DEEP: Establishing a Reverse Distribution Program for Recycling Mercury-Added Lamps

Establishing a Reverse Distribution Program for Recycling Mercury-Added Lamps

Why recycle mercury-added lamps?
Mercury-added lamps are an energy efficient lighting option when compared to incandescent lamps. However, mercury-added lamps, including commonly used fluorescent lamps, should be recycled to prevent mercury from entering the environment. Some lamp wholesalers and distributors have established programs to take the spent lamps back from their customers and send them off for recycling. This system is commonly referred to as reverse distribution.

What is a reverse distribution recycling system?
Under a reverse distribution system, a lamp wholesaler accepts spent mercury-added lamps from its customers, aggregates them, and sends them off to a recycling facility. When the wholesaler delivers new lamps, they also arrange to pick up the spent ones in the same trip.

What are the benefits of participating in a reverse distribution lamp recycling program?
All users of mercury-added lamps, except for household users, are required by law to recycle their spent mercury-added lamps. Therefore such users, especially small businesses, may find a reverse distribution program a more convenient and economic way to properly recycle their spent lamps. By establishing a reverse distribution program, wholesalers are able to provide an additional service to their customers.

What regulations will a wholesaler need to follow?
A lamp wholesaler that elects to transport and/or store spent mercury-added lamps will need to follow a set of regulations collectively know as the Universal Waste Rule. A complete list of the Universal Waste Rule requirements are found in Section 22a-449(c)-113 of the Regulations of Connecticut State Agencies. You can also refer to the Universal Waste Rule Environmental Program Fact Sheet for general information.

Can a wholesaler accept lamps from their customers?
Yes. Under the terms of the Universal Waste Rule, a lighting wholesaler may accept spent mercury-added lamps from a business or residential customer. The wholesaler may aggregate the lamps at its facility or transport them directly from the customerís location to the recycling facility. The wholesaler may also accept spent lamps from customers who purchase their lamps over the counter.

Can a wholesaler store and aggregate lamps at its facility?
Yes. Under the terms of the Universal Waste Rule the wholesaler may accept spent lamps brought to the facility by customers, transported to the facility by the wholesaler or other transporter, or transported from another wholesale location. The spent lamps must be stored in accordance with the Universal Waste Rule, including labeling the containers, storing the lamps to prevent breakage, and immediately cleaning up any broken lamps .

How many spent lamps can a wholesaler store at any one time?
There is no set limit. However, the spent lamps must be stored safely and in a manner that minimizes the chance of breakage. A wholesaler who stores more than 5,000 kilograms (about 11,000 pounds) of lamps at any point in time will be considered a Large Quantity Handler of Universal Waste and will need to obtain an EPA identification number from DEEP. If the wholesaler stores less than 5,000 kilograms, an EPA identification number is not necessary for the storage of spent lamps.

Where does a wholesaler send the lamps?
DEEP maintains a list of lamp recycling facilities and brokers in the northeast.

How are lamps transported to a recycling facility?
A user of mercury-added lamps, wholesalers, or common carriers may transport the spent lamps. The lamps must be transported in accordance with the standards of the Universal Waste Rule.

Some wholesalers have more than one site in the state. Do the regulations allow a wholesaler to transport the spent lamps to another wholesale location?
Yes. The Universal Waste Rule does allow a wholesaler to transport their lamps from one location to another in the state.

What regulations apply if the wholesaler wants to send the spent lamps to a facility in another state?
Connecticut's Universal Waste Rule dictates how the spent lamps are transported within this state. States in the Northeast have adopted laws and regulations that allow for the transportation of these spent lamps. Once the spent lamps are transported across the border into a neighboring state, the laws and regulations of that state are in effect. Check with the applicable state(s) for information on their regulations prior to shipping any spent lamps.

What other obligations do lighting wholesalers have?
Under Section 22a-619(2)(i) of the Connecticut General Statutes, anyone who sells mercury-added lamps to the owner or manager of any industrial, commercial, or office building, or to anyone who replaces or removes from service outdoor lamps that contain mercury, shall clearly inform the purchaser, in writing on the invoice for the lamps or in a separate document, that the lamps contain mercury, a hazardous substance that is regulated by federal and state law, and that they may not be placed in the solid waste destined for disposal.

Other than a reverse distribution recycling system, what are other ways a lamp wholesaler can recycle spent mercury-added lamps from their customers?

  • The lamp wholesaler can inform their customers about bringing their spent lamps to a household hazardous waste collection event, if applicable, or provide their customers with a list of lamp recyclers.

  • The lamp wholesaler can enter into a contract with a lamp recycling facility or an independent transporter that will pick up the customer's lamps to be recycled.

  • The lamp wholesaler can accept lamps that are delivered directly to the wholesaler by the customers.

  • The lamp wholesaler can accept lamps from customers who come into the facility to buy lamps over the counter.

What about "low mercury" lamps? How are they regulated?
In Connecticut, all mercury-added lamps, except those used by households, must be recycled. DEEP strongly encourages households to bring their spent lamps to a household hazardous waste collection event. Although low mercury lamps are not considered hazardous waste, they still must be managed in the same manner as hazardous waste lamps.

Contact Information and Assistance

Related Fact Sheets and Other Information
Recycling Information
Lamp Recycling (NEWMOA)

All environmental fact sheets are designed to provide basic information and to answer general questions. You must refer to the appropriate Connecticut General Statutes for the specific definitions and statutory requirements. 

Content Last Updated on December 18. 2006

Fact Sheets List