The waste management industry is highly regulated, but it’s also subject to both state and federal laws. This can make pinning down how to legally and safely deal with your waste a complicated, confusing process. Working with an experienced and knowledgeable waste management company who can address some of these questions is one way to minimize that confusion. One such common source of uncertainty that these companies frequently get asked about is whether a business requires a generator’s EPA identification number.

01   /   Important Information: Why You May Need to Acquire a Generator’s EPA Identification Number

State versus Federal Regulations

As with many issues related to waste management, the answer about whether you need this number is not a straightforward yes or no. There are federal regulations that dictate whether this number is necessary or not, but it’s also largely dependent on your state.

The Type of Waste Matters

Whether you need an Environmental Protection Agency identification number depends on a number on factors, one of which is the type of waste you’re actually producing. Specifically, you only need this number if you’re dealing in hazardous waste.

The Amount of Waste Matters

If you’ve determined that you are looking to ship waste that is hazardous, the next criteria to determine if you need a generator’s EPA identification number in volume. How much of that waste are you looking toship?

In this way, you can use these three factors to determine whether you and your business need to obtain this number:


Your location (specifically what state)strict.


How much of that hazardous material needs to be shipped

Conditionally Exempt Small Quantity Generator

If you generate less than 220 pounds per month of hazardous materials, your facility is considered a conditionally exempt small quantity waste
generator, and you don’t need an EPA ID number.

However, having said that, there are states where you do need that number regardless of how much hazardous waste you generate. In some states, even one pound of hazardous material is enough to warrant having to obtain that number in order to legally ship the waste.

Small Hazardous Quantity Waste Generator

If you generate more than 220 pounds per month but less than 2,200 pounds per month of hazardous waste, you are considered a small quantity generator. At this point, you do need a number, and that holds true for every state.

Large Quantity Hazardous Waste Generator

If you generate over 2,200 pounds of hazardous waste every month, you are a large quantity generator, and you need an EPA ID number to legally ship that waste. As with small quantity generators, this number is needed regardless of your state.

02 / Points to Keep in Mind about Your Federal EPA Identification Number


You need to have your number before you ship anything hazardous. Shipping hazardous waste without the number (when it’s required due to your status, state, or volume) is against federal regulations.


You must report your waste generator status to the federal government.


If you’re a large quantity generator, you have to ship your waste out within ninety days, and you will be liable to pay tax on the tonnage.


In the application process, the number itself is site-specific to where you’re generating the waste. If you move, you’ll need to apply for and receive a new number.


As a built-in check and balance to the system, treatment facilities can’t legally accept waste from generators who should have those federal EPA numbers but don’t.

For more information about EPA identification numbers, your potential status as a generator, and what this all means for your business, please contact a representative of MCF Environmental Services, a full service hazardous waste management company.

Robert Losurdo

President, COO