Variations in Hazardous Waste Generator Reporting by State

This matrix tracks state-level variations in hazardous waste generator reporting, with a focus on routine periodic reporting and the requirements for submitting hazardous waste manifests to regulatory authorities.

The matrix applies to Very Small Quantity Generators (VSQG), Small Quantity Generators (SQG), and Large Quantity Generators (LQG) and addresses differences in how states implement reporting and manifest-submission requirements for off-site hazardous waste shipments.

In June 2018, the U.S. Environmental Protection Agency launched the federal e-Manifest system, allowing generators to create and submit hazardous waste manifests electronically. As of January 22, 2025, LQG and SQG generators are required to register for e-Manifest, while VSQG generators are not required to register. Routine submission of manifests to state agencies is still required in certain states, and those variations are reflected in this matrix.

This matrix does not include spill reporting requirements or manifest exception reporting, which are addressed separately.

The EPA’s 2016 Hazardous Waste Generator Improvements Rule replaced the term CESQG with VSQG in federal regulations and introduced a requirement for SQGs to renotify the EPA of their hazardous waste activities every 4 years. Re-notification requirements apply in authorized states that have adopted the rule; not all authorized states have done so.

This overview is provided for informational purposes only. Due to the matrix's summary nature, it may not capture all regulatory nuances. Facilities should consult applicable regulations and/or seek legal or regulatory guidance when evaluating compliance obligations.