Ten states end tube sales
Vermont, California, Oregon, Rhode Island, Colorado, Hawaii, Maine and Minnesota already ban sales of new fluorescent tubes. Illinois follows on January 1, 2027, then Washington in 2029.
Lighting retrofit waste recycling for contractors.
When retrofit lamps are hazardous waste, the building owner must manage them correctly, and ALMR says contractors "may share that legal responsibility". We collect what your crew pulls, schedule pickup around your job, and send a certificate of recycling for every job.
Association of Lighting and Mercury Recyclers (ALMR), Message for Contractors"The most significant environmental enforcement actions concerning incorrect handling of waste lamps and ballasts have involved lighting retrofits."
Program paperwork
Some programs pay only after the paperwork arrives.
Some utility and owner programs ask for proof that removed lamps and ballasts were recycled, sometimes before the incentive is paid. Most large utility programs we reviewed did not. These eight show what that paperwork can look like.
Eugene Water & Electric Board, Oregon
A Lighting Waste Disposal Certificate is due "within two (2) months of the completion of the project". Receipts, a bill of lading or a manifest back it up. PCB ballasts must be counted, so build the deadline into closeout.
Certificate within 2 months
Columbia Water & Light, Missouri
Lamps must go to "a certified recycling agency". The application asks for "Proof of proper disposal of any lamps/and or ballast that fall under the Universal Waste Rule". Collect that proof as the job runs.
Proof of disposal
Concord Municipal Light Plant, Massachusetts
The program requires a completed Lighting Waste Disposal Form for payment. If the form is missing, the incentive waits.
Disposal form for payment
DC Department of General Services
Its retrofit scope of work requires "documentation ... that materials have been recycled". Lamps and ballasts must be removed from the site daily, so staging happens every shift.
Recycling documents, daily removal
Otter Tail Power, Minnesota
"Neither fluorescent lamps nor ballasts may be disposed of as municipal waste". Disposal costs are the customer's to pay, so price them into the project.
No municipal waste
Minnesota Department of Transportation
MnDOT project guidance says "Do not break or crush fluorescent lamps". Crews keep "shipping papers that document where the waste is recycled", which the owner can ask to see.
Shipping papers kept
Connecticut Light & Power
An older NEWMOA survey found the utility asked contractors to "certify that they have a contract with a lamp recycler". The contract had to exist before the work, not after.
Recycler contract certified
ComEd, Illinois
Removed lamps and PCB ballasts "must be permanently taken out of service and disposed of in accordance with local codes and ordinances". Resale is not allowed.
2024 Custom Incentives Application
Sources: each program's published terms, application or scope of work, read October 2026. The Connecticut entry comes from an older NEWMOA survey. Terms change, so check your own program's current version.
On the job
From the first fixture to the owner's file.
A retrofit runs on a schedule, and the lamps have to keep pace with it. This sequence keeps the jobsite clear and the owner's file complete.
Count before demo
Send rough counts of tubes, ballasts and batteries for each building, plus the demo dates. We schedule pickup around your job.
Stage it daily
At the end of each shift, move lamps into closed, labeled containers at one staging point. Keep them whole and out of the debris.
Sort the ballasts
Set pre-1979 and unlabeled ballasts aside, and any leaking unit on its own. We keep pre-1979 and unlabeled ballasts apart from the rest of the load.
One pickup, three streams
Lamps, ballasts and batteries leave in the same visit and are sent to a permitted recycler. Nothing waits for a second vendor.
Hand over the record
A certificate of recycling for every job. ALMR recommends passing it to the building owner, who is the generator, at closeout.
Jobsite and demolition
Staging lamps on a live job.
EPA's demolition guidance says lamps "should be isolated, labeled, and taken to a mercury recycler or consolidation site". It adds that "fluorescent lamps should not be crushed".
EPA also says ballasts made through 1979 may contain PCBs. Non-leaking ones "can be removed and recycled or disposed of properly", while leaking material "must be incinerated" under TSCA. Our ballast recycling page covers the sorting.
- Lamps pulled whole, never crushed
- Lamps kept apart from demolition debris
- One staging point, cleared each shift
- Containers closed except while being filled
- Each container labeled "Used Lamp(s)" or "Waste Lamp(s)"
- Start date written on each container
- Broken lamps cleaned up and contained at once
- Pre-1979, unlabeled and leaking ballasts set apart
- Pre-1991 "silent" wall switches checked for mercury
- Daily removal, where the contract calls for it
- Recycler references and compliance history checked
- Certificate destination agreed with the owner
Sources: EPA, Light Systems and Demolition; EPA, PCB ballast guidance; 40 CFR 273.13, 273.14 and 273.15. EPA also tells contractors to "Check with your state environmental agency". Federal rules shown. States can be stricter. Not legal advice.
Why the work is coming
More retrofits, and state rules that follow the lamps.
Failed tubes can no longer be replaced in a growing list of states, so fixtures get converted. Some states also set rules that change how removed lamps are handled on site.
Replacement stock is shrinking
US shipments of new linear tubes fell from about 400 million in 2015 to about 60 million in 2022. DOE projected under 10 million for 2026.
Local Law 88 upgrades
Covered buildings over 25,000 gross square feet, or groups over 100,000, had to upgrade lighting "No later than January 1, 2025". Each upgrade turned installed tubes into waste.
Lamps must be recycled
Statute 115A.932 says lamps "must be recycled by delivery... to a lamp recycling facility". Several other states ban landfilling lamps even from households.
No crushing on site
The Department of Ecology says it plainly: "You cannot crush waste lamps under the universal waste regulations". Lamps stay whole until pickup.
Contractors notify clients
Maine says "Spent lamps may not be placed in the trash". Its statute, 38 MRSA 1662, also requires contractors to notify their clients. Check the statute for what the notice covers.
Sources: state statutes and ECmag, August 2024, for sales bans. US Department of Energy webinar, July 2022, via LightNOW, for shipments; 2026 is a projection. NYC Local Law 88. Minnesota Statutes 115A.932; state statutes and NEWMOA for household landfill bans. Washington Department of Ecology. Maine 38 MRSA 1662.
Demo date on the calendar?
Send counts now. We schedule pickup around your job.
Contractor questions
What crews and estimators ask.
Short answers on rules, ballasts and paperwork. Each one names its source, so you can pass it along to the owner.
What regulations must be followed?
Three layers usually apply. Lamps fall under federal universal waste rules in 40 CFR Part 273: containers that prevent breakage, labels, and shipment within one year. PCB ballasts fall under TSCA rules in 40 CFR 761. Then add your state's rules and any utility or owner program terms.
Who is the generator on a retrofit job?
Usually the building owner. ALMR's message to owners says "regulatory compliance remains the responsibility of the owner of the lamps". Its message to contractors adds that contractors involved "may share that legal responsibility". Settle in writing, before demolition, who arranges recycling and who keeps the certificate.
How should I package my ballasts for pickup?
Sort them before they go into a container. Keep ballasts marked "No PCBs" together and pre-1979 or unlabeled ones in a separate group. Set leaking ballasts apart: EPA says leaking PCB material must be incinerated under TSCA. We keep pre-1979 and unlabeled ballasts apart from the rest of the load.
I don't have enough ballasts to justify a bulk pickup. What are my other options?
Add them to the lamp pickup. Ballasts come out in the same retrofit, so one scheduled pickup can take lamps, ballasts and batteries together. For a small, lamp-only batch, a mail-back box is the other route. PCB ballasts do not go in lamp mail-back kits.
Are LED lamps hazardous waste?
Not automatically, but do not assume they can go in the trash. LED tubes are not on EPA's universal waste lamp list. North Carolina DEQ and California DTSC say businesses must evaluate them. DTSC recommends managing them as universal waste when unsure.
What happens to the disposed lamps?
They are taken apart and recycled. EPA says the metal end caps, glass tubing and phosphor powder can all be separated and recycled. Recovered mercury goes into new lamps, metal is sold as scrap, and glass is remanufactured. Our lamp recycling page covers each lamp type we take.
What does a certificate of recycling show?
Typically the total weight of material a recycler received on a given date. J.J. Keller describes it as the "recycler's certification of, typically, the total weight" received. It is recommended practice, not a federal mandate, though EPA's program guide lists "maintain Certificates of Recycling" as a step.
What is the most common lighting recycling program option?
EPA's program guide lists four: pickup, mail-in, milk-run and self-transport. Retrofits usually fit scheduled pickup, because lamps and ballasts come out together in bulk. Mail-in suits small lamp-only batches. Hauling lamps yourself makes you a transporter under 40 CFR 273.18, with DOT rules attached.
Does a retrofit job need an EPA ID number?
Only if a site becomes a large quantity handler. Under 40 CFR 273.9, that means holding 5,000 kg or more of universal waste at any time, all types combined. The handler must notify EPA and get an ID before reaching that amount (273.32). Regular pickups keep accumulation well below it.
Can we crush tubes on site to save space?
Usually not. EPA's demolition guidance says "fluorescent lamps should not be crushed", and EPA treats drum-top crushing as treatment. Washington and New York say lamps under universal waste rules cannot be crushed. Vermont and Maine ban drum-top crushers outright. Keep lamps whole until pickup.
Do I have to count every lamp before pickup?
No. Rough counts per building are enough for a written quote and a pickup plan. A certificate of recycling typically records the total weight received, not a lamp-by-lamp tally. If your program asks for counts, such as EWEB's PCB ballast count, keep a simple tally as fixtures come down.
What do we do with lamps that break during removal?
Clean them up at once and seal them in their own container. 40 CFR 273.13(d)(2) says to "immediately clean up and place in a container any lamp that is broken". Contain any release under 273.17. EPA notes that intentionally crushed lamps "cannot be shipped as universal waste in many states".
Send the counts before demo day.
Rough counts per building are enough to start. We reply with a written quote, and we schedule pickup around your job.