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Since then, there have been concerns in the scrap recycling industry as to whether or not airbags were considered hazardous materials. Auto recyclers, shredder operators, and other airbag stakeholders were left with a number of regulatory questions about both Takata and non-Takata airbags that remained in vehicles destined for recycling.

Why this matters … Were the issue not clarified, a fear existed that decades old vehicle recycling processes would be no longer exempt under the Resource Conservation and Recovery Act (RCRA).

But, but, but … Through a number of outreach efforts, including a face-to-face meeting, ReMA raised these concerns with the EPA. On behalf of its members, ReMA advocated for the EPA to issue a clarifying memo with guidance for recyclers that routinely recycle vehicles containing airbags. These efforts proved successful when the EPA issued such a memo dated July 19. Among other items, the memo confirms that airbags remaining installed in vehicles are considered part of the vehicle being recycled and are, therefore, exempt scrap metal under RCRA. The full memo, along with a summary of regulatory interpretations is available to ReMA members.

For more information about airbags or this memo, please contact David Wagger or Billy Johnson.