Federal deregulation efforts and shifting trade rules are reshaping the outlook for electronics reuse and recycling, leaders of the Recycled Materials Association (ReMA) told attendees at the E-Scrap Conference 2025 in Grapevine, Texas.
Kristen Hildreth, ReMA vice president of government relations and public policy, and Erin McCoy, international trade policy analyst, described a fast-moving policy environment that stretches from federal agencies to Congress and international trade bodies.
Hildreth said the second Trump administration has relied heavily on executive orders while pressing agencies to roll back regulations, particularly in environmental and energy arenas, noting that the Office of Management and Budget has urged regulators to move faster and consider shorter public comment periods.
At the same time, staff reductions and early retirements are eroding expertise at agencies such as the EPA’s Office of Resource Conservation and Recovery, where notices of intent to reduce staff could affect work on batteries and electronics, and the prolonged shutdown this fall slowed or paused many projects.
Alongside those constraints, Hildreth pointed to several initiatives that could directly touch electronics operations. Under the Infrastructure Investment and Jobs Act, EPA is developing battery collection best practices and labeling guidance for devices ranging from small consumer products to large electric vehicle packs, while EPA and the Department of Energy build a national extended producer responsibility (EPR) framework that many expect will be used by states as a template.
Within the DOE, nearly $1 billion in funding announced in August for batteries, critical minerals and rare earth recovery offers chances for recyclers that partner with universities or public agencies or propose pilot projects, although roughly $700 million in earlier battery manufacturing grants were canceled during the recent shutdown.
On Capitol Hill, Republicans control both chambers and the White House and are centering work on taxes, health care, technology and artificial intelligence, while a relaunched House recycling caucus has created a new forum to discuss industrial and commercial material streams as well as residential ones.
Hildreth highlighted measures such as the Steward Act, a package of recycling infrastructure and data provisions, and the Promoting Resilient Supply Chains Act, which would tell the Department of Commerce to treat recycling and reuse as essential to supply chain security. She said lawmakers are starting to ask whether domestic recyclers can handle growing volumes from data centers and artificial intelligence investments.
Hildreth urged companies to answer those questions directly by talking more openly about their performance and investment when they meet officials.
“Sometimes, and I say this very lovingly, y’all aren’t the best at telling everyone how great of a job you’re doing, or how much material you’re moving or the new investments that you’ve made to process more”, she said.
McCoy turned to the trade picture and said electronics reuse and recycling businesses sit inside an unusually dense web of tariffs and trade remedies. She noted that most cross-border electronics trade takes place within North America or among countries in the Organization for Economic Co-operation and Development and that an Article 11 arrangement linked to the Basel Convention allows continued trade in many scrap streams even though the US is not a party to Basel.
She said Section 232 investigations are becoming more frequent and faster, with timelines that can shrink to three to six months and with fewer public hearings.
The US-Mexico-Canada Agreement is due for its first review in 2026 and ReMA plans to submit written comments and testify at a public hearing to defend rules of origin provisions that keep qualifying North American recycled content moving duty free, McCoy noted.
In the longer run, she said, export controls are becoming a larger part of the policy conversation around critical materials, citing a copper Section 232 investigation in which export restrictions were proposed for the first time, although the White House ultimately chose a requirement that part of the highest quality material remain available to US buyers.
The biggest risk is losing market access, she said, adding that companies should think now about diversifying the countries they ship to and the suppliers they rely on.
And while tariffs are already changing some business calculations, the upside is that refurbishers could see more business opportunities, she said. “Because people are not going to be buying new electronics from overseas, they won’t be able to access certain markets, so maybe they’re going to be using things already here, domestically more.”
