Why EPA Definitions Matter

 The EPA designates separate regulatory paths depending upon what happens to an aerosol can's major constituents: propellant, contents, can, plastic

The Difference between "Recycling through Energy Recovery" and "Recycling through Reclamation"

In terms of aerosol options, the term “recovery” is a general term rather than an EPA term. It refers to “recovering” some value from a product or part of a product that would otherwise be waste. “Recovery” only means that some value is extracted before disposal or recycling. It does not specify how much.

“Reclamation” means that a substantial portion of the total product is reused in a manner consistent with its original purpose. When aerosol constituents are part of fuel-blending, something  is “recovered” from what would have been waste, but its constituent elements are not “reclaimed” because they are not used for their original purposes. According to EPA Memoranda, “reclaimed” items  are those “regenerated” or recovered “as a usable product” (RO 11726).  A “usable product” is one that can be effectively substituted for a commercial product or that has value as a commodity. "Reclamation” is a higher level of recycling than “recovery."

Why Aerosol Cans Sent to Us are Not "Waste"

When the product and propellant within an aerosol can are “reclaimed” in substantial proportion, meaning that these elements are managed as “valuable commodities” and are reused in a manner consistent with their normal use (rather than energy recovery), they are classified as “commercial chemical products” by USEPA (40 CFR 261.2 (c)(3)).  Commercial chemical products are “solid wastes only if thrown away, and so are not solid waste if reclaimed” (RO 13490, references 40 CFR 261.2 (c)(3)).

EPA Waste Management Hierarchy

The EPA Waste Management Hierarchy places  “Reuse” just under “Reducing Waste” (and above “Recycling”) because when the constituents of a product are “reclaimed” for use in their original purposesas valuable goodsthe resources that would have been put into manufacturing new commercial products are saved.