Frequent Questions

Importers of hazardous waste are subject to the generator requirements in Part 262. However, when more then one person is involved in the importation of hazardous waste who must comply with the generator responsibilities?

Where more than one person falls within the scope of an importer, all parties involved with the importation of hazardous waste can be held jointly and severally liable for compliance with the generator requirements in Part 262 (Memo, Shapiro to Ouellete; March 22, 1994 (RCRA Online 11820)). [PDF 9K]  However, we recommend that one of the parties assume the generator responsibilities on behalf of all parties.  EPA encourages such agreements and will look to the designated party to perform all of the generator responsibilities.  However, EPA reserves the right to enforce against any of the parties if the requirements of Part 262 are not adequately met (Memo, Skinner to Seraydarian; June 25, 1985 (RCRA Online 11085)).

Additional guidance regarding RCRA regulation of hazardous waste importers is available in the following documents:

Monthly Call Center Report Question; March 1995 (RCRA Online 13739)
Monthly Call Center Report Question; January 1995 (RCRA Online 13725)

Further information regarding the import of hazardous waste is available at the following URL:

http://www.epa.gov/epawaste/hazard/international/imp-exp.htm

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