Regulatory Fact Sheet
Quick reference for universal waste compliance under federal and Illinois regulations.
Regulatory Overview
Universal Waste Designation: Fluorescent and HID lamps are classified as universal waste under federal and Illinois regulations. Manifest and other paperwork requirements depend on your handler classification and can change, so verify current requirements before transport.
Landfill Disposal: Fluorescent and HID lamps are generally restricted from municipal landfills. Requirements vary by jurisdiction and can change, so verify current state and local rules before disposal.
Generator Liability: The generator (building owner or tenant) retains liability for ensuring lamps are sent to a compliant recycler. Working with a documented recycler like Chicago Lamp Recycling helps mitigate this risk.
Container & Storage Requirements
Containers used to store and transport spent lamps must meet the following requirements:
| Handler Type | Quantity Limit | Max Storage Time |
|---|---|---|
| Small Quantity Handler | Varies, verify current threshold | Varies, verify current limit |
| Large Quantity Handler | Varies, verify current threshold | Varies, verify current limit |
Quantity thresholds and storage time limits are set by federal and Illinois universal waste rules and can change. Verify current limits with Illinois EPA or your compliance advisor.
Shipping Requirements
Manifest requirements: Whether a hazardous waste manifest is required depends on your handler classification under federal and Illinois universal waste rules. Verify your current requirements before shipping.
Proper labeling required: Containers must be labeled with the waste type and accumulation start date before shipping.
Destination facility: Lamps must be sent to a permitted recycler, not a landfill, transfer station, or unpermitted facility. Retain your own shipping and disposal records as part of your compliance documentation.