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Universal Waste

Universal waste is a subset of hazardous waste and may contains mercury, lead, cadmium, copper and other substances hazardous to human and environmental health. Universal wastes are generated from a wide variety of sources (i.e., individuals, government agencies, hospitals, businesses, etc.) in a variety of settings, not just in traditional industrial settings.

In 1995, U.S. EPA developed an alternate, streamlined management program to encourage the collection and recycling of these commonly generated hazardous wastes. The federal universal waste regulations can be found in 40 CFR Part 273. Virginia Department of Environmental Quality has adopted the federal universal waste regulations by reference with a few additional requirements. DEQ regulations can be found at 9VAC20-60-273. Managing qualifying hazardous wastes as universal waste is optional. Generators have the choice to manage hazardous wastes that fit into the categories of universal waste as universal wastes under Part 273 or under the complete hazardous waste requirements.

Management of Universal Waste

The universal waste regulations were developed with several interrelated goals in mind: encourage the recycling of the categories of wastes designated as universal waste; improve the management of certain types of hazardous wastes reduce the amount of hazardous waste that ends up in solid waste landfills and combustors; ease the regulatory burden on the facilities that manage these wastes, particularly by allowing more time for accumulation of these wastes in order to facilitate appropriate recycling or disposal; and ensure that these wastes go to appropriate treatment or recycling facilities.


  • Universal waste volume is not included when determining hazardous waste generator status. This may benefit some companies by allowing them to reduce their generator status level which in turn would reduce their generator regulatory requirements.
  • Universal waste can be accumulated for up to one year which is a longer accumulation time than allowed for small quantity and large quantity generators of hazardous waste.
  • Less labeling is required on universal waste.
  • A hazardous waste manifest is not required to accompany a universal waste shipment in Virginia or within any other state that recognizes it as universal waste.
  • Less recordkeeping is required.
  • A shipment of universal waste can be transported via a universal waste transporter rather than a hazardous waste transporter.


Categories of Universal Waste

The applicability of the universal waste requirements to each category of waste described below can be found in 40 CFR Part 273 Subpart A and are discussed further on DEQ's web page, "Specific Universal Waste Types - Management Requirements". Universal wastes that are mixed with hazardous wastes are fully regulated as hazardous wastes. Mixtures of universal waste and very small quantity generator (VSQG) waste or household hazardous waste can be managed under the universal waste requirements since these hazardous waste are not subject to full hazardous waste regulation.

Universal Waste Categories:

Mercury-Containing Equipment: Devices that contain elemental mercury integral to their function. Includes thermostats, but does not include batteries or lamps.
Pesticides: Substances that are intended for preventing or mitigating pests or intended for use as a plant regulator or defoliant. Excludes animal drugs and animal feed containing animal drugs.
Batteries: Devices consisting of one or more electrically connected electrochemical cells designed to receive, store and deliver electric energy. Includes nickel cadmium batteries and lead acid batteries.
Lamps: Bulbs or the tube portion of electric lighting devices that are specifically designed to produce radiant energy. Includes mercury vapor lamps, fluorescent light bulbs, and neon lights.

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Virginia Department of
Environmental Quality
P.O. Box 1105
Richmond, VA 23218
(804) 698-4000

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