TL;DR: An EPA identification number (EPA ID number) is a unique 12-character code assigned to a specific site that generates, transports, or manages hazardous waste under RCRA Subtitle C. You apply using EPA Form 8700-12 (the “Site Identification Form,” formally titled the Notification of RCRA Subtitle C Activities), submitted to your authorized state environmental agency or, in states without an authorized program, the EPA regional office. There is no federal application fee. Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) must obtain one before they can ship hazardous waste off-site; a permitted disposal vendor cannot legally accept a shipment, or sign a hazardous waste manifest, from a site that doesn’t have one. Very Small Quantity Generators (VSQGs) are generally exempt at the federal level, but several states require an ID number regardless of generator category.
What Is an EPA ID Number?
An EPA ID number (also called a hazardous waste generator identification number, hazardous waste generator ID, or hazardous waste generator number) is a site-specific identifier issued under the Resource Conservation and Recovery Act (RCRA) Subtitle C hazardous waste program. It is tied to a physical location, not to a company or a person — a research institution with hazardous-waste-generating activity at three separate buildings or campuses may need a separate ID number for each address, depending on how the state defines a “site.”
The number itself is used to identify the generator on every hazardous waste manifest, in EPA’s e-Manifest system, and in any biennial or annual hazardous waste reporting the generator’s category requires. Without it, a waste stream has no way to be tracked from the point of generation to final disposal — which is the entire point of the manifest system under 40 CFR Part 262.
Who Actually Needs One
- Large Quantity Generators (LQG) — generate ≥1,000 kg/month of hazardous waste (or >1 kg/month of acutely hazardous, P-listed waste) — must obtain an EPA ID number.
- Small Quantity Generators (SQG) — generate >100 kg but <1,000 kg/month — must also obtain one.
- Very Small Quantity Generators (VSQG) — generate ≤100 kg/month — are not required by federal EPA regulation to obtain an ID number or file a notification form, though several states impose their own, stricter requirement regardless of generator status. Even where it isn’t legally required, many commercial disposal vendors and university EH&S offices require an ID number as a condition of service, since it’s the only identifier their own reporting systems recognize.
- Transporters and treatment, storage, and disposal facilities (TSDFs) are separately required to hold their own EPA ID numbers.
See our lab waste disposal guide for the full generator-status thresholds (VSQG/SQG/LQG), accumulation time limits, and satellite accumulation area rules that determine which category a lab falls into.
Why a Disposal Vendor Asks for This Before Anything Else
For a lab or research facility going through vendor onboarding for hazardous waste disposal, the EPA ID number is typically the first document a vendor requests — before a service agreement, before a waste profile, before a pickup is scheduled. That’s because the vendor is legally exposed if it accepts regulated waste from an unregistered generator: the hazardous waste manifest that accompanies every shipment requires the generator’s EPA ID number in the generator block, and a TSDF or transporter cannot lawfully complete that manifest without it. A lab that hasn’t applied yet will stall its own vendor onboarding at the first step, regardless of how ready the rest of its waste program is.
How to Apply: EPA Form 8700-12
The application itself is EPA Form 8700-12, the Site Identification Form (formally, the Notification of RCRA Subtitle C Activities). It collects the facility’s name and physical address, mailing address, contact information, NAICS code, and a description of the specific hazardous waste activities conducted at the site (generation, treatment, storage, disposal, transportation, or a combination).
- Confirm who administers the program in your state. Most states are authorized by EPA to run their own RCRA Subtitle C program, so the completed form goes to your state environmental agency, not directly to EPA. In the small number of states/territories without an authorized program, it goes to the applicable EPA regional office instead.
- Complete Form 8700-12. Some states have opted in to electronic submission through EPA’s myRCRAid system, which allows the Site ID Form to be filed online rather than on paper; check with your state agency to confirm whether electronic filing is available and, if so, use it — it’s typically faster to process than a mailed paper form.
- Submit it to the correct state agency or EPA region. If your state doesn’t support electronic filing, the form is mailed or otherwise submitted directly to that state’s hazardous waste program office.
- Receive your EPA ID number. EPA’s published guidance does not specify a fixed federal processing timeline or fee, and both vary by state — contact your state hazardous waste program directly for current turnaround expectations before you commit to a disposal date with a vendor.
Keep a copy of the completed Site ID Form and the confirmation of your assigned number in your facility’s waste management files — vendors and inspectors will ask for it again.
Federal vs. State-Administered Programs
RCRA Subtitle C is a federal statute, but EPA authorizes individual states to administer their own hazardous waste programs in lieu of the federal one, provided the state program is at least as stringent. Because of this, the specific application process, whether electronic filing is offered, and whether a VSQG must register at all can differ meaningfully from state to state. Always confirm current requirements with your specific state’s environmental or hazardous waste agency rather than assuming the federal minimum is what applies locally.
Do Very Small Quantity Generators (VSQGs) Need One?
Not under federal RCRA rules by default. A site that stays at or below the VSQG threshold (≤100 kg/month of hazardous waste) is not required by federal EPA regulation to obtain an EPA ID number or submit a notification form. In practice, a VSQG lab should still check two things before assuming it can skip this step: (1) whether its state imposes a stricter, state-specific registration requirement regardless of generator category — several do — and (2) whether its intended disposal vendor requires an ID number as a condition of accepting waste, independent of what the federal minimum requires. A VSQG that occasionally generates enough waste to trigger a higher category in a given month (an “episodic generator,” under EPA’s generator improvements rule) may also need to apply at that point.
What Happens After You Have Your Number
Once assigned, the EPA ID number becomes part of the facility’s permanent regulatory record for hazardous waste. It is used on every hazardous waste manifest the site generates, in EPA’s e-Manifest system, and in any periodic (biennial, for LQGs; some states require annual) hazardous waste reports the generator’s category is subject to. It does not expire, and it stays with the physical site even if the operating entity or facility name changes — though a change in ownership, name, or address should still be reported to the issuing state agency to keep the record accurate.
Frequently Asked Questions
How long does it take to get an EPA ID number?
EPA does not publish a fixed federal processing time, and it varies by state. States with electronic submission through myRCRAid generally process applications faster than paper submissions. Contact your state hazardous waste program directly for a current estimate before scheduling a first pickup with a disposal vendor.
Is there a fee to apply for an EPA ID number?
There is no federal application fee for Form 8700-12. Some states charge their own hazardous waste program fees separately from the ID number application itself — check your state agency’s fee schedule.
Does every hazardous waste generator need an EPA ID number?
Large Quantity Generators and Small Quantity Generators must obtain one. Very Small Quantity Generators are not required to at the federal level, but many states require it anyway, and many disposal vendors require it as a condition of service regardless of legal minimum.
Can I apply for an EPA ID number online?
In states that have opted in to EPA’s myRCRAid electronic reporting system, yes — the Site ID Form (8700-12) can be filed electronically. Where a state hasn’t opted in, the form is submitted on paper to the state agency or EPA regional office.
What’s the difference between an EPA ID number and a hazardous waste manifest?
The EPA ID number identifies the site as a registered generator (or transporter, or TSDF); the hazardous waste manifest is the shipment-tracking document used every time waste actually moves off-site, and it requires the generator’s EPA ID number to be valid. You need the ID number before you can ever complete a manifest.
