WHAT IS UNIVERSAL WASTE?
The U.S. Environmental Protection Agency (EPA) defines five categories of common universal waste under federal regulations (40 CFR Part 273). These are hazardous wastes that are widely produced and can be managed under streamlined rules to promote safe recycling and disposal:
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COMMON UNIVERSAL WASTE ITEMS (FEDERAL)
BATTERIES
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Includes rechargeable and non-rechargeable types such as lithium-ion, nickel-cadmium, and others.
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Excludes spent lead-acid batteries managed under separate rules.
See Applicability Details
Pesticides
LAMPS
Universal waste lamps include any hazardous waste bulb or tube portion of an electrical lighting device, including: fluorescent, high intensity discharge (HID), mercury vapor, low and high pressure sodium (LPS and HPS), metal halide, and neon lamps (‘neon’ lamps also include those containing other noble gases such as argon, krypton, or xenon).
AEROSOL CANS
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Non-refillable containers that dispense substances using compressed gas
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Often hazardous due to flammable propellants or toxic content
See Applicability Details
MERCURY-CONTAINING EQUIPMENT
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Includes thermostats, barometers, and other devices with elemental mercury integral to their function
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Excludes items where mercury has been removed or that are not hazardous
See Applicability Details
PESTICIDES
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Applies to recalled, suspended, or canceled pesticides, or those collected in waste pesticide programs
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Mercury-Containing Equipment
See Applicability Details
STATE-SPECIFIC UNIVERSAL WASTE PROGRAM DETAILS
Illinois has made state-specific additions to the federal universal waste rules under Title 35 of the Illinois Administrative Code, Part 733. Here are the key updates and additions:
In addition to the federal categories (batteries, pesticides, mercury-containing equipment, lamps, and aerosol cans), Illinois has added:
1. Paint and Paint-Related Waste (PPRW)
- As of January 1, 2025, Public Act 103-887 allows post-consumer paint to be managed as universal waste.
- This includes oil-based paints, which are now eligible for streamlined handling under universal waste rules.
- The Illinois EPA proposed rules to include PPRW in 35 Ill. Adm. Code 733, and the Pollution Control Board accepted the proposal for public hearing and comment
2. Household and Very Small Quantity Generator Waste
- Illinois also includes certain household hazardous wastes and wastes from very small quantity generators (VSQGs) under its universal waste program
In Iowa, universal waste regulations follow the federal standards outlined in 40 CFR Part 273, with some state-specific guidance provided by the Iowa Waste Reduction Center (IWRC) and the Iowa Department of Natural Resources (DNR)
Special Notes on Aerosol Cans
- Can be recycled as scrap metal.
- Facilities may puncture cans if they follow specific safety practices.
- Punctured cans must undergo hazardous waste determination.
- Must be labeled as:
- “Universal Waste—Aerosol Can(s)”
- “Waste Aerosol Can(s)”
- “Used Aerosol Can(s)”
Minnesota has added three additional waste types to its universal waste program:
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Dental amalgam being recycled
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Disposable compressed gas cylinders
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Pretreated dental wastewater
These additions are permitted under the authority of the Minnesota Pollution Control Agency (MPCA) and are subject to reduced hazardous waste requirements if managed properly.
Minnesota has made several adjustments to the federal rules:
- Petition Process Not Adopted: Minnesota does not adopt the federal petition process for adding new universal wastes (40 CFR §§273.80–273.81)
- Conditionally Exempt Generators: Minnesota does not adopt 40 CFR §273.8 regarding conditionally exempt small quantity generators
GREEN TIP FLUORESCENT LAMPS
Some fluorescent lamps are designed to pass the hazardous waste test for mercury and are labeled as 'low mercury' or have green-colored metal end caps, known as 'green tips'. These lamps do still contain mercury, and in Minnesota must be recycled and are prohibited from solid waste.
Obtain a Hazardous Waste Identification Number (HWID): http://www.pca.state.mn.us/publications/w-hw1-02.pdf
Nebraska follows the federal universal waste rules under 40 CFR Part 273, but has made state-specific additions and clarifications in Title 128, Chapter 25 of the Nebraska Administrative Code.
The Nebraska standards for Universal Waste Management can be found, here
Resources:
Universal Waste Regulations Official Guidance Document
Nebraska Department of Water, Energy, and Environment (DWEE)
Wisconsin has adopted the federal universal waste rules under 40 CFR Part 273, but has also made state-specific additions and modifications under Wisconsin Administrative Code Chapter NR 673.
The Wisconsin DNR provides many resources to properly handle Wisconsin Universal Waste:
- Handling batteries
- Managing lamps
- Mercury-containing equipment
- Pesticides and aerosol cans
Full Rule Update
Key Management Requirements
- Extended Storage Periods: Wisconsin allows longer accumulation times than federal rules.
- Reduced Recordkeeping Burden: Simplified documentation for universal waste handlers.
- Training and Safety: Businesses and institutions must follow best practices for safe collection, storage, and transport.
- Transporter and Facility Requirements: Universal waste must be sent to licensed recycling or hazardous waste facilities
Kansas follows the federal universal waste rules under 40 CFR Part 273, but has made state-specific modifications through the Kansas Administrative Regulations (K.A.R.) § 28-31-273.
State-Specific Modifications
- Kansas adopts 40 CFR Part 273 as of July 1, 2006, with the following exclusions:
- All comments and notes from the federal rule.
- Subpart G (Petition process to add new universal wastes) is not adopted
- Substitution of terms is made per K.A.R. 28-31-100 through 28-31-100s to align with Kansas-specific terminology
Additional Resources:
Missouri has adopted the federal universal waste rules under 40 CFR Part 273, but with state-specific modifications and additions outlined in Title 10, Division 25, Chapter 16 of the Missouri Code of State Regulations.
State-Specific Additions and Modifications
- Effective Date: Missouri adopted the Universal Waste Rule on January 31, 1999.
- Regulatory Reference: Found in 10 CSR 25-16.273, which incorporates 40 CFR Part 273 by reference with Missouri-specific changes
- No disposal in landfills: Disposal of hazardous waste in Missouri sanitary landfills has been illegal since January 1, 1994, except for very small amounts
- Treatment Restrictions: Handlers must not treat or dilute universal waste (e.g., crushing mercury lamps) unless they have a Missouri Resource Recovery Certification or a hazardous waste permit
Missouri DNR Code of State Regulations
North Dakota has adopted the federal universal waste rules under 40 CFR Part 273, with state-specific implementation outlined in the North Dakota Administrative Code (NDAC) Chapter 33.1-24-05.
North Dakota has not added any additional waste types beyond those recognized federally.
The North Dakota Department of Environmental Quality (NDDEQ) oversees universal waste compliance through its Division of Waste Management. The Hazardous Waste Compliance Guide provides detailed instructions for generators and handlers
South Dakota has adopted the federal universal waste rules under 40 CFR Part 273, with state-specific implementation found in Administrative Rules of South Dakota (ARSD) Chapter 74:28:33.
The rules are enforced by the South Dakota Department of Agriculture and Natural Resources (DANR)
ADDITIONAL REGULATORY INFORMATION
MERCURY CONTAINING EQUIPMENT (MCE)
Mercury-containing equipment (MCE) is regulated as universal waste to streamline its collection and recycling. This includes devices like thermostats, barometers, and manometers that contain elemental mercury integral to their function.
- Applicability (§273.4)
: Regulations apply once the equipment is considered waste—either when discarded or when the handler decides to discard it - Exemptions
: Equipment not yet waste, not hazardous, or with mercury components removed is not covered under this rule.
- Small Quantity Handlers
must prevent releases and may remove ampules under strict containment and safety protocols. - Large Quantity Handlers
follow similar but more rigorous standards
Resource Conservation and Recovery Act (RCRA)
RCRA governs hazardous waste from generation to disposal
. Mercury-containing waste is classified as hazardous and must meet EPA treatment and recycling standards. However, household waste is often exempt unless stricter state laws apply
Disposal & Transport Guidelines
- Mercury must be stored in sealed containers with absorbent material and labeled clearly.
- Transport should be secure and ventilated if in a passenger vehicle.
- Disposal options include local hazardous waste collection programs or recycling centers
LED BULBS
Although the bulb portions of most light-emitting diodes (LEDs) lamps are not hazardous and thus not universal
waste lamps, the attached circuit boards are regulated electronic wastes in Minnesota. Some LED lamps closely
resemble fluorescent tubes, but may be labeled as ‘LED’ or have wiring or a string of LEDs visible in the tube
portion when brightly backlit.
PROPER CONTAINER (PACKAGING)
- Waste must be stored in closed, structurally sound containers that are compatible with the type of waste.
- Containers must be designed to prevent leaks, spills, and breakage.
For example:- Lamps should be stored in boxes or drums that prevent breakage.
- Batteries should be kept in containers that prevent short-circuiting and leakage
PROPER LABELING & MARKING
Each container must be clearly labeled with:
- “Universal Waste – Batteries”
- “Universal Waste – Mercury-Containing Equipment”
- “Universal Waste – Lamps”
- “Universal Waste – Aerosol Cans”
- “Universal Waste – Pesticides”
RECYCLING OPTIONS
THERE ARE MANY OPTIONS AVAILABLE. OUR RECOMMENDATIONS ARE BELOW:

LICENSED WASTE HANDLER
Retrofit Environmental is a licensed regulated waste transporter, and 10-day transfer facility with a network of downstream vendors that ensure proper and responsible recycling practices.

COMMUNITY COLLECTION EVENT
Many communities offer events once or twice a year to offer residents a proper outlet for Universal wastes, and other waste, like Electronic waste. The Retrofit Companies, Inc. holds multiple collection events across the Upper Midwest every year. Check our Facebook page or Event Calendar for upcoming events in your county.

PRE-PAID RECYCLING SERVICES
For small quantities, package services like RecyclePak, offer an easy solution. You can order right from our website.
Contact your service rep to learn more about whether our pre-paid solution is right for your organization.

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