Frequently asked

Lamp, ballast and battery recycling, answered.

We collect fluorescent, CFL and HID lamps, ballasts and batteries, by scheduled pickup or a mail-back box. Here are short, sourced answers to what facilities teams and contractors ask before a job, in six groups.

In plain terms

Spent mercury lamps and batteries from a business are usually universal waste under 40 CFR Part 273. That means closed, labeled containers, up to one year of storage, and shipment for recycling. Ballasts that contain PCBs follow a separate law, 40 CFR Part 761.

The rules

Disposal, storage and ballasts.

Federal answers first, with the state differences that change them. For the full rule set in one place, read the compliance guide.

Disposal and the rules

Are fluorescent tubes hazardous waste in every state?

Federal RCRA rules require many businesses to recycle mercury lamps. The universal waste rule, 40 CFR Part 273, gives them a lighter track than full hazardous waste rules. States go further. California, Minnesota, Washington, Maine, Massachusetts and Vermont ban landfilling lamps even from households.

If I don't generate many lamps, am I still required to recycle them?

Federally, households and very small quantity generators may choose whether to use the universal waste rule (40 CFR 273.8). Mix their lamps with regulated universal waste, though, and all of it is regulated. Some states remove the choice: Minnesota's statute says lamps "must be recycled."

Do I need an EPA ID number for lamps?

Only once you become a large quantity handler. Under 40 CFR 273.32, a handler must notify EPA for an ID before holding 5,000 kg of universal waste at any time. That figure combines lamps, batteries and other universal waste. Large handlers keep shipment records for three years (273.39).

Are LED lamps hazardous waste?

Not automatically, and not automatically exempt. LED lamps are not on EPA's universal waste lamp list. North Carolina DEQ and California DTSC say businesses must evaluate them. DTSC advises managing them as universal waste if unsure. Check your state agency's position before a retrofit.

How are my spent lamps regulated?

Unless a lamp is shown to be non-hazardous, 40 CFR 273.5 brings it under the universal waste rule. Under the rule, a used lamp "becomes a waste on the date it is discarded" and the one-year storage clock starts. The container, label and training duties apply from that day too.

Do fluorescent bans apply to existing buildings?

No. The state bans stop the sale of new fluorescent lamps, not their use. Illinois Public Act 103-0799 covers lamps sold "as a new manufactured product" and says nothing about lamps already installed. What changes is replacement: once new tubes are hard to buy, fixtures get converted.

Storage and breakage

How should lamps be stored?

Whole, in containers "structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps" (40 CFR 273.13(d)(1)). Keep each container closed between fills. Staff who handle the lamps must know the handling and emergency procedures, under 273.16.

What should the container labels say?

One of three phrases set by 40 CFR 273.14(e): Universal Waste Lamp(s), Waste Lamp(s) or Used Lamp(s). You also need to show how long each container has been stored. The rule accepts a date on the container, an inventory system, or a marked storage area (273.15).

Can broken lamps be recycled?

Yes, if they are contained right away. Federal rules say to clean up and containerize any broken lamp immediately (40 CFR 273.13(d)(2)). Keep broken lamps in their own closed container. Lamps crushed on purpose are different: EPA notes they cannot ship as universal waste in many states.

Crushing mercury lamps: when is it acceptable?

It depends on the state, and the safe default is never. EPA treats drum-top crushing as treatment. Vermont and Maine ban drum-top crushers, and New York and Washington say universal waste lamps cannot be crushed. Illinois allows on-site crushing only to reduce volume, and Florida allows drum-top crushers.

Ballasts

Can ballasts go in the trash?

Federally, sometimes; in practice, rarely. 40 CFR 761.60(b)(2)(ii) lets intact PCB small capacitors go out as municipal solid waste. Missouri DNR warns that landfilling carries a "high potential of CERCLA liability" anyway. Ramsey County, Minnesota calls trashing PCB ballasts illegal. King County, Washington bars all ballasts from transfer stations.

Which ballasts might contain PCBs?

Older magnetic ones. EPA says only T12 magnetic ballasts, not T8 or T5 ballasts, may contain PCBs. Where the PCBs sit matters too. PCBs only in the small capacitor follow one path. PCBs in the potting material make the ballast bulk product waste (40 CFR 761.3, 761.60).

What if an older ballast is leaking?

Handle it as PCB waste. EPA classes a leaking PCB ballast as bulk product waste for incineration, and fixtures it contaminates as PCB remediation waste. Cleanup falls under 40 CFR 761.125, and storage for disposal is capped at 30 days (761.65(c)(1)). Intact lamps from that fixture stay universal waste.

I don't have enough ballasts to justify a bulk pickup. What are my other options?

Add them to a lamp pickup, or use a container made for ballasts. Sellers offer non-PCB ballast pails by mail, but PCB ballasts do not go in lamp mail-back kits. On our pickups, we keep pre-1979 and unlabeled ballasts apart from the rest of the load.

Sources: EPA universal waste, lamp basics and PCB ballast pages. 40 CFR 273 and 761. NC DEQ, CA DTSC, Missouri DNR, Ramsey County MN, King County WA. State statutes and NEWMOA. Illinois PA 103-0799. Federal rules shown. States can be stricter. Not legal advice.

Lamps already piling up?

Send rough counts and we reply with a written quote.

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The job

Batteries, boxes, records and price.

The practical side: what goes in which container, what the paperwork shows, and how lamp recycling is priced.

Batteries

Are lithium batteries hazardous waste?

Usually, once discarded. EPA says most lithium-ion batteries "are likely to be hazardous wastes when they are disposed of" since they can ignite or explode. Both rechargeable lithium-ion and single-use lithium batteries can be managed as universal waste. Keep them out of household garbage and recycling bins.

Is there any specific way I should prepare my batteries for recycling?

Yes, especially for lithium. EPA advises bagging each battery, or device containing one, separately. Cover the terminals with non-conductive tape, such as electrical tape. Keep every cell casing intact: 40 CFR 273.13(a)(2) allows handling only while each casing stays unbreached and closed.

Can a damaged, defective, or recalled battery be managed under universal waste?

Damaged batteries stay in the system if contained: 40 CFR 273.13(a)(1) requires leaking or damaged batteries to be containerized. For a damaged lithium-ion battery, EPA says to contact the maker for handling instructions. DOT lets damaged lithium batteries travel only by highway, rail or vessel, individually packed (49 CFR 173.185(f)).

Can different battery types share one container?

Federally, yes. 40 CFR 273.13(a)(2) lets handlers sort batteries by type or mix types in one container. Lead-acid batteries managed under Part 266 sit outside these rules (273.2). Lithium batteries still go in their own bags with taped terminals inside that container, per EPA's guidance.

Boxes and pickups

Can you mix different types of bulbs in a recycling kit?

Usually not across lamp types. Sellers offer separate containers for straight tubes, U-bends and HID, CFLs, ballasts and batteries, and one medium tube box excludes CFLs. PCB ballasts do not go in lamp mail-back kits. Our mail-back boxes page covers what goes where.

Can I place broken lamps in a prepaid recycling container?

Usually not. USPS lamp program bulletins accept intact lamps only. They note "A broken lamp is classified as hazardous waste" there. One large seller excludes broken and shatter-resistant bulbs from its kit. Seal broken lamps in their own closed container and ask for them to be quoted separately.

Why can't I use other boxes I have to return my waste?

Because the shipping exemption depends on the package. DOT exempts intact lamps holding up to 100 mg of mercury each, in packages holding up to 1 g (49 CFR 173.164). A 2013 PHMSA interpretation adds a drop test. A box that has not passed that test does not qualify.

Do I have to count every lamp before they're shipped or picked up?

Not to the last tube. Rough counts by type are enough for a quote. For your own records, large quantity handlers must keep shipment records for three years (40 CFR 273.39). Many reporting tools want weight, not counts. You get a certificate of recycling for every job.

How often should lamps be picked up?

Often enough that no container passes one year in storage, the federal limit in 40 CFR 273.15. Volume matters too. Holding 5,000 kg or more of universal waste at once makes you a large quantity handler, with more duties. We schedule pickup around your job.

What do I do with the boxes once they're filled?

Seal them and ship them within the year. USPS lamp program bulletins say to date the box when filling starts and not to overfill it. Seal it with tape at least 3 inches wide. Each filled box still counts against the one-year storage limit in 40 CFR 273.15.

Records and price

What happens to the lamps once they're shipped or picked up?

They are sent to a permitted recycler and taken apart. In EPA's words, virtually all parts "can be separated and recycled," from metal end caps to phosphor powder. Recovered mercury goes into new lamps, metal is sold as scrap, and glass is remanufactured.

What does a certificate of recycling show?

Typically, the recycler's certification of the total weight received on a date. J.J. Keller calls it a recommended practice, not a federal mandate. EPA's lamp program guide lists keeping certificates, and ALMR notes one can be passed along to the building owner. You get one for every job.

Does a utility rebate need proof of disposal?

Some programs do, so read your terms. Eugene's EWEB wants a Lighting Waste Disposal Certificate within two months of project completion. Columbia, Missouri asks for proof of proper disposal of universal waste lamps and ballasts. Concord, Massachusetts requires a completed disposal form before it pays.

How can I track my recycling progress?

By weight, which is how Portfolio Manager and GRESB both count waste. ENERGY STAR Portfolio Manager tracks "Lamps/Light Bulbs" and "Batteries" as separate material types. GRESB reports waste by weight at the asset level. LEED v4 operations policy asks for safe storage and disposal of batteries and lamps.

How much does fluorescent tube disposal cost?

It depends on volume, lamp type and how the lamps travel, so we reply with a written quote. Public contracts price straight tubes per foot, other lamps each, and ballasts and batteries per pound, often with a minimum charge. Our pricing page shows sourced public benchmarks.

Is mail-back cheaper than pickup?

For a small batch, often yes, because pickups can carry a minimum charge. At volume it flips: Missouri's state lamp guidance calls prepaid mail-back significantly more expensive than pallet-load pickup. NEMA once put transport at 25 to 50 percent of total cost where segregated transport is required.

Sources: EPA lithium-ion battery pages. 40 CFR 273; 49 CFR 173.164 and 173.185. PHMSA interpretation 130011, 2013. USPS lamp bulletins, 2013 and 2014. Seller listings, 2026. J.J. Keller. ALMR. EWEB, Columbia MO and Concord MA program terms. ENERGY STAR. GRESB 2026. LEEDuser. Missouri contracts and guidance. EPA 1997 economic analysis.

Still have a question about your load?

Send rough counts and the question with them. We reply with a written quote and a plan for pickup or mail-back.