Biennial Reports Due 3/1: What Must You Submit?

It is an even-numbered year, which means that hazardous waste generators must submit Biennial Reports to the US EPA by March 1 as required under the Resource Conservation and Recovery Act (RCRA) and 40 CFR Part 262.41.

The instructions for meeting reporting requirements under Subtitle C of RCRA are more than 100 pages long, so you’re forgiven if you haven’t read them all. This article covers the major elements of a generator’s RCRA Biennial Report, what every report must include, and where to find more information.

In this article:

• Who Must Submit the RCRA Biennial Report?
• Why Does RCRA Require Biennial Reports?
• What’s In the RCRA Biennial Report?
  • Site ID Form
  • The Generation and Management (GM) Form
  • The Waste Received from Off-site (WR) Form
  • The Off-site Identification (OI) Form

Who Must Submit the RCRA Biennial Report?

The US EPA requires all hazardous waste generators designated as Large Quantity Generators for any single month during the most recent odd-numbered year (2025) to submit a Biennial Report.

That’s right—if you exceeded the 1,000 kg generation threshold (or the 1 kg threshold for acutely hazardous waste) during even one month in 2025, and that month did not qualify as an episodic event, you must submit a Biennial Report that covers all your last year’s hazardous waste activity by March 1.

As is always the case with hazardous waste regulations, your State’s reporting standards may vary, but must be at least as stringent as the Federal rules. Some states require large quantity generators to report annually; others require all generator categories to submit reports. So, be sure to check your State’s rules before you start reporting.

Lion Members can check State hazardous waste requirements in the Lion.com Member Area under the Resources Tab. Choose your state from the State Tools menu and check out Lion’s summary of unique hazardous waste requirements.

Why Does RCRA Require Biennial Reports

Under RCRA, hazardous waste must be managed properly from “cradle-to-grave.” Biennial Reports of hazardous waste activity illustrate trends in hazardous waste generation, management, and transport.

In addition, EPA can use Biennial Reports to help ensure hazardous waste generated in the US is accounted for and properly disposed of.

What’s In the RCRA Biennial Report?

Under the EPA's Generator Improvements Rule, the RCRA Biennial Report comprises three or four major elements, depending on which state you work in.

Site ID Form

The EPA’s Generator Improvements Rule, in effect now in nearly all the US States, added a requirement for large quantity generators to “re-notify” the EPA of their activity every two years (40 CFR 262.18(d)(2)).

The Site ID Form is used initially to procure an EPA ID, which is required for most hazardous waste generators. The re-notification requirement means that—even if you’ve already submitted a Site ID form and already have an EPA ID number—you must submit a Site ID form with your Biennial Report. Keep in mind that this includes Addendums to the Site ID Form regarding hazardous secondary materials (40 CFR 262.42).

Note: Small quantity generators are required to “re-notify” the EPA of their hazardous waste activities every four years (40 CFR 262.18(d)(1)).

The Generation and Management (GM) Form

For each hazardous waste or “waste stream” your facility generates, you must provide the EPA with details about the quantity and type of waste, how you managed the waste, and the final disposition of the waste (e.g., off-site shipment).

The Waste Received from Off-site (WR) Form

The EPA authorizes large quantity generators to receive waste from sites under the control of the same “operator” (i.e., the same company) when specific conditions are met. Collecting waste at a central location makes for more efficient management, disposal, and recordkeeping.

Sites that receive waste from so-called “sister sites” must report to the EPA about the type and quantity of waste they received, where the waste came from, and how the waste was managed on-site. While our biennial reporting tips are geared toward generators, other facilities that receive waste from off-site, like TSDFs, must report as well.

The Off-site Identification (OI) Form

Only required in certain states, the Off-site ID Form provides the EPA with details—names, addresses, etc.—of generators, transporters, TSDFs, and other receiving facilities where hazardous waste was generated or shipped for recovery, treatment, or disposal.

Why Compliant Reporting Matters

Submitting a complete and accurate Biennial Report to US EPA before the March 1 deadline, every two years, is an essential element of hazardous waste compliance for large quantity generators. For EPA, the data regulated facilities submit is used to inform important agency decisions about where to devote limited resources for environmental remediation, compliance assistance, and regulatory enforcement.

Before visiting a facility to assess or inspect hazardous waste operations, EPA compliance officers commonly review the generator's current Site ID Form and/or other information submitted with the biennial report. If EPA finds that the reporting misrepresented the site's activities in any way, e.g., if the site generates far more waste than was reported, that will be cause for concern, lead to additional scrutiny toward the rest of your operations and could result in fines for noncompliance with the RCRA regulations.