This is because unwanted pharmaceuticals that are sent to reverse
distributors may have financial value—a value that is only determined by the sorting
process at the reverse distributor. Pharmaceuticals sent to reverse distributors (and
from reverse distributors to manufacturers) are treated as “products in commerce”
because of this financial value, and thus are not subject to hazardous waste
transportation and permitting requirements. For those pharmaceuticals that do not have
financial value, reverse distributors become the waste generator.