EPA Small Quantity Generator Renotification Requirement – Due September 1, 2025
by Gary Jones, Vice President of Environmental, Health, and Safety Affairs Aug 14, 2025

Under the 2016 Hazardous Waste Generator Improvements Rule, the U.S. Environmental Protection Agency (EPA) requires all Small Quantity Generators (SQGs) of hazardous waste to re-notify EPA or their state environmental agency of their generator status every four years. This requirement helps maintain accurate data for compliance assistance, oversight, and outreach activities. Because many printing operations are classified as SQGs, this is a new and relevant requirement that needs to be met.

Who Is an SQG?

Under EPA’s definitions, an SQG is a facility that generates more than 100 kilograms (220 pounds) but less than 1,000 kilograms (2,200 pounds) of hazardous waste per month. Generally, this equates into about a half of a 55-gallon drum of waste up to 3-4 55-gallon drums per month.

Almost all states recognize EPA’s definition of a SQG, but not all of them. For example, in Maryland, a “fully regulated generator” includes both EPA’s defined SQGs and Large Quantity Generators (LQGs).

What SQGs Must Do

The next renotification is due September 1, 2025, and then every four years thereafter (e.g., 2029, 2033). SQGs must complete and submit the Notification of RCRA Subtitle C Activities Site Identification Form, known as EPA Form 8700-12 or a state-equivalent form.

There are two options for submitting the form. It can be downloaded and submitted in hard copy to your state or electronically using myRCRAID. Many states are now using myRCRAID, an online system for submitting the Site ID form. myRCRAID is a module of the larger RCRAInfo program which is an online platform that allows a facility to track information about their hazardous waste generation, manifests, and other key data.

State-Specific Requirements

The renotification requirement applies in states that have adopted the EPA’s Hazardous Waste Generator Improvements Rule, as well as in states (e.g., Iowa and Alaska), Native American Country, and U.S. Territories where the rule is administered by an EPA regional office. Refer to EPA’s map of where the Generator Improvements Rule is currently in effect.

Some states may require renotification more frequently than every four years. SQGs should check with their state environmental agency for specific requirements.

Requirements for Large and Very Small Quantity Generators

Large quantity generators of hazardous waste, or LQGs, are required to re-notify EPA of their status by March 1 of each even-numbered year using Form 8700-12. LQGs may submit this re-notification as part of the Biennial Report required under 40 CFR 262.41.

Very Small Quantity Generators (VSQGs) are not required to obtain an EPA ID number and therefore have no re-notification requirement.

For More Information and Assistance

If you are not certain about your generator status, what is a hazardous waste, or what your state requires, please contact the Alliance’s EHS staff - Gary Jones at gjones@printing.org or Sara Osorio at sosorio@printing.org.

In this article, Gary Jones, Vice President of EHS Affairs, PRINTING United Alliance, addresses EPA compliance. More information about EPA can be found at Business Excellence-EHS Affairs or reach out to Gary should you have additional questions specific to how these issues may affect your business: gjones@printing.org.     

To become a member of the Alliance and learn more about how our subject matter experts can assist your company with services and resources such as those mentioned in this article, please contact the Alliance membership team: 888-385-3588 / membership@printing.org. 

Compliance Environmental Health / Safety
Gary Jones Vice President of Environmental, Health, and Safety Affairs
Hire This Expert

Gary A. Jones is the Vice President of Environmental, Health and Safety (EHS) Affairs at PRINTING United Alliance. His primary responsibility is to monitor and analyze EHS and sustainability related legislative and regulatory activities at the federal and state levels, including some international actions. He provides representation on behalf of the printing, packaging, and graphic arts industry. Mr. Jones works closely with the federal and state-level Environmental Protection Agencies (EPA), Occupational Safety and Health Agency (OSHA), Department of Transportation (DOT), and other agencies. He also provides membership assistance on EHS compliance and sustainability programs through a variety of approaches including responding to inquiries, presentations, writing, and consulting services.

Mr. Jones is also supporting PRINTING United Alliance’s efforts for the Sustainable Green Printing Partnership (SGP). SGP is dedicated to assisting printing operations respond to customer demands for sustainable printing.

He holds a BS in biology from LaRoche College and an MS in chemistry from the University of Pittsburgh.

Speaking Topics:

  • EPA and OSHA compliance topics for the printing industry
  • Sustainability trends, impacts, and compliance requirements
  • Customized seminars and workshops, including: Compliance Today, Beyond Compliance Tomorrow, OSHA Compliance Essentials, and Hazardous Waste Boot Camp
  • Customized seminars and workshops on EPA and OSHA Compliance and Sustainability

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