New ELI Report Illustrates Opportunities for Materials Recovery and Reuse in the Retail Sector

May 2018

Simply by virtue of the gas inside them, discarded aerosol cans are treated as hazardous waste under the Resource Conservation and Recovery Act (RCRA). But these same cans, when disposed of by consumers, are treated as household solid waste, meaning they can be managed or recycled differently, including ways that involve substantial steel and aluminum recovery from municipal waste management. A new report from ELI examines materials recovery and recycling in the retail sector, using consumer aerosol cans as an example.

Aerosol cans account for nearly half of the RCRA-regulated material in the retail sector, driving the status of retail stores as large-quantity generators. When treated as hazardous waste, the vast majority of cans are incinerated, posing enormous costs for the retailer and, eventually, the consumers. Yet the metal from the cans and the propellant contained inside them are recoverable, recyclable, and/or reusable.

“Reharvesting these materials can be undertaken in an environmentally protective manner,” said ELI President Scott Fulton. “The question now is whether RCRA should be turned more decisively in the direction of resource conservation and recovery.”

As explained in the report, minimizing waste generation includes the diversion of waste streams for reuse and recycling as well as the recapture of materials. In devising new approaches for the management of materials and the diversion of wastes under RCRA, federal regulators can draw on their knowledge and years of experience working with particular sectors and materials.  Federal regulators can also draw on additional sources of authority. For example, §101(b) of the National Environmental Policy Act (NEPA) expressly directs the federal government to improve and coordinate its “plans, functions, programs and resources” to “enhance the quality of renewable resources and approach the maximum attainable recycling of depletable resources.” Steps in this direction include EPA’s recently proposed rule to classify at least some aerosol cans as “universal waste.” This rule, whose comment period closed May 15, would allow discarded “intact” aerosol cans to be accumulated for longer periods and sent to a wider array of destination facilities for disposal or recycling.

“Sustainability and smart materials management are core objectives in much of the business community,” said Fulton. “At their root, these objectives are grounded in conservation thinking, focused on designing products with end-of-life in mind and strong reuse and recycling programs, allowing for an increasingly circular economy.”

The full report, RCRA and Retail: Considering the Fate of Consumer Aerosol Cans, can be downloaded for free at:

James M. McElfish, Jr., lead author of the report, is available for interview.