Frequent Questions

What is a commercial chemical product (CCP) and what is its regulatory status when reclaimed?

A commercial chemial product (CCP) is an unused chemical intermediate, off-specification variant, or spill or container residues as defined in §261.33 (50 FR 614, 618; January 4, 1985). CCPs include all types of unused chemical products, including products that would not commonly be considered chemicals (e.g., circuit boards, batteries, and other types of equipment) (Monthly Call Center Report Question; August 1996, RCRA Online #14012). 

The term also includes chemical products that are not listed in §261.33 but exhibit one or more characteristics of hazardous waste (50 FR 14216, 14219; April 11, 1985). 

The regulatory status of a secondary material when reclaimed depends on the type of material reclaimed. CCPs are not regulated as solid wastes when reclaimed. CCPs are also not solid wastes when speculatively accumulated, but are solid waste when used in a manner constituting disposal or burned for energy recovery,used to produce a fuel or contained in fuels (Section 261.2(c)).
 
Additional guidance on CCPs is available in the following documents: 

Memo, Lowrance to Kaul; February 23, 1993 (RCRA Online #11726
Monthly Call Center Report Question; August 1991 (RCRA Online #13490
Memo, Clay to Ream; November 28, 1990 (RCRA Online #13431
Memo, Williams to Gray; January 20, 1988 (RCRA Online #11321)

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