Universal Waste Guide

Author: Marketing
Date: February 3, 2024


Waste disposal is a complex process of how-to’s and regulations. This is especially true when it comes to universal waste. The term “universal” alone is such a broad term that does not make the job easier; is why we are here.

So, we’ve compiled all the info you need on universal waste. If you’re managing a waste facility or you’re looking into an entry-level waste management job, this article can serve as a valuable resource and knowledge base for you.

What is Universal Waste?

Waste that is designated as hazardous but contains very common materials are known as universal waste. The United States Environmental Protection Agency defines universal waste in more detail here:

Title 40, Code of Federal Regulations (40 CFR) (Title 40 - eCFR)

Business establishments and waste generators are required to dispose of universal wastes in compliance with mandated laws and regulations.

Types of Universal Waste

When it comes to universal waste, the federal regulations specify them into four categories of materials that can be included for universal waste management. These materials or products are Batteries, Pesticides, Lamps, and any equipment that contains the hazardous element, Mercury. For this section, we will define each item through the part 273 regulations.


According to the Title 40 of the Code of Federal Regulations, a battery is a piece of equipment that contains one or more connected electrochemical cells, which consists of anode, electrolyte, and cathode with both electrical and mechanical collections. These are designed to store, receive, and release electricity. It also includes batteries that are fully intact or unbroken.

On top of that, in terms of universal waste, batteries include both rechargeable and non-rechargeable. Both of which contain mercury, cadmium, or lead. Because of that, the Resource Conservation and Recovery Act or the RCRA deems them as hazardous wastes. Therefore, they must not be disposed of in ordinary trash bins.

Below are a few examples of the batteries that are included in the Universal Waste Rule requirements:

  • Sealed Lead-Acid batteries
    A good example for a lead-acid battery is your car battery. However, lead-acid batteries only fall under the universal waste rule if it is not managed or if it is not eligible for management any longer. This is according to 40 CFR 266, Subpart G.

    That said, also according to 40 CFR 266, Subpart G, lead-acid batteries that are either transported, generated, reclaimed or reclaimed where stored, or regenerated does not fall under universal waste management. In simpler terms, these batteries are not yet discarded. Therefore, they are not classified as wastes.

  • Alkaline and Dry Cell Zinc-Carbon batteries
    These are among the most common batteries used, which makes them common waste batteries. However, they do not produce hazardous amounts of elements. So, they do not fall under universal wastes. However, most would recommend that they should be disposed of along with batteries under universal wastes.

    This is so that they won’t go to undesired waste disposal facilities, treatments, or locations. Such facilities or treatments are incineration or in solid waste landfills.


According to the 40 CFR part 273.9, it defines pesticide as any mixture of substances that is meant to mitigate, destroy, repel, or prevent any pest, or be used as a plant regulator, desiccant, or defoliant. However, there are a few exceptions that you need to consider, which are the following:

  • If it is not a new drug for animals and it has been regulated by the Secretary of Health and Human Services.
  • If it is a new animal drug under the Federal Food, Drug, and Cosmetic Act or the FFDCA section 201 (w).
  • If it is a food product for animals that is under the FFDCA section 201 (x) that contains any of those mentioned above.

The regulations for universal wastes can actually help with the proper management of pesticides. This is especially true for pesticides that have been recalled if they are stocks of any suspended or cancelled form or brand of pesticide. The recalling of these materials are either voluntary or mandatory from the FIFRA section 19 (b). More on that below.

Also, under the universal waste act, pesticides can also be managed properly while still in inventory. On top of that, it can also be used for managing other cancelled or suspended pesticide products. 

When it comes to pesticides, oftentimes, it is classified as hazardous waste. However, in some cases, it can be listed under universal wastes. That would only be applicable if the type of pesticide are the following:

  • These pesticides are unused, suspended, or cancelled. These pesticides are recalled according to section 19(b) of the Federal Insecticide, Fungicide, and Rodenticide Act or FIFRA. They can also be recalled if they are not registered or compliant with the FIFRA.
  • Any unused pesticides that were collected and/or managed by a pesticide waste collecting program or any program of the sort.

To further understand this section, we will also provide all guidelines regarding pesticides for universal waste requirements. These are:

  • The universal wastes requirement is not applicable to any pesticide that is not a waste product or a hazardous waste product.
  • When a pesticide is recalled, it automatically becomes a waste product when these conditions are met:
  • The person that created the waste product decides to voluntarily agree to the recalling of said products.
  • The person who is conducting the recalling of products decides to dispose of said recalled products.
  • As mentioned above, the universal waste requirement is only applied to pesticides that are either recalled, suspended, or cancelled, as part of a waste pesticide collection program.

    Any hazardous waste pesticides that do not fit into any of the above mentioned, must, therefore, be managed by the requirements located in 40 CFR 262.70. This discusses the pesticides disposed of in a farm land along with the instructions located on the label of the hazardous pesticide.

Mercury-Containing Equipment

When it comes to equipment that contains mercury, which is a highly toxic and hazardous element, the 40 CFR part 273.9 defines it as a device or a part of a device that contains mercury that is its primary energy source. This includes apparatuses such as thermometers, barometers, manometers, gauges, regulators, mercury switches, etc. However, products, such as batteries, cathode ray tubes, and lamps are excluded from this. Otherwise, they would be regulated as hazardous waste as it shows toxicity characteristic with mercury.

The mercury-containing equipment only became a part of the Federal Rule in 40 CFR 273 on August 5, 2005. 

On top of that, there are also a lot of equipment that contains mercury but is not considered as a universal waste product. Such items are:

  • Any mercury-containing equipment that is not discarded because they are still being used.
  • Any equipment that contained mercury but had the toxic element removed from it.
  • Aby mercury-containing equipment that is not considered as hazardous waste.


According to the definition of 40 CFR part 273.9 a lamp is a bulb or tube portion of a lighting device powered by electricity, and it was added to the Federal Rule on July 6, 1999. Lamps include, but are not limited to, high density discharge, neon, fluorescent, mercury vapor, metal halide lamps, and high pressure sodium.

This category for universal wastes is much broader when compared to Batteries, Pesticides, and Mercury-Containing Equipment. This is because, unlike equipment that contains mercury, it also includes lamps that do not contain any mercury substance or element. With that said, fluorescent light bulbs are still the most common waste product in the Lamps category.

Hazardous waste lamps can only be considered as universal waste when they fall under the 40 CFR 261. On top of that, they may also be considered when they have been discarded or have been permanently removed from its socket.

Another thing that is worth mentioning about lamps is the crushing of these hazardous waste. This is a definite no from the Universal Waste Rule, 40 CFR 273.11 (b) and 273.31 (b), which states that there will be no crushing of these hazardous waste bulbs as a form or during treatment. The only time that it is allowable to crush these bulbs is when it is properly managed and regulated as a hazardous waste product.

When that is made official, these bulbs can be treated or crushed in containers or tanks by the person who generated it. This is part of the 40 CFR 262.34, which is the generator treatment allowance. It is also in conformance with all hazardous waste management standards where it is applicable.

However, it is important to take note of the fact that some states in the US add additional universal waste regulations that are exclusive to each state. That is why it is vital that you contact your local government and check if any of these regulations or if there are any added regulations regarding universal waste. This will help save you from a lot of trouble in the future.

Regulatory Standards for Universal Waste

The Universal Waste Rule has separate requirements for each regulated entity. These are the following:

  1. Universal Waste Handlers
  2. Universal Waste Transporters
  3. Destination Facilities

Universal Waste Handlers

These are the people responsible for generating universal wastes. They could also be the owner of a certain establishment that accepts universal wastes from another universal waste handler, accumulates universal waste, and distributes universal wastes to other universal waste handlers. It may even be a foreign country.

The proper management requirements for all universal waste handlers are the following:

  • Using proper containers. It should be a non-leaking container or any of the sort.
  • Segregating universal waste in the correct areas.
  • Should not be disposing of universal wastes or treat them aside from those stated in the regulations.
  • Obtain an EPA identification number. One may also contact the DTSC.
  • Determining if the materials gathered were because of handling or recycling hazardous wastes.
  • Do not keep universal wastes longer than one year.
  • Using proper labels during disposal
  • When storing universal wastes, comply with all zone requirements where applicable.
  • One should always have spill kits ready in any case a universal waste product spills or leaks, such as mercury-containing equipment.
  • Provide proper training to personnel who handle universal wastes.
  • Track all shipments of all shipped universal wastes.
  • Responding to any release of universal chemical waste and determining if it is hazardous.

Universal Waste Transporter

According to the Universal Waste Rule, a universal waste transporter is the one who handles off-site transportation of universal wastes. These include a universal waste handler who is transporting universal waste in their vehicle. Plus, it also would include shipping services, such as FedEx, UPS, etc.

Destination Facilities

Basically, a destination facility is a type of establishment that is fully regulated to treat and dispose of universal waste. Good examples of destination facilities include hazardous waste landfills and hazardous waste recycling facilities. On top of that, a destination facility is required to manage universal waste in accordance with the requirements and conditions of the hazardous waste facility permit.

Universal Waste Management Disposal

When it comes to universal waste management disposal, one cannot simply send their universal wastes to their local solid waste landfill or non-hazardous waste recycling center. They must follow one of the following options:

  1. One may transport it to another universal waste handler. These are typically businesses that cater to the collecting, storing, receiving, and shipping universal wastes.
  2. One may contact a universal waste transporter, such as a curbside collection program, pick-up service, or a packaged shipment.
  3. One may drop-off their universal wastes in a proper destination facility.

Federal Universal Waste Program

The Federal Universal Waste Program was established to promote the proper disposal and recycling of these universal waste products. These wastes are essentially under the Federal criteria of hazardous waste, but are quite common. Plus, most do not pose immediate dangers.

The majority of the states in the US have adopted the Federal Universal Waste Program. However, only some incorporated all of the regulations. That is because a state is not required to follow all Federal waste regulations. That said, if in any case a universal waste regulation is not followed, and a universal waste product is deemed as hazardous waste, it must be managed as a hazardous waste.


Universal wastes is quite a broad term, especially when it comes to managing and disposing of them. However, if you are equipped with the right knowledge, you will be able to comply with the rules, requirements, and regulations.


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