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EPA Biennial Report 2024: Who needs to file and what to do

The next Biennial Report will be due on March 1, 2024. If you generate a significant amount of hazardous waste, you may qualify.   


Who Qualifies?
Federal regulations mandate the completion and submission of a EPA Biennial Hazardous Waste Report, also known as the “Biennial Report,” or an equivalent state hazardous waste report that follows the same data collection instructions. You are required to file this report under the following circumstances: 

1. You meet the Federal definition of a RCRA Large Quantity Generator (LQG) in any month during the collection year (which occurs in odd years). The definition of an LQG includes: 

  • Generating 1,000 kilograms (2,200 pounds) or more of non-acute RCRA hazardous waste in any calendar month. 
  • Generating or accumulating more than 1 kilogram per month (2.2 pounds per month) of any RCRA acute hazardous waste listed in 40 CFR 261.31 or 261.33(e) in a calendar month. 
  • Generating or accumulating more than 100 kg/mo (220 lbs/mo) of residue or contaminated soil, waste, or other debris resulting from the cleanup of a spill, into or on any land or water, of any RCRA acute hazardous waste listed in 40 CFR 261.31 or 261.33(e) in any calendar month. 

2. If you treated, stored, recycled, or disposed of RCRA hazardous wastes on-site or shipped hazardous waste offsite to a RCRA permitted treatment, storage, recycling, or disposal facility, or received hazardous wastes from off-site generators for recycling without storing the wastes before recycling during the reporting year (odd years). 

3. If you meet the definition of a reverse distributor as defined in 40 CFR 266.500 during the collection year (odd years). 

Reverse distributor means any person that receives and accumulates prescription pharmaceuticals that are potentially creditable hazardous waste pharmaceuticals for the purpose of facilitating or verifying manufacturer credit. Any person, including forward distributors, third-party logistics providers, and pharmaceutical manufacturers, that processes prescription pharmaceuticals for the facilitation or verification of manufacturer credit is considered a reverse distributor. 


Note: If you meet the LQG definition in any calendar month, you are required to complete the Hazardous Waste Report for the entire reporting year. 


What to do: 

If we already do periodic site visits to your facility as a part of our compliance management service, our project managers will check if you need to complete the EPA Biennial Report and if so, will add reminders to your compliance calendar.  

If you need help with completing the EPA Biennial Report or finding out if you qualify, contact us at We look forward to assisting you. 

Click here for related FAQ and details of EPA Biennial Report regulatory requirements