A lamp recycling program for every building you manage.

A facility lamp recycling program needs closed, labeled containers at each site, storage under one year, and records you can roll up. We collect fluorescent, CFL and HID lamps, ballasts and batteries by scheduled pickup or a mail-back box.

No obligation. We reply by email with a written quote.

  • Fluorescent, CFL and HID
  • Ballasts and batteries
  • Pickup or mail-back
  • A record for every job
Example layout, not real data

One storage clock per site, one view for the portfolio.

Each building that holds spent lamps runs its own one-year clock under 40 CFR 273.15. This illustrative card shows how a portfolio view can keep every clock in sight.

Example portfolioillustrative, as of 2026-10-01
Example site A, retail centerOldest lamp container dated 2025-11-12
Day 323Ship soon
Example site B, garden apartmentsLamps and batteries, dated 2025-12-20
Day 285Ship soon
Example site C, office towerOldest lamp container dated 2026-02-10
Day 233On the clock
Example site D, medical officeOldest lamp container dated 2026-04-01
Day 183On the clock
Example site E, warehouseOldest lamp container dated 2026-06-15
Day 108On the clock
Example site F, community centerPicked up 2026-09-15; new container started
Day 16Record filed

Example layout, not real data. Each site's day count runs from the date on its oldest container against the one-year storage limit in 40 CFR 273.15.

How to read the example: "Ship soon" flags a site past nine months, a threshold you set for yourself. "On the clock" means the oldest container is younger than that. "Record filed" means the last pickup closed with a certificate of recycling and a new container has started.

Handler status

The 5,000 kg line, read site by site.

A site holding less than 5,000 kg of universal waste is a small quantity handler. A busy campus or a long-neglected storage room can cross that line, and the duties change with it. The clock and the count both start at the site.

The clock starts at discard

"A used lamp becomes a waste on the date it is discarded". A lamp pulled from a fixture and set aside for recycling starts its one-year clock that day.

40 CFR 273.5, 273.15
Proof of the date

Each site must be able to show how long its lamps have been stored. A date on the container, an inventory system, or a marked storage area can do it.

40 CFR 273.15
All universal waste counts

The federal limit is 5,000 kg held "at any time", counted across lamps, batteries, pesticides, mercury equipment and aerosol cans together. Spent batteries count toward the same total as lamps.

40 CFR 273.9
Applied location by location

The federal text does not say "per site", but state guidance applies it location by location. New Jersey counts waste "accumulated at the collection site". Florida counts what handlers hold "at their locations at any time".

NJ and FL guidance
Before you cross it

A site expecting to reach 5,000 kg must notify EPA and get an EPA ID number first. Large quantity handler status then lasts through the end of the calendar year.

40 CFR 273.32, 273.9
Shipment records

Large quantity handlers keep a record of each shipment for three years. A log, invoice, manifest or bill of lading can serve as that record.

40 CFR 273.39
Staff told the procedure

Even small handlers must inform employees of "proper handling and emergency procedures". That includes whoever changes lamps on site.

40 CFR 273.16
Owner stays responsible

ALMR's message to owners says "regulatory compliance remains the responsibility of the owner of the lamps". Hiring a vendor does not move that duty.

ALMR, message for owners

Sources: 40 CFR Part 273, via Cornell LII; New Jersey and Florida state guidance; ALMR. Federal rules shown. States can be stricter. Not legal advice.

Reporting

Lamp records that feed the reports you already file.

Sustainability reporting asks for waste by weight and by asset. A record for every job, filed by site, gives each building the numbers those frameworks ask for.

ENERGY STAR

Portfolio Manager waste

Portfolio Manager tracks 29 waste and material types, including "Lamps/Light Bulbs" and "Batteries", each as recycled or disposed. Amounts are entered by weight.

LEED v4 BD+C

Storage and collection

One MR prerequisite covers "a minimum of two of the following three waste streams: batteries, mercury-containing lamps, and electronic waste". It is titled Storage and Collection of Recyclables.

LEED v4 O+M

Purchasing and waste policy

MRp1 includes "Establish safe storage areas for batteries and mercury-containing lamps". The same policy prerequisite also lists "Safe disposal of batteries and lamps".

GRESB

Reported by weight

GRESB 2026 collects hazardous and non-hazardous waste by weight, at the asset level. Per-site weights from each job's record support that reporting.

EPA program guide

Keep the certificates

EPA's 10-step lamp program guide includes "Track Documentation: maintain Certificates of Recycling". A certificate of recycling for every job builds that file site by site.

Certificates

What a certificate shows

J.J. Keller describes it as the "recycler's certification of, typically, the total weight" received on a date. It is recommended practice, not a federal mandate.

Sources: ENERGY STAR Portfolio Manager waste and materials guidance. LEED v4 prerequisites as summarized by LEEDuser, a secondary source. GRESB 2026 reference material. EPA lamp recycling program guide. J.J. Keller.

Program setup

Five steps to a portfolio lamp program.

The same routine works for two buildings or forty. What changes from site to site is volume, and volume decides pickup or mail-back.

  1. List every site

    Note each address, its rough lamp count, who changes lamps there, and whether ballasts or batteries come out too.

  2. Set one storage spot

    Closed containers that prevent breakage, labeled "Used Lamp(s)" or "Waste Lamp(s)", dated when the first lamp goes in.

  3. Name who changes lamps

    Staff, vendors and tenant contractors follow one rule: whole lamps go to the labeled container.

  4. Match service to volume

    Busy sites get scheduled pickup on a recurring route. Small ones use a mail-back box. Both feed the same record.

  5. Roll up the records

    A recycling record for every job, filed by site and by stream, ready for your annual reporting.

Who changes lamps

Three crews, one rule.

In many portfolios, lamps get changed by in-house maintenance, an outside vendor and tenant contractors. Each one can leave spent tubes in a closet, a dumpster or a truck bed, and each one starts a clock.

Write one rule into vendor and tenant contracts: spent lamps go whole to the site's labeled container. Then tell staff the handling and emergency procedures, as 273.16 asks.

Read the compliance guide
Small sites

A box instead of a truck.

A building that fills a few dozen tubes a year rarely needs a scheduled pickup. A mail-back box can sit in the storage room until it is full, then ship from the front desk.

The one-year clock still runs. USPS lamp program bulletins say to write the accumulation start date on the box and to ship intact lamps only.

How mail-back boxes work
Portfolio questions

What property and facility managers ask.

Short answers for running lamps across a portfolio. Rules are federal unless a state is named.

What is mail in lamp recycling?

It is a recycling box you fill on site and ship back, with no truck visit. It suits buildings with small, steady volumes. USPS lamp bulletins call for intact lamps only, a start date on the box, and recycling within one year. PCB ballasts stay out of lamp kits.

How are my spent lamps regulated?

Federally, businesses typically manage them as universal waste under 40 CFR Part 273. A used lamp becomes waste on the date it is discarded (273.5). From then it needs a closed, labeled container and can be stored no longer than one year. Several states also ban landfilling lamps.

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

In some states, yes. Six states, California and Minnesota among them, ban landfilling even household lamps. Federally, very small quantity generators may choose to manage lamps under Part 273 (40 CFR 273.8). If those lamps are mixed with regulated universal waste, all of it is regulated.

How do I set up a program for my facility?

Start with a site list and rough counts. Set one storage spot per building with closed, labeled, dated containers. Decide who changes lamps and put the rule in vendor contracts. Then choose pickup or mail-back by volume. Our compliance guide covers each federal duty in detail.

How do I know if bulk pickups are right for me?

Volume decides it. Missouri's state lamp guidance calls the prepaid service used for small shipments significantly more expensive than pallet-load service. Sites that fill pallets usually fit scheduled pickup, and sites with a few boxes a year suit mail-back. See how pricing works for the units used.

How can I track my recycling progress?

Use the record from each job. A certificate of recycling typically states the total weight received on a date. Enter those weights by site in ENERGY STAR Portfolio Manager under "Lamps/Light Bulbs" or "Batteries", as recycled. Summed across sites, they show progress from one year to the next.

Do batteries count toward the 5,000 kg limit?

Yes. The federal threshold in 40 CFR 273.9 counts all universal waste held at any time. That means lamps, batteries, pesticides, mercury-containing equipment and aerosol cans combined. A site storing batteries next to its lamps adds both together. Our battery recycling page covers packing by chemistry.

Who should keep the lamp recycling records?

The owner, site by site. ALMR's message to owners says "regulatory compliance remains the responsibility of the owner of the lamps". Large quantity handlers must keep shipment records for three years under 40 CFR 273.39. Filing every site the same way keeps any later review simple.

How often should lamps be picked up?

Often enough that no container at any site passes one year in storage, the federal limit in 40 CFR 273.15. Busy sites may need several pickups a year, and quiet ones a single visit. Setting a recurring schedule by site volume keeps every clock inside that window.

Can ballasts and batteries go in the same pickup?

Yes. We collect fluorescent, CFL and HID lamps, ballasts and batteries, so one scheduled pickup can clear all three streams from a site. Keep each stream in its own container. We keep pre-1979 and unlabeled ballasts apart from the rest of the load, because they may contain PCBs.

Can tenants put spent lamps in the building dumpster?

Usually not. Business lamps are typically universal waste, and California, Minnesota, Washington, Maine, Massachusetts and Vermont ban landfilling lamps even from households. Write the rule into tenant and vendor contracts: spent lamps go whole to the site's labeled container. The owner remains responsible, according to ALMR.

What do we do when a lamp breaks in a tenant space?

Clean it up right away and seal the pieces 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". Releases must be contained under 273.17. EPA's own cleanup page is written for homes, so follow your site procedure.

Put every building on one routine.

Send a site list with rough counts per building. We reply with a written quote for pickup, mail-back, or a mix of both.