Frequent Questions

Are all hazardous waste generators required to submit the RCRA Biennial Report?

Federally, only large quantity generators (LQGs) are required to submit the Biennial Report (Section 262.41). Small quantity generators (SQGs) and conditionally exempt small quantity generators (CESQGs) are not subject to the federal biennial reporting requirements, but such generators should consult with their implementing agencies since states can have more stringent reporting requirements.

See the Biennial Report Web site.

Note: On November 28, 2016, EPA published the Hazardous Waste Generator Improvements Final Rule, which makes several revisions to the hazardous waste generator regulations including the designation of CESQG changing to very small quantity generator (VSQG). Other revisions may also affect the information provided in this FAQ. The final rule and additional information, including a fact sheet, frequent questions, and a webinar recording and slides, are available at

The Hazardous Waste Generator Improvements Final Rule is effective on May 30, 2017; however, implementation in a particular state depends on the state’s authorization status. A discussion of the effect that this final rule will have on state authorization is available on page 85801 of the rule. Information about how the rule will affect the requirements in this FAQ in a particular state is best obtained from the state hazardous waste program. A list of state hazardous waste programs is available at

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