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 6. Other Considerations
As mentioned in the introduction to section II.D, EPA also considers price as a factor
affecting the availability of an item. However, the price of products, whether virgin or
recycled, is affected by many variables, including availability and costs of material
feedstocks, energy costs, labor costs, rate of return on capital, transportation charges, and
the quantity of the item ordered. In addition, price may vary depending on whether the
product is a common stock item or requires a special order. Price can also be affected by
the geographical location of the purchaser because some products may not be uniformly
available throughout the United States. Therefore, the best sources of current price
information for quantities of items to be delivered to specific locations are the manufacturers
and vendors of the recycled content products.
Relative prices of recycled content products compared to prices of comparable virgin
products also vary. In many cases, recycled content products may be less expensive than
their virgin counterparts. In other cases, virgin products may have lower prices than
recycled content products. However, other factors can also affect the price of virgin
products. For example, temporary fluctuations in the overall economy can create
oversupplies of virgin products, leading to a decrease in prices for these items. Therefore,
while price is a consideration, in most cases, it is not a determining factor when selecting
items for designation. It becomes a determining factor only when EPA obtains evidence that
the relative price of an item with recovered materials content is significantly higher than the
relative price of a comparable virgin product. For this reason, EPA did not address price in
the individual item designation discussions presented in sections X-XVI of this document.
ERA also considered the feasibility of designating experimental or developmental
products containing recovered materials. In the Agency's experience, such designations do
not result in government procurement of products containing recovered materials, because the
items are not reasonably available, or there is only one source; this leads to an unsatisfactory
level of competition. For this reason,- EPA does not intend to designate experimental or
developmental products until it, can be shown that they meet all of EPA's selection criteria,
as described above. (For additional discussion of designating experimental and
developmental products, see EPA's comments on General Accounting Office Report No. B-
251080, "Solid Waste: Federal Program to Buy Products with Recovered Materials Proceeds
Slowly.")
E. Methodology for Selecting Items for Designation
As described in section II.C.2, Executive Order 12873 directs ERA to promulgate a
Comprehensive Procurement Guideline and related Recovered Materials Advisory Notice.
This section explains the methodology ERA used to select items for designation and the
rationale used to develop the recommended recovered materials content levels for the items
designated in the CPG. The recommended recovered materials content levels can be found
in the related RMAN.
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