In this guide 5 min read
This guide is for businesses that end up with used batteries, fluorescent lamps, aerosol cans or mercury thermostats as part of their work: shops, plants, warehouses, offices, schools and property managers. The federal rules below apply to businesses. Household waste is excluded from the hazardous waste rules (40 CFR 261.4(b)(1)), so if you are cleaning out a home, check with your city or county for a drop-off site.
This article explains federal rules in general terms. It is not legal advice. State and local rules can be stricter, so check with your state environmental agency before you make changes at your site.
Key takeaways
- Universal waste has five federal types: batteries, lamps, mercury-containing equipment, aerosol cans and some pesticides. States can add more, and a state can leave some out.
- The rules in 40 CFR Part 273 are simpler than the hazardous waste rules, but universal waste still cannot go in the trash.
- Below 5,000 kilograms on site at any time, you do not need to notify EPA.
- Label it, keep it in sound containers and ship it within one year.
- Universal waste managed under Part 273 does not count toward your hazardous waste generator category.
The short answer on universal waste
Universal waste is a short list of common hazardous wastes that EPA lets businesses handle under simpler rules, so that more of it gets recycled. The rules are in 40 CFR Part 273. They ask less of a business than the full hazardous waste rules do, but universal waste still cannot go in the trash. It has to be stored, labeled and sent to a handler or a recycler that accepts it.
The five federal types of universal waste
EPA's universal waste rules cover five types (40 CFR 273.1). An item counts only if it is a hazardous waste (40 CFR 273.2 to 273.6):
- Batteries that are hazardous waste. EPA says many lithium-ion batteries, like the rechargeable ones in tools, phones and equipment, are likely to be hazardous waste when they are discarded. Spent lead-acid batteries can also be managed under separate rules in 40 CFR Part 266, Subpart G.
- Lamps, such as fluorescent tubes, compact fluorescent bulbs and high intensity discharge lamps.
- Mercury-containing equipment, such as thermostats, switches and gauges that hold mercury.
- Aerosol cans. EPA added them to the program in a 2019 rule (84 FR 67202). States do not have to adopt that rule, so check that yours has.
- Pesticides that have been recalled, or collected through a waste pesticide collection program.
States can add more types, and a state does not have to include all five federal types. EPA's examples include antifreeze in Louisiana and New Hampshire, ballasts in Maine, Maryland and Vermont (these states cover ballasts that contain PCBs), and solar panels in California and Hawaii. Your state environmental agency has the list that applies to you.
Small and large quantity handlers of universal waste
EPA calls a business that keeps universal waste a "handler." Which kind of handler you are depends on how much you keep on site at one time, with all five types counted together (40 CFR 273.9).
- Small quantity handler: less than 5,000 kilograms (about 11,000 pounds) at any time. You do not need to notify EPA (40 CFR 273.12).
- Large quantity handler: 5,000 kilograms or more at any time. You must notify EPA and have an EPA identification number before you reach that amount (40 CFR 273.32). If you have already notified EPA of hazardous waste activities and have an EPA identification number, you do not need to notify again. The status lasts through the end of that calendar year.
Universal waste that you manage under Part 273 does not count toward your hazardous waste generator category (40 CFR 262.13(c)(6)). A shop can recycle its lamps and batteries as universal waste without that waste moving it into a higher generator status. Your state's universal waste program may set its own handler limits and notice rules.
Universal waste on site at any one time
How to store and label universal waste
For a small quantity handler, the duties are short (40 CFR 273.13 to 273.17):
- Use sound containers. Manage universal waste so it does not leak or break. Lamps need closed packaging that keeps them from breaking, and aerosol cans need a container kept away from heat. A battery or a piece of mercury-containing equipmentA device or part of a device that holds elemental mercury it needs to work, such as a thermostat (40 CFR 273.9). EPA also names mercury switches and gauges as examples. that leaks or is damaged goes in a closed, sound container.
- Label it. Each item, or the container that holds it, needs a phrase the rule allows. For lamps, that is "Waste Lamp(s)", "Used Lamp(s)" or the words Universal Waste with Lamp(s). Batteries, aerosol cans and mercury-containing equipment follow the same pattern. Pesticides are different: the phrase is "Universal Waste-Pesticide(s)" or "Waste-Pesticide(s)", and the product's label, or another label the rule allows, stays on too (40 CFR 273.14).
- Ship it within one year. You can keep universal waste for up to one year from the date it became waste or the date you received it from another handler. You also need a way to show that date, such as a date on each container or an inventory (40 CFR 273.15).
- Tell your employees. Everyone who handles universal waste, or is responsible for managing it, needs to know how to handle it and what to do in an emergency (40 CFR 273.16).
- Contain releases right away. A broken lamp or a leaking battery has to be contained immediately (40 CFR 273.17).
A large quantity handler has a few more duties, including the notification above and a record of each shipment it sends or receives (40 CFR 273.39). Label wording, storage time and training can also be set by your state, so confirm those details with the agency that runs its universal waste program.
Where universal waste can go
A handler can send universal waste only to another universal waste handler, to a destination facilityA facility that treats, disposes of or recycles a type of universal waste (40 CFR 273.9). that treats, disposes of or recycles it, or to a foreign destination (40 CFR 273.18 and 273.38). The dumpster is not one of those places. In practice, a business hands its universal waste to a collector, who takes it to a recycling facility. If you are unsure where a shipment of universal waste may go in your state, ask the state environmental agency.
What does not count as universal waste
- Used oil has its own rules in 40 CFR Part 279. Our guide on used oil and hazardous waste explains them.
- Solvents and other shop chemicals are not one of the five federal types. If they are hazardous, they follow the full hazardous waste rules, and our hazardous and special waste division handles them.
- Electronics are not one of the five federal types either. Some states add them to their own list.
Is it universal waste?
Pick an item, then choose where it goes.
Universal waste
- Fluorescent tubesLamps that are hazardous waste, such as fluorescent tubes, can be managed as universal waste.
- Used batteriesBatteries that are hazardous waste are one of the five federal types.
- Mercury thermostatsThey count as mercury-containing equipment.
- Aerosol cansEPA added them in 2019. Check that your state has adopted the change.
- Recalled pesticidesRecalled pesticides, and those collected in a waste pesticide program, are covered.
Not universal waste
- Used motor oilUsed oil has its own rules in 40 CFR Part 279.
- Spent solventsHazardous solvents follow the full hazardous waste rules.
- Old computersElectronics are not a federal type. Some states add them.
All sorted.
How UES collects universal waste
Our Hazardous & Special Waste Division collects universal waste and electronic waste from businesses. We collect batteries, lamps, ballasts and electronics, and you can ask us about other items.
- Tell us what you haveA rough count is enough.
- We tell you how it shipsA scheduled pickup or containers sent to you. Prepaid return boxes for fluorescent lamps.
- We collect and recycle itIt goes to a recycling facility.
- You keep the recordsShipping records, your Customer Portal history and a Certificate of Recycling on request.
We collect universal waste from businesses only. Request service on our universal waste page, see our fluorescent bulb collection service, or call 800.988.7977. We reply the same business day.
Questions businesses ask
Are fluorescent bulbs universal waste?
Yes. Fluorescent tubes and other lamps that are hazardous waste can be managed as universal waste under 40 CFR Part 273. Your state program may handle lamps a little differently.
How long can a business keep universal waste?
Up to one year from the date it became waste or was received from another handler, and you need a way to show that date (40 CFR 273.15). Look up the time limit in your state too, because it can differ.
Does universal waste count toward my hazardous waste generator status?
No, as long as you manage it under the universal waste rules in 40 CFR Part 273. EPA says it then does not need to be counted when you work out your generator category (40 CFR 262.13(c)(6)). Check with your state hazardous waste agency before you leave universal waste out of your monthly count.
Does UES take universal waste from homes?
No. We collect universal waste from businesses only. Households can check with their city or county for a drop-off site.
Written by Universal Environmental Services. Based on federal rules as of October 2026. This is general information, not legal advice.
Sources
- 40 CFR Part 273, Standards for Universal Waste Management, ecfr.gov
- EPA, Universal Waste, epa.gov, updated Sep 18, 2026
- Federal Register, Increasing Recycling: Adding Aerosol Cans to the Universal Waste Regulations, 84 FR 67202, December 9, 2019
- 40 CFR 262.13, Generator category determination, ecfr.gov
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