Are LED Lamps Considered Universal Waste? How To Dispose of LED Lamps Properly

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LED lamps are the latest innovation in energy-efficient lighting and offer exciting benefits ranging from electrical efficiency to novel lighting form factors such as LED strip lights.

The being said, some of the first LED lamps to hit the market are now more than five years old. Although LED lamps have been, and continue to be marketed as lasting a long time, the unfortunate reality is that many of the initial LED lamps to hit the market are either failing to meet their longevity promises, or simply lack the efficiency performance or color quality that consumers have come to expect from LED lighting today.

This is especially true among our customers, who find that the first generation LED lamps they initially installed are simply not good enough for their needs, and are looking for high CRI or flicker-free lighting options. As a result, a common question we receive, is: after replacing old LED lamps, where do you dispose of the old LED lamps? What are the regulations and requirements for their disposal?

LED Lamps: No Mercury, but Still Considered Universal Waste

The United States EPA has several regulations surrounding the disposal and management of potentially hazardous materials. Universal Waste is a class of materials that are widely produced and used, but have the potential to harm the environment. Household items such as batteries and lamps are considered Universal Waste, and as a result, when you visit your local landfill or waste company, you will likely see a separate section designated for such materials.

You are likely familiar with regulations surrounding fluorescent lamps and their disposal, due to the high levels of mercury that these lamps contain. One of the benefits of LED lighting, however, is that there are no hazardous chemicals such as mercury.

While LED lamps are indeed much safer from a chemicals perspective, they do contain circuitboard components and other materials that the US EPA designates as Universal Waste, due to the high concentration of metals such as copper. While it might intuitively seem that LED lamps should not be subject to Universal Waste due to their lack of mercury, the EPA maintains a relatively broad definition of "Lamps" as defined in Section 237.9:

Lamp, also referred to as “universal waste lamp” is defined as the bulb or tube portion of an electric lighting device. A lamp is specifically designed to produce radiant energy, most often in the ultraviolet, visible, and infra-red regions of the electromagnetic spectrum. Examples of common universal waste electric lamps include, but are not limited to, fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide lamps.

What is the Best Way to Dispose of LED Lamps?

Each jurisdiction and locale will have different rules and regulations regarding the disposal of LED lamps. For regular household volumes, your local landfill or waste management company will likely have reasonable fees or quotas on LED lamp disposal. For example, they may accept up to 30 lamps for free, after which they may charge a certain fee per pound or per lamp.

Because LED lamps are still relatively new, staff at the landfill facility may not be familiar with whether or not LED lamps are subject to Universal Waste regulations. We would recommend starting with the assumption that the LED lamps are subject to the same regulations as fluorescent lamps, as this will likely save you a lot of time and trouble.

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