An EPA ID number is a site-specific code assigned under the Resource Conservation and Recovery Act (RCRA) to any facility or transporter that handles hazardous waste. It attaches to a physical location rather than to a business, so a company running operations at three addresses needs three numbers. Generators, transporters, and treatment, storage, and disposal facilities all have to obtain one before handling waste, and there is no federal fee to apply.
Who Needs an EPA ID Number
Three categories of hazardous waste handlers must have a number before they touch a single drum: generators (the businesses and institutions producing the waste), transporters (anyone moving it off-site), and treatment, storage, and disposal facilities, known as TSDFs, at the end of the chain.
Large quantity handlers of universal waste also need one. Universal waste covers common items like certain batteries, pesticides, mercury-containing equipment, and fluorescent lamps. If your site accumulates 5,000 kilograms (about 11,000 pounds) or more of universal waste at any one time, you must notify the EPA Regional Administrator and receive an ID number before you cross that threshold.1eCFR. 40 CFR Part 273 Subpart C – Standards for Large Quantity Handlers of Universal Waste
Foreign transporters carrying RCRA-manifested hazardous waste inside the United States are covered too. Movement documents for imported shipments must list each transporter’s EPA ID number for any leg on U.S. soil.2eCFR. 40 CFR 262.84 – Imports of Hazardous Waste
Generator Thresholds That Determine Whether You Need One
For generators, how much hazardous waste your facility produces in a month decides both your category and whether federal rules require an ID number at all. There are three tiers.
Large Quantity Generators (LQGs) produce 1,000 kilograms (about 2,200 pounds) or more of hazardous waste per month, or more than 1 kilogram (about 2.2 pounds) of acutely hazardous waste per month. LQGs carry the fullest set of obligations, including biennial reporting.3US EPA. Categories of Hazardous Waste Generators
Small Quantity Generators (SQGs) produce more than 100 but less than 1,000 kilograms per month. SQGs need an EPA ID number and must meet most generator standards, though some requirements are scaled down.3US EPA. Categories of Hazardous Waste Generators
Very Small Quantity Generators (VSQGs) produce 100 kilograms or less per month. Under federal rules, VSQGs are exempt from the notification requirement and do not need a federal EPA ID number.4US EPA. Frequent Questions About Hazardous Waste Generation
That VSQG exemption is federal only. Many authorized states have adopted stricter rules that do require VSQGs to obtain an ID number, so check with your state environmental agency before assuming your facility is exempt.4US EPA. Frequent Questions About Hazardous Waste Generation
One-Time Waste Events
A facility that normally produces little hazardous waste may occasionally have a single event that pushes it over its usual threshold, such as a building cleanout, an equipment decommissioning, or an emergency spill response. Federal rules let VSQGs and SQGs handle these under episodic generation standards instead of reclassifying for the whole year.
The allowance is one episodic event per calendar year. For a planned event, notify EPA at least 30 days ahead using Form 8700-12. For an unplanned event, notify EPA by phone, email, or fax within 72 hours, with a formal Form 8700-12 to follow. You need an EPA ID number in hand or must obtain one as part of the notification.5eCFR. 40 CFR Part 262 Subpart L – Alternative Standards for Episodic Generation
All waste from the event must be manifested and shipped off-site within 60 days of the event’s start date, and records must be kept for at least three years afterward.5eCFR. 40 CFR Part 262 Subpart L – Alternative Standards for Episodic Generation
How to Apply
The application is EPA Form 8700-12, formally the “RCRA Subtitle C Site Identification Form.” It asks for your legal business name and physical site address, a site contact, the types of hazardous waste you handle, your generator category, and ownership details.6U.S. Environmental Protection Agency. Instructions and Form for Hazardous Waste Generators, Transporters and Treatment, Storage and Disposal Facilities to Obtain an EPA Identification Number
Many states accept electronic filing through myRCRAid, a module inside the RCRAInfo Industry Application. Not every state has opted in, so confirm with your state environmental agency whether online submission is available. Where it is, electronic filing generally moves faster and cuts down on the paperwork errors that hold up applications.6U.S. Environmental Protection Agency. Instructions and Form for Hazardous Waste Generators, Transporters and Treatment, Storage and Disposal Facilities to Obtain an EPA Identification Number
There is no federal fee. Some states charge application or annual maintenance fees, and they vary widely, from nothing to a few hundred dollars depending on the jurisdiction.
Keeping the Number in Good Standing
Once the number is issued, you’re on the hook for accurate records of everything the site generates, ships, and hands off: quantities, dates, transporters, and destinations.
Recordkeeping
Generators must keep a signed copy of each hazardous waste manifest for at least three years from the date the waste was accepted by the initial transporter. Biennial reports and exception reports must be kept at least three years from the report’s due date.7eCFR. 40 CFR Part 262 Subpart D – Recordkeeping and Reporting Applicable to Small and Large Quantity Generators Some states require longer.
Biennial Reporting for LQGs
Large Quantity Generators file the Biennial Hazardous Waste Report (EPA Form 8700-13A/B) by March 1 of every even-numbered year, covering the previous calendar year. The report due March 1, 2026, covers 2025. SQGs and VSQGs have no federal biennial reporting duty, though state rules may differ.8US EPA. Biennial Hazardous Waste Report
Updates, Ownership Changes, and Deactivation
Because the number belongs to the site, a change of ownership does not create a new one. The new owner inherits the existing ID and updates the registration. Update your information any time the site contact, ownership, or waste activities change.
Moving to a new address is different. The old number stays with the old site, and you apply for a new one at the new location. To deactivate a number when hazardous waste activity ends, submit an updated Form 8700-12 marking the site inactive, or follow your state’s deactivation procedure.
Penalties for Operating Without One
Handling hazardous waste without the required EPA ID number violates RCRA Subtitle C, and the enforcement numbers are serious.
Civil penalties can reach $37,500 for each violation, with each day of continued violation counted as a separate offense.9U.S. Environmental Protection Agency. Resource Conservation and Recovery Act (RCRA) and Federal Facilities Those statutory figures are periodically adjusted upward for inflation, so actual per-day amounts at the time of enforcement are typically higher.
Criminal penalties apply where violations are knowing. Knowingly violating a material Subtitle C requirement carries fines up to $50,000 per day and up to two years’ imprisonment. A second conviction doubles both. For knowing endangerment (knowingly placing another person in imminent danger of death or serious bodily injury), the fine can reach $250,000 and imprisonment can reach 15 years.9U.S. Environmental Protection Agency. Resource Conservation and Recovery Act (RCRA) and Federal Facilities
Set against those figures, the cost of obtaining and maintaining an EPA ID number is minor.