Conducting equipment clean outs, phasing collections, or ramping

up service will ensure that the program is not inundated with equipment.

Implement a Commercial Equipment Pick-up System: Ensure a chain of custody to better

track equipment and report to customers by assigning a bar code or other identification to

shipments at the point at which the recycling service is ordered.

Develop a Standard MOU with Manufacturers with Few Variations. Dictate the terms

of an agreement and only allow variations in very special circumstances. If a business wants

to collect its own material, it should be required to pay for the cost of separating and

recycling its own equipment.

Assign a Dedicated Staples Daily Contact. Consider assigning an internal dedicated staff

person that could serve as the daily point contact to retrieve data, contact Core Team

personnel, and communicate preferences and decisions.

Promote Reuse. Ask potential recyclers being interviewed for future collections to provide

the cost of adding reuse to the services provided, and the method by which data will be

destroyed. Use domestic reuse organizations until a credible system is put in place for the

return or proper management of electronics sent for reuse to other countries.

Enhance Data Security to Allow for Reuse: In the future, electronics from companies

should be tagged with a noticeable sticker or other identifier to signal to the recycler that

special handling is required (e.g., scrubbing the hard drive to allow for reuse). By instituting

a rigorous procedure that ensures data destruction, reuse might increase for companies that

have newer and, therefore, more marketable, equipment.

Incorporate Recycler Selection Criteria. If expanding computer collections across the

U.S., use the recycler selection criteria developed for the pilot project and determine the



relative importance of the proximity of a recycler to a consolidation point, among other

issues.

Collect Additional Items. Consider collecting and recycling other electronic items that

Staples sells but doesn’t now collect, such as computer discs and other electronic media.

These items should be phased in along an established timetable.

TRAINING AND REGULATORY REQUIREMENTS

Provide Training For Contract Customers. Many of Staples’ contract customers started

recycling their computer equipment during this pilot project. Consider developing training

specific for companies that will need to educate their own employees to start recycling

computers instead of throwing them away.

Handle All Materials Using General Guidelines For Universal Waste. Adopt general

guidelines to abide by the universal waste requirements if expanding the program nationwide

or making it permanent in the five New England states that were part of the pilot project.

Seek to Standardize Regulatory Requirements. Although complying with state regulatory

requirements was not overly burdensome, and PSI received excellent assistance from state

regulatory officials, the process was time-consuming. Standardized regulations will lower the

costs to collect, transport, and recycle electronics. However, if the regulatory requirements

prove to be too cumbersome in some states, consider limiting the initial program to states

with a more relaxed interpretation of how electronics can be safely managed.

Develop a Tracking System for Collected Computers. Staples’ automated return system

already tracks customer information, product type, brand name, and other data. Explore

adapting this return system to accommodate customers bringing used electronics.

Standardize Computer Handling Guidelines And Training For Staples Associates. Refine and standardize training for the national rollout to ensure that it will meet the

regulatory requirements in all states.

DATA COLLECTION, CONTRACTS, AND BUDGET

Maximize Data Collection Capabilities Within Staples. Staples’ pallet-cost collection

system should be supported by more specific methods of per-unit accounting, including the

assignment of bar codes to individual items using methods comparable to Staples’ current

return and exchange procedures.

Calculate Other Costs To Staples. Calculate and budget for total costs that will likely be

part of the national expansion of the collection system, including associate and management

time, storage, equipment and supplies, advertising, and promotion.

Budget for Non-computer Equipment. Expect, and budget for, a certain percentage of

related non-computer equipment, even if it is specifically not accepted as part of the program.

Develop Detailed Contract with Recycler. Develop a detailed contract with the recycler

regarding expectations about the companies for which brand sorts should take place, whether

retail and commercial loads will be tracked separately, the forms used for data collection,



how manufacturer cost shares are to be calculated, who invoices manufacturers for their cost

share, average weights used per equipment type, and which equipment types will be sorted

by brand.

EDUCATION AND OUTREACH

Phase Program Promotion. Continue the practice of phasing in the collection program

concurrent with ramped up advertising and promotion to ensure that staff do not become

overwhelmed by equipment and continue to support the program.

Provide Recycling Education to Staples Customers. When equipment is being collected,

Staples has a unique opportunity to educate retail and commercial customers about why

recycling computers makes sense, what happens to the equipment once it is picked up, what

would happen if the equipment was not collected, and what other products Staples recycles.

Enhance Communication with Partners. Regular communication updates with partners

will enhance project communication and reinforce the common goal toward which all

partners are working – the recycling of computer equipment.

Engage Pilot Partners in Outreach and Education. To increase project visibility, contact

pilot partners to assess the promotional and outreach resources available through these

organizations.

Obtain Local Approval to Exhibit Store Banners. Seek a waiver from the prohibition in

some municipalities to putting a banner on the exterior of the store.

Coordinate with America Recycles Day. Nearly every state has an America Recycles Day

coordinator who would be receptive to a partnership on computer recycling.

PROGRAM EVALUATION

Evaluate Customer Satisfaction. Staples should train its customer service staff to survey

retail and contractor customers to learn valuable lessons about the program.

Provide for Internal Feedback. Staples associates familiar with the recycling program

should provide important feedback on needed improvements.

Communicate Project Results. Holding a briefing at critical junctures in the project

timetable will ensure that project results and implications are understood, and that the feeling

of participating in a joint project is enhanced.

the collection and recycling of used ... › › resource › ...the goal of the project was to...

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