Small Quantity Generators (SQGs) of hazardous waste faced an important regulatory deadline earlier this month. Under federal rules adopted in 2016, these facilities are required to renotify the U.S. Environmental Protection Agency (EPA) every four years regarding their hazardous waste activities. The most recent deadline was September 1, 2025. Even if your facility did not submit by that date, it is not too late to act. Understanding the SQG hazardous waste renotification rule, why it matters, and how to correct a missed filing is critical to maintaining compliance and avoiding penalties.
What Is the SQG Hazardous Waste Renotification Requirement?
SQGs are facilities that produce between 220 and 2,200 pounds of hazardous waste each month. To comply with federal hazardous waste regulations (40 CFR 262.18(d)), these generators must submit EPA Form 8700-12 to renotify their activities every four years. The form is submitted electronically through the EPA’s RCRAInfo system.
In addition, 40 CFR 262.20(a)(1) was modified, effective January 22, 2025, to require that both SQGs and Large Quantity Generators (LQGs) maintain an active registration in RCRAInfo. This electronic platform is used for site identification, hazardous waste manifesting, and compliance tracking.
Many states also require a separate state-specific notification. For example, Michigan facilities must complete the Site Identification Form (EQP 5150) and submit it to the Department of Environment, Great Lakes, and Energy (EGLE). In authorized states like Michigan, filing with the state agency also fulfills the EPA’s federal renotification requirement. Other states may use their own form or direct generators to EPA’s electronic system, so it is important to confirm your state’s process.
Why Hazardous Waste Renotification Matters for Businesses
The requirement is more than an administrative update. SQG hazardous waste renotification ensures accurate oversight of hazardous waste generators nationwide, allows regulators to target compliance assistance to facilities that need it, and verifies that businesses are handling waste responsibly.
For facilities, staying compliant reduces the risk of enforcement actions, protects against reputational harm, and avoids costly interruptions in waste disposal operations.
Missed the September 1, 2025, Deadline? Here’s What to Do
There are no automatic extensions for facilities that missed the deadline. A missed filing means the facility is technically out of compliance, which may lead to notices of violation, fines, or additional regulatory scrutiny.
If your facility has not yet renotified, the best course of action is to act immediately:
- Submit EPA Form 8700-12 through RCRAInfo as soon as possible, even if late.
- Complete any state-specific forms (such as Michigan’s EQP 5150) required in your jurisdiction.
- Document the reason for the delay to show a good-faith effort and be prepared to explain corrective action if contacted by regulators.
Addressing the lapse quickly can reduce the risk of penalties and demonstrate responsibility to regulators.
Staying Compliant Beyond 2025
Compliance is not a one-time exercise but an ongoing responsibility. To stay ahead, facilities should:
- Maintain internal calendars and reminders for future deadlines.
- Train staff on hazardous waste requirements and recordkeeping.
- Periodically review generator status and update forms if operations change.
These practices not only keep your facility in compliance but also streamline future reporting cycles.
Tetra Tech’s Compliance Support for SQGs
Whether your facility submitted on time or still needs to catch up, Tetra Tech’s regulatory professionals can help you navigate the process. Our team assists with completing and submitting EPA Form 8700-12, preparing state-specific forms, determining generator status, correcting compliance gaps, and advising on proper waste handling practices. For facilities that missed the deadline, we provide guidance on corrective action and communication with regulators to minimize risks. We also help clients set up compliance calendars and internal systems so deadlines are never overlooked in the future.
Take Action Now to Protect Compliance
If your facility is an SQG and you have not yet submitted your renotification, it is important to act quickly. Even though the September 1, 2025, deadline has passed, filing late is far better than failing to file at all. Contact Tetra Tech’s regulatory experts at [email protected] to complete your renotification, bring your program back into compliance, and build a stronger system to support ongoing hazardous waste management requirements.
