Retailers face serious challenges in complying with their obligations under Resource Conservation and Recovery Act (“RCRA”) and other federal environmental statutes in light of the wide variety of retail products covered by EPA’s waste disposal regulations. EPA recently expressed its intent to consider future rulemaking under RCRA governing retail products unsold, returned, or removed from

The Environmental Protection Agency (“EPA”) has announced that it plans to explore future rulemaking on the management of “waste retail products” under the Resource Conservation and Recovery Act (“RCRA”).  Waste retail products include unsold or returned retail products which may at some point become hazardous waste under current RCRA regulations.  According to the Unified Agenda