Small Quantity Generators Must Re-Notify EPA by September 1
September 1, 2025, is the second deadline for small quantity generators (SQGs) of hazardous wastes to re-notify EPA (or their state environmental agency) of their activities. EPA’s 2016 RCRA Generator Improvements Rule added a provision to the hazardous waste regulations to require re-notification from SQGs once every four years on September 1 (40 CFR 262.18(d)(1)).
Small quantity generators must re-notify EPA using Form 8700-12, also called a Site ID Form (or the state equivalent). Electronic reporting via the MyRCRAID system is an option in some states.
By requiring re-notification from small quantity generators every four years, EPA can “maintain more accurate data into the future for outreach, compliance assistance, and oversight activities.”
Among other information required on the form, regulated persons notify the EPA of their generator status–large, small, or very small.
Very Small Quantity Generators (VSQGs) are not required to obtain an EPA ID number and therefore have no re-notification requirement.
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Small quantity generators must re-notify EPA using Form 8700-12, also called a Site ID Form (or the state equivalent). Electronic reporting via the MyRCRAID system is an option in some states.
By requiring re-notification from small quantity generators every four years, EPA can “maintain more accurate data into the future for outreach, compliance assistance, and oversight activities.”
Why EPA Requires Notification from Generators
Generators must not treat, store, dispose of, transport, or offer for transportation, hazardous waste without having first received an EPA identification number. They must apply for the ID number for their site by submitting the Site ID Form.Among other information required on the form, regulated persons notify the EPA of their generator status–large, small, or very small.
What About Large and Very Small Quantity Generators?
Large quantity generators of hazardous waste, or LQGs, are required to re-notify EPA of their status by March 1 of each even-numbered year using Form 8700-12. LQGs may submit this re-notification as part of the Biennial Report required under 40 CFR 262.41.Very Small Quantity Generators (VSQGs) are not required to obtain an EPA ID number and therefore have no re-notification requirement.
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