Large and small quantity hazardous waste generators (LQGs and SQGs) typically must re-notify EPA or their state environmental agency every four years. Some states even require very small quantity generators (VSQGs) to re-notify. Re-notification improves generator data for outreach, compliance assistance, and oversight purposes.

To determine how this mandate applies to a specific dealership location:

  1. Learn how waste generator re-notification is handled in your state by contacting your state dealer association or state hazardous waste office. States vary as to which wastes must be counted as “hazardous,” which generators must re-notify, and which re-notification form to use.
  2. Determine if the dealership location is a LQG (generates about 2,200 pounds or more of hazardous waste per month), a SQG (generates between 220 and 2,200 pounds of hazardous waste per month), or a VSQG (generates less than 220 pounds of hazardous waste per month. NADA estimates that many, if not most, dealership locations are VSQGs. To assist with these determinations, check dealership files for prior generator notifications and review NADA’s Dealer Guide to Federal Hazardous Waste Law.

If re-notification is required, complete and submit a federal Notification of Resource Conservation and Recovery Act (RCRA) Subtitle C Activities (also known as the RCRA Subtitle C Site Identification Form or EPA Form 8700-12), or the state form equivalent. If possible, use MyRCRAID to re-notify online.

Find more information on re-notification mandate and on Form 8700-12 here. For further assistance, call or email your state or EPA regional hazardous waste office.

Contact [email protected] with questions.