Circular ITAD in 2026: Practical Steps for Enterprises

Katelyn Harrison
Marketing Specialist
HOBI-environmental steps for 2026

What Changes for 2026

2026 will be the year of new rules for the waste industry. Several new industry regulations will take effect in the new year, including the EU Waste Shipment Regulation, effective May 21, 2026, which will enforce tighter export limits and require record-keeping. Additionally, the industry has seen major adjustments to repair laws, including the EU Right to Repair, which Member States must apply from July 31, 2026. The global rise in digital media has raised the bar for data security measures, prompting companies to revise outdated security infrastructure. NIST released SP 800-88 Revision 2 in 2025, updating media sanitization policies and vendor controls to the R2 standard.  

Circularity was a major player in 2025, and sustainability needs will continue to grow in 2026 as e-waste volumes continue to rise. In 2022, 62 million tonnes of e-waste were generated, but recycling rates remain low, making circularity a continued priority in the New Year. 

Set 2026 Circular ITAD Targets and KPIs

As 2026 approaches, make sustainability your goal during IT asset disposition. E-waste reduction doesn’t happen overnight; it’s a gradual process increased by strategic circular ITAD planning. 

  • Prioritize circularity by adopting a reuse-first hierarchy with numeric goals, such as a 20 percent reuse rate for decommissioned assets. 
  • Create and track four Key Performance Indicators (KPIs) to help manage (1)reuse rate, (2)resale recovery per unit, (3)verified erasure pass rate, and (4)days prom pickup to settlement. 
  • Add two outcome metrics: emissions avoided through reuse and landfill diversion rate, and keep a quarterly rollup for ESG packs. 
  • Publish targets in Q1 and align procurement, finance, and security. 
  • For EU flows, include shipment documentation targets to match 2024/1157 enforcement. 

Build Circularity Into Lifecycle Planning 

Circularity should be part of every company’s ITAD plan as a part of the disposition process. Reuse plays a significant role in e-waste reduction, and buying with end-of-life in mind will help avoid disposition hurdles and maximize ROI from beginning to end. OEMs are becoming more repair-friendly as more users demand repairable devices. Preferring repairable devices with parts access that support Right to Repair norms will increase enterprise ROI and support circularity by extending the lifecycle of retired equipment. 

Add return and buyback terms to OEM and reseller contracts to help align incentives, boost sales, manage inventory risks, and create a new revenue stream via remarketing. This also supports a circular economy and increases environmental credit. Tagging assets on day one via owner, site, warranty, refresh date, and resale channel creates accurate documentation for a secure chain-of-custody and reduces gaps or discrepancies. Quarterly refresh waves ensure IT equipment remains in pristine condition, and maintaining a steady volume will help protect resale prices and prevent value deterioration. Additionally, plan for the end of Windows 10 support and incorporate Year One enterprise ESU prices into the cost and timing. 

Secure Disposition Without Slowdowns 

Data security is paramount, even after asset retirement, and poor planning can result in slowdowns and compliance failure.

  • Require NIST SP 800-88 r2 compliant erasure or physical destruction by risk tier. Update SOPs, tools, and training consistently to keep up with industry standards. 
  • Use a serialized chain of custody from the site to final disposition to help track assets from beginning to end. This provides evidence of compliance and a clear audit trail. 
  • Capture evidence artifacts, erasure reports, certificates, drive serial numbers, device grades, and downstream endpoints to minimize backups and ensure compliance. 
  • Align with legal and privacy on retention rules and audit access.
  • For EU shipments, confirm receiving facilities and documentation meet 2024/1157 rules. 

Make Reuse First, Programs That Work

Prioritize reuse as a value-added method of increasing enterprise ROI. 

  • Incorporate internal redeployment portals and match supply to open requisitions each month. 
  • Employee purchase plan with precise grading and a warranty, with price bands set by grade, to extend device lifecycles. 
  • Donation programs are an excellent way to keep assets in circulation. Include device list, data verification, receiver vetting, and tax documentation. 
  • Spare pool for break-fix cannibalization to cut new buys.
  • Identify no-go items, firmware-locked devices, and units with missing parts that block safe use. 

As sectors come under the ESPR acts from the 2025-2030 plan, prepare for Digital Product Passport data handoffs for EU operations. 

HOBI-step by step plan of action
step by step plan of action

Monetize the Remainder and Report It

Successful monetization is about knowing the market and identifying the correct sales channels to maximize enterprise ROI. 

  • Select remarketing channels by category, wholesale, auction, or direct end-to-end users via a reputable partner. 
  • Negotiate revenue sharing based on real grade mix and days-to-sell.
  • Use market checks and sample bids each quarter to pinpoint potential sales. 
  • Reconcile settlements monthly, unit count, grade, price, fees, and net recovery. 
  • Build an audit-ready report that includes reuse, resale, recycling, emissions avoided, and certificates to ensure compliance and build environmental credits. 
  • Map EU exports and downstream endpoints to meet 2024/1157. 

Meet Standards and Reporting Needs 

Use certified partners to meet industry standards such as R2v3, ISO 14001, and ISO 45001, and monitor changes, including the R2 five-year review launched in 2025. Batteries are a significant ITAD pain point, and proper packaging and labeling, in addition to trained handling, are paramount to IT asset disposition safety and are required under the EU Battery Regulation

Reporting is growing as an industry standard, and mapping results to ESG disclosures provides quantifiable measurements of success to track and maintain. In the United States, the SEC climate rule adopted in March 2024 remains in litigation and has been stayed. Formats are constantly shifting, so keep a consistent narrative that avoids over-committing to formats that could change. Ensure all export and data residency rules are current, and document downstream countries and final processors. 

Choose the Right ITAD Partner, Checklist 

Choosing the right ITAD partner is critical for regulatory compliance, secure data erasure, environmental protection, data center solutions, and scalable logistics services that reduce slowdown. When choosing an ITAD provider, consult the ITAD checklist. 

  • Current R2v3 certificate with recent surveillance audit. 
  • Full downstream due diligence to the final processor, with a country list on file. 
  • Serialized tracking portal from pickup to resale or recycling. 
  • Multi-site logistics at scale, data center de-install capability, battery handling per EU rules if applicable. 
  • Secure erasure at volume, NIST 800-88 r2 methods, sample validation, and failure thresholds. 
  • Transparent pricing, service levels, and named escalation paths. 
  • Reference accounts in your industry with similar volume. 

90 Day Action Plan for 2026 

Don’t start 2026 unprepared. Utilize this 90-day action plan to take control of your ITAD strategy. Save budget, improve emissions reduction, mitigate data breaches, and improve logistics turnaround with practical steps for circular ITAD

Days 1-30: Set targets, develop KPIs, baseline last year’s results, shortlist partners, align legal and security on NIST 800-88 r2

Days 31-60: Pilot two sites, one office, and one data center. Test the pickup-to-settlement flow and compare resale channels for maximum ROI. 

Days 61-90: Finalize partner. Publish standards, device grades, no-go lists, and battery rules that reflect EU 2023/1542 where you ship or sell into the EU.

Launching a dashboard will help monitor units received, reuse share, resale prices, erasure pass rates, and exceptions. Incorporate buy-with-end-of-life terms into contracts to maximize value return, and, if you operate in the EU, add WSR documentation checks before exports. 

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