What Are the RCRA Reporting Requirements? Guide to the Biennial Report & More

Key Takeaways

• Generator status under RCRA is determined by monthly hazardous waste output and controls whether a facility must file a hazardous waste report, how often, and with what form.
• The biennial report due date is March 1 of every even-numbered year, and it must be filed using EPA form 8700 13A/B by all Large Quantity Generators (LQGs) and TSDFs.
• Other RCRA reporting requirements, like exception reports, manifests, and EPA form 8700 12, depend on how waste is handled, transported, or if incidents occur on site.
• State-specific rules may expand waste reporting obligations even for Small or Very Small Quantity Generators, especially for organizations operating across multiple states.

Who Must Report Under RCRA?

Under the Resource Conservation and Recovery Act (RCRA), generator classification is based on the amount of hazardous waste a facility generates during any given calendar month. That monthly total determines the generator category, which in turn defines which RCRA reporting requirements apply.

Each category has different obligations for reporting, tracking, and managing hazardous waste.

Large Quantity Generators (LQGs)

• LQGs generate 1,000 kg (≈2,200 lbs) or more of hazardous waste in a calendar month, or more than 1 kg (≈2.2 lbs) of acutely hazardous waste.
• LQGs must submit a hazardous waste report every two years using EPA Form 8700 13A/B.

Small Quantity Generators (SQGs)

• SQGs generate between 100 kg and 1,000 kg (≈220–2,200 lbs) of hazardous waste per month.
• SQGs are not required to file a biennial report at the federal level. However, some states require annual or other periodic reporting, which can catch people off guard if they only follow EPA rules.

Very Small Quantity Generators (VSQGs)

• These facilities produce less than 100 kg (≈220 lbs) of hazardous waste per month.
• VSQGs are exempt from federal biennial reporting, but must still manage waste properly and meet storage, labeling, and disposal rules. Some states may require reporting even at this level.

Treatment, Storage, and Disposal Facilities (TSDFs)

• If you manage, treat, or store hazardous waste on a commercial scale, you fall under this category.
• TSDFs are always required to submit a hazardous waste report, and it has to cover a lot more detail than what most generators provide.

Not all states mirror federal requirements. I keep bookmarked pages for California, Texas, and New York because their waste reporting rules go beyond the EPA’s. Texas, for example, often requires annual reporting for SQGs, and California includes state-regulated (non-RCRA) waste in their submissions. If your facility operates in multiple states, this can quickly become confusing.

What Is a Biennial Report?

A biennial report is a federally required submission under the RCRA for sites that meet the criteria of a Large Quantity Generator (LQG) or operate as a Treatment, Storage, and Disposal Facility (TSDF). It provides the Environmental Protection Agency (EPA) with detailed information on the generation, management, and final disposition of hazardous waste.

The report allows the EPA to:

• Track hazardous waste generation trends across industries and regions.
• Monitor how waste is treated or disposed of, both on-site and off-site.
• Compare reporting data between generators, transporters, and TSDFs for consistency.

The biennial report is required for:

• Any site that was classified as an LQG during any month of the reporting year.
• All TSDFs that received hazardous waste from off-site sources.
• Sites that met LQG status temporarily are still obligated to report for the full year.

The biennial report is filed using EPA form 8700 13A and may be accompanied by 13B. It includes:

• Facility identification details, including EPA ID number and contact information
• Generator status during the year
• Waste codes, types, and total amounts of hazardous waste generated
• On-site treatment, storage, or disposal methods used
• Off-site shipment data, including transporter and receiving TSDF details
• Final waste management methods applied by the TSDF

How and When to Submit a Biennial Report?

The biennial report due date is March 1 of every even-numbered year. Each cycle reflects the previous odd-numbered calendar year’s hazardous waste activity. For example, a report filed by March 1, 2026, would document waste from 2025.

There are three ways facilities typically submit their report:

1. EPA RCRAInfo Industry Application: This is the primary online system for most states. It allows digital completion and submission of EPA form 8700 13A.
2. State-managed portals: Some authorized states do not use RCRAInfo and require submission through a state-specific site.
3. Manual/PDF submission: In rare cases where electronic systems aren't used, the form can be completed and submitted directly to the state agency.

Before getting started, I double-check the submission method required in the state where the site is located. That helps avoid uploading to the wrong system or missing supplemental forms.

Most of what goes into the report is already part of your regular tracking: manifests, shipment logs, and waste totals. As long as those records are accurate, the submission process is more about organization than discovery.

Other RCRA Waste Reporting Requirements

The biennial report is just one part of the full picture. There are other RCRA reporting requirements that may apply depending on how hazardous waste is managed, shipped, or handled on-site.

I keep these grouped by type so it’s easier to reference when planning out annual compliance tasks. Some apply only once during setup, others are triggered by specific events or state rules.

Notification of Regulated Waste Activity (EPA Form 8700-12)

Before a facility can manage hazardous waste under RCRA, it has to notify the EPA or its state agency using EPA form 8700 12. This applies when a site first becomes a generator, but also when there are changes to operations that affect its status.

The same form is used for multiple purposes:

• Initial notification when a facility begins hazardous waste generation, transport, treatment, storage, or disposal.
• Re-notification when generator status changes (such as from SQG to LQG), or when the EPA ID number needs to be updated.
• Site changes, including ownership, contact information, or closure.

The most common mistake I run into is assuming this form is a one-time submission—it’s not. Anytime the generator status shifts or the site undergoes operational changes, EPA form 8700 12 needs to be reviewed and refiled if necessary.

Some states require re-notification at regular intervals even if there are no changes. For example, SQGs must submit a re-notification every four years under the federal rules, but some states shorten that cycle.

If you're using EPA’s RCRAInfo system, the form can be completed and submitted online. Some states still require a hard copy or a separate submission through their own portal.

Exception Reports

An exception report is required when a hazardous waste shipment does not reach its intended Treatment, Storage, or Disposal Facility (TSDF) within a specific timeframe. This requirement applies only to generators and helps ensure that hazardous waste is not lost or mishandled during transport.

Reporting is triggered based on generator status:

• Large Quantity Generators (LQGs) must submit an exception report if they do not receive a signed copy of the manifest from the receiving TSDF within 45 days of shipment.
• Small Quantity Generators (SQGs) must submit a shorter version of the report if the manifest is not returned within 60 days. This applies only in states that follow the federal regulations.

The exception report must include:

• A legible copy of the original manifest
• A written description of efforts made to locate the missing shipment or obtain the TSDF copy

Failure to file an exception report on time may be considered a violation of the RCRA reporting requirements, especially if the waste remains unaccounted for after the deadline.

Manifest and e-Manifest Requirements

The Uniform Hazardous Waste Manifest is a standardized tracking document required for the shipment of hazardous waste from the point of generation to the receiving TSDF. It is designed to ensure proper tracking and accountability during transportation.

The manifest must include:

• Generator information and EPA ID
• Waste codes, quantities, and descriptions
• Transporter details
• Destination facility information
• Generator, transporter, and TSDF signatures

A copy of the manifest must accompany the shipment at all times. Each party involved must retain their signed copy for recordkeeping purposes.

To modernize the process, the EPA launched the e-Manifest system, which allows for digital tracking of hazardous waste shipments. Facilities can:

• Create and submit manifests electronically
• Sign digitally using verified accounts
• Access manifest histories through the EPA’s e-Manifest portal

State-Specific Annual Reports

Some states require hazardous waste generators to submit an annual facility report, even if a site is not subject to the federal biennial reporting schedule. These state-specific programs are authorized by the EPA but often go further than federal rules.

Key differences may include:

• Reporting frequency: Some states require annual submissions instead of every two years.
• Lower thresholds: Reports may be required from Small Quantity Generators (SQGs) or even Very Small Quantity Generators (VSQGs).
• Expanded scope: Some reports include non-RCRA hazardous waste or require more detailed waste descriptions.

This matters especially for organizations with sites in multiple states. A generator that qualifies for exemption under federal rules—or in one state—may still have to file a hazardous waste report elsewhere. Differences in classification, required forms, and digital systems can lead to inconsistencies if each site isn’t managed by local compliance staff familiar with state rules.

I suggest keeping a state-by-state compliance calendar when managing waste reporting across regions. It helps track submission windows, formats, and thresholds so that nothing gets missed, especially in states with rules that differ from the federal baseline. Inconsistent filings can still raise issues during audits, even when the federal report is on time.

Release or Emergency Incident Reporting

RCRA requires facilities to report certain incidents involving hazardous waste, particularly unpermitted releases or emergency situations that threaten health or the environment. These reports are separate from routine waste reporting and must follow emergency response protocols under 40 CFR Part 264/265, Subpart D.

A release report may be required when:

• Hazardous waste is spilled or released outside of approved containment areas.
• There is a fire, explosion, or other event that could threaten people or the environment.
• On-site equipment fails, leading to an uncontrolled discharge of waste or runoff.

If the facility is operating under a permit, the incident must be managed under the site's contingency plan. Unpermitted facilities (such as generators accumulating waste on-site) must follow the emergency procedures for their generator category. The facility must document the incident in its operating record and submit a written report to the EPA Regional Administrator within 15 days after the incident.

In some cases, RCRA reporting overlaps with other federal programs like the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and Emergency Planning and Community Right-to-Know Act (EPCRA).

These programs may require additional notifications or follow-up actions. I check incident details against the thresholds in each regulation to confirm what applies. Filing late or missing a required notification can result in enforcement actions, even if the incident itself was well-managed.

Tools and Resources for RCRA Waste Reporting

I keep a short list of resources I refer to whenever I’m working through RCRA reporting requirements, especially during prep for a hazardous waste report or when helping others figure out which rules apply. These tools help answer questions about generator status, submission methods, and how to handle forms like EPA form 8700 13A.

• EPA Biennial Report Page: Covers who must file, how to complete the form, and the official biennial report due date. Updated each cycle with current instructions.
• RCRAInfo Industry Application: Used to file the hazardous waste report electronically in most states. I use this to access previous filings and confirm site registration before submitting a biennial report.
• EPA Generator Categories Guide: Outlines the thresholds that define each generator type. This helps when reviewing how monthly quantities affect reporting and when waste reporting obligations begin.
• Hazardous Waste Determination Resource: Useful for reviewing how waste is classified and whether it falls under RCRA rules before any waste reporting begins.
• State Waste Program Directory: If I’m working across multiple states, I check this to confirm which forms and frequencies apply locally. It links to each state’s environmental agency.

These are the links I go back to when I need to double-check classifications, submission methods, or state-specific exceptions. Having them in one place cuts down on the time spent tracking down official sources, especially when preparing a hazardous waste report ahead of the biennial report due date.

Reporting Best Practices

Applying a consistent structure to hazardous waste tracking and submission reduces errors and helps maintain compliance across reporting cycles. These best practices support accurate filing and smooth preparation ahead of each biennial report due date.

• Centralize reporting records in one system: Storing manifests, EPA form 8700 13A, generator logs, and waste codes in a single location improves consistency across filings. This is especially helpful when multiple team members or sites are involved in waste reporting.
• Confirm generator status for each reporting period: Generator categories can change month to month, which affects RCRA reporting requirements. Reviewing totals for each month helps avoid underreporting or missed obligations.
• Validate EPA ID numbers and facility contact details: Errors in identification numbers or outdated contact info can cause delays or rejected submissions. This is especially important for facilities filing a hazardous waste report through RCRAInfo.
• Reconcile waste codes and shipment records early: Comparing current inventory with past manifests helps catch discrepancies before the biennial report is due. This step also supports accurate classification and quantity reporting.
• Update transporter and TSDF information: Verifying that transporter IDs and receiving facility details match the manifest ensures data accuracy across submissions. Inconsistent or incomplete records can trigger follow-up from regulators.
• Begin preparing well before the biennial report due date: Early prep gives enough time to track down missing documents and identify changes that affect your hazardous waste report. Sites that wait until the last minute often run into data gaps that delay submission.

Strong reporting depends on consistency more than complexity. The systems don’t need to be complicated, but they do need to be reliable. Facilities that treat hazardous waste data as part of their regular operations, not just a task tied to the biennial report due date, tend to submit with fewer corrections and less last-minute stress. When internal records align with EPA expectations, the process becomes less about chasing documents and more about confirming what’s already in place.

Hazardous Waste Report FAQs

What is the 90-day rule for hazardous waste?

The 90-day rule requires Large Quantity Generators (LQGs) to ship hazardous waste off-site within 90 days of accumulation. This affects generator status, which determines whether a hazardous waste report is required under RCRA reporting requirements.

Does RCRA reporting apply to satellite accumulation areas?

Satellite accumulation areas are part of a generator’s site and do not trigger separate reporting. However, waste accumulated in these areas still counts toward monthly totals used to determine biennial report obligations.

Whose signatures must be on a hazardous waste manifest?

The hazardous waste manifest must be signed by the generator, each transporter, and the receiving Treatment, Storage, or Disposal Facility (TSDF). These signatures establish the waste’s chain of custody and support the data reported in the hazardous waste report.

What is the minimum required retention period for hazardous waste manifests?

Manifests must be retained for three years from the date the initial transporter accepts the waste. Proper recordkeeping supports reporting accuracy and documentation during audits.

Can I correct or revise a biennial report after submission?

Yes, a submitted biennial report can be corrected by submitting a revised version of EPA form 8700 13A through RCRAInfo or the state portal. The correction must be clearly labeled and should be submitted as soon as possible, preferably before the next biennial report due date.

TRADESAFE provides premium industrial safety equipment, such as Lockout Tagout Devices, Eyewash Stations, Absorbents, and more; precision-engineered and trusted by professionals to offer unmatched performance in ensuring workplace safety.