Wisconsin Hazardous Waste Annual Report

Wisconsin's hazardous waste regulations require several types of hazardous waste generators to report to the Department of Natural Resources every year on regulated waste activities. The report, which covers activity during the previous calendar year, is completed and submitted through the RCRAInfo Industry Application online reporting system and is due March 1.

The DNR uses annual report data for planning, fee assessment, compliance monitoring and enforcement efforts. Additionally, this data is required to be submitted to the U.S. Environmental Protection Agency for odd-numbered report years to be used for evaluation and planning, developing regulations, compliance monitoring and enforcement. Annual reports also satisfy the re-notification requirements for small and large quantity generators.

Who Must Submit A Hazardous Waste Report

A facility must submit an annual report if, during the report year, the facility did any of the following:

• Generated in any calendar month:
  • more than 100 kilograms (220 pounds) of hazardous waste;
  • more than 1 kilogram (2.2 pounds) of acute hazardous waste; or
  • more than 100 kilograms (220 pounds) of acute hazardous waste spill cleanup material.
• Accumulated at any time:
  • more than 1,000 kilograms (2,205 pounds) of hazardous waste;
  • more than 1 kilogram (2.2 pounds) of acute hazardous waste; or
  • more than 100 kilograms (220 pounds) of acute hazardous waste spill cleanup material that was generated onsite.
• Was a publicly owned (wastewater) treatment works that accepted hazardous waste (via truck, rail or dedicated pipe) for treatment and complied with s. NR 670.001(3)(b)9, Wis. Adm. Code.
• Performed any other hazardous waste treatment, storage or disposal activities onsite that required a hazardous waste facility license.
• Chose to operate under a higher generator category than it previously had (i.e., small quantity generator to large quantity generator or very small quantity generator to small quantity generator or to large quantity generator).

The DNR reviews facility generator status information and manifest data to identify and alert sites that appear to meet one or more criteria for hazardous waste annual reporting. For any facility that appears to require a report:

• An “Awaiting Submission” notice will be visible in the report module within RCRAInfo.
• Site contacts will typically receive an email with reporting instructions once the report opens in January.

If a facility is required to report but for some reason does not receive notice from the DNR, or if the facility is electing to report, the facility representative should submit a hazardous waste report in the report module without prior approval or notice from the DNR. It is the facility’s responsibility to ensure it meets all reporting requirements.

Episodic generation and reporting

A very small quantity generator (VSQG) that properly notified the DNR of an episodic hazardous waste generation event, and satisfied all requirements related to the event, is not required to complete an annual report unless the VSQG has engaged in other hazardous waste activities that require an annual report to be completed. If the VSQG does not have to submit an annual report, no base fees or tonnage fees are associated with the VSQG, even if it experienced an episodic generation event.

A small quantity generator (SQG) must complete an annual report. An episodic hazardous waste generation event does not require an SQG to report as a large quantity generator (LQG). However, the SQG will need to pay the SQG base fee and tonnage fee for all the hazardous waste it generated, including the episodic hazardous waste, during the reporting year.

• Episodic Generation of Hazardous Waste Guidance (WA-1872)

Report Instructions

Report Instructions

Beginning with the 2025 report year, the platform for submitting annual reports will be through the Federal RCRAInfo Industry Application (or RIA). Reporters will be responsible for:

• Creating a RCRAInfo Industry Account,
• Obtaining permission to submit a report, and
• Following instructions outlined on this webpage to complete the report by the March 1 deadline.

This may require you, your report preparer, or your facility's report certifier to take additional steps in preparation for completing the 2025 hazardous waste annual report. To avoid delays in meeting the March 1 deadline, it is important to review the information below and take the necessary actions.

Reporters may continue to use their DNR Switchboard accounts to download copies of submitted hazardous waste reports from report years 2019-2024 but will not be able to submit new reports or revise previous reports through the Switchboard portal. If you need to complete or correct a report from 2024 or earlier, please contact your regional licensing, reporting and compliance specialist.

Creating Your RCRAInfo User Account

To complete a hazardous waste annual report in RCRAInfo, you'll need to create a RCRAInfo Industry User Account. If you already have a RCRAInfo account you will not need to create a new account to complete reports, but you may have to revise your permission level to be able to prepare or submit annual reports.

To create an account:

1. For optimum functionality, use Google Chrome. If you attempt to use an incompatible browser, you'll receive a warning message.
2. Navigate to https://rcrainfo.epa.gov/rcrainfoprod/action/secured/login
3. Click "Register."
4. Select "Industry User."
5. Provide a Username and Email.
6. You will be directed to create a Login.Gov account.
7. Follow all instructions to create an account. Once finished, you will be redirected to RCRAInfo to complete your registration.
8. In RCRAInfo, provide all fields with a red asterisk.
9. Your account has been created and your registration is complete. Follow instructions to request permissions.

Tutorials are available on the RCRAInfo account creation process.

Understanding User Account Roles/Permissions

The RCRAInfo Industry Application (RIA) enables individual users to tailor their account to access each site they work for or represent with a permission level that matches the role they have for that site. The RIA contains modules with different functions, and an individual can determine the permission level they need for each individual module. An individual must request permission for each site for which they are associated and select the permission level for each module for that site.

Permissions Levels

• None: No access to the module
• Viewer: View data
• Preparer: Edit and save data
• Certifier: Edit, sign and submit data
• Site Manager: Automatically has the highest permission level for all modules and additional capabilities

Requesting Permission for the Report Modules

To sign and submit a hazardous waste report, you must either have the Certifier permission for the annual and biennial report modules or be the Site Manager. If you need to change your current permission levels, see Modifying Permission Level below.

1. Log in to https://rcrainfo.epa.gov/rcrainfoprod/action/secured/login. Remember to use Google Chrome.
2. On the My Sites tab, hit the "Select Existing Site" button.
3. Enter your site's EPA ID number and click "Search."
4. Check the box next to your site and hit "Request Access."
5. Select your permission level for BOTH the Annual and Biennial Report Modules. Selecting "Active" for Site Manager gives you the highest level of permissions for all modules.
6. Hit "Send Request."
7. Your request will be sent either to any existing RCRAInfo Site Managers for your site or to DNR Waste Program Staff. You'll get an email when your request has been approved.

If you request Site Manager or Certifier permission, you may be prompted to complete the Electronic Signature Agreement (ESA) the next time you log on. Follow the steps to electronically verify your identity.

If you don't qualify for electronic identity verification, or if you elect not to do electronic identity verification, you must print, sign and mail the report. You won't be able to submit any forms until your ESA is complete.

Modifying Permission Level

If you already have access to a site but need to revise your permission level, follow these instructions:

1. Log in to RCRAInfo. Remember to use Google Chrome.
2. Click on your name in the upper right-hand corner. This opens your profile information.
3. Click on the "My Site Permissions" tab.
4. Click the checkbox next to all sites that you want to change your permission level on.
5. Click on the “Modify Permissions for Selected Site” button.
6. Selecting "Active" for Site Manager gives you the highest level of permissions for all modules (e-manifest, myRCRAid and WEITS).
7. Hit "Send Request."
8. If your site already has a Site Manager, they can approve your request. If your site doesn't have a Site Manager already, your request is reviewed by DNR Waste Program Staff. You will get an email when your request has been approved.

Step-By-Step Instructions for Completing an Odd-Year Report

To complete a report in odd-numbered years (also known as Biennial Report or BR years), to be submitted to the DNR at the start of the following year:

1. Log in to RCRAInfo. Remember to use Google Chrome.
2. Click on the "My Sites" tab.
3. Click the "Site Name" (it will be a blue hyperlink).
4. Click on the "Biennial Report" tab. If you do not see these tabs, you do not have permission to access these modules. See Modifying Permission Level above.
5. Click on the green "Create New Submission" button. You will be given three options on how to proceed with creating a report:
   1. “Upload a File” allows you to upload a flat file instead of using data entry screens. See "Submitting Data by Data Upload" section below.
   2. “Continue to Data Entry” will begin a report that will be completed by entering data into data entry screens.
   3. If this site was a small or very small quantity generator for the entire report year, you can choose the “click here” option to complete only the required notification form. DO NOT CHOOSE THIS OPTION IF THIS SITE IS A TSDF OR LQG. You will be directed to complete a notification form and fee/exemption form.
6. If this site must complete a GM form, click "Add GM form." See GM tab on this webpage for more information.
7. If this site must complete a WR form, click "Add WR form." See WR tab on this webpage for more instructions.
8. All reporters must complete the Site ID form. Click on the "Add Site ID" form button. The form will prefill with information from the most recently approved notification form on file. All fields with a red asterisk are required. See the "Site ID form" tab on this webpage for more instructions.
9. Once the report is complete, an individual with Site Manager or Report Certifier permission can electronically sign and submit the report.
10. You may receive "validation" messages. These are prompts that alert you to potential issues with your report. You will need to either make a correction or provide an explanation before you can submit the report.
11. Once you've electronically submitted the report, your report will be reviewed and accepted by DNR staff. You may be contacted for more information or to make corrections before or after acceptance.

There is no requirement to mail a copy of the report to the DNR.

Step-By-Step Instructions for Completing an Even-Year Report

To complete a report in even-numbered years (also known as AR or annual report), to be submitted to the DNR at the start of the following year:

1. Log in to RCRAInfo. Remember to use Google Chrome.
2. Click on the "My Sites" tab.
3. Click the "Site Name" (it will be a blue hyperlink)
4. Click on the "Annual Report" tab. If you do not see these tabs, you do not have permission to access these modules. See "Modifying Permission Level" above.
5. Click on the green "Create New Submission" button. You will be given two options on how to proceed with creating a report:
   1. “Upload a File” allows you to upload a flat file instead of using data entry screens. See Submitting Data by Data Upload section below.
   2. “Continue to Data Entry” will begin a report that will be completed by entering data into data entry screens.
6. If this site must complete a GM form, click "Add GM form." See GM tab on this webpage for more information.
7. If this site must complete a WR form, click "Add WR form." See WR tab on this webpage for more instructions.
8. All reporters must complete the Site ID Form. Click on the "Add Site ID form" button. The form will prefill with information from the most recently approved notification form on file. All fields with a red asterisk are required. See the "Site ID form" tab on this webpage for more instructions.
9. Once the report is complete, an individual with Site Manager or Report Certifier permission can electronically sign and submit the report.
10. You may receive "validation" messages. These are prompts that alert you to potential issues with your report. You will need to either make a correction or provide an explanation before you can submit the report.
11. Once you've electronically submitted the report, your report will be reviewed and accepted by DNR staff. You may be contacted for more information or to make corrections before or after acceptance.

There is no requirement to mail a copy of the report to the DNR.

Submitting Data by Data Upload

Facilities may choose to upload GM and/or WR data directly into the RCRAInfo Report module via flat file. This option is most appropriate for facilities that have 50 or more GM and/or WR forms, are familiar with RCRA Subtitle C Reporting and Instructions Forms, and that understand basic computer concepts and terminology. The Site ID Notification cannot be uploaded via flat file and must be completed within the Report module. Complete instructions and file specifications for the 2025 Biennial Report Year are available here: 2025 BR File Specifications Guide.

Certifying Hazardous Waste Report Information

Digitally Signing and Submitting the Report

The report must be digitally signed by the owner/operator or authorized representative of the site. Per 40 CFR 260.10, an “authorized representative” is a person responsible for the overall operation of the site or an operational unit (i.e., a plant manager or superintendent, or a person of equivalent responsibility).

An individual must either be a Site Manager or have the certifier permission level to submit the report electronically. Users with the preparer permission level can prepare the report and notify the reviewer or certifier when the report is ready for the final review and signature. There is no longer a multi-step signature process or an option to sign a paper signature page.

Environmental Consultants

Some companies have consultants that prepare their annual report submittals. If a company also wishes to delegate the responsibility of submitting and certifying the report to an environmental consultant that company must delegate this authority - the DNR cannot make this delegation.

To delegate this authority, the company employee with a Site Manager role within RCRAInfo must grant either Site Manager or Certifier permission to the consultant. Note that the facility retains the responsibility for providing accurate and timely information.

Note, licensed hazardous waste treatment, storage and disposal facilities are not allowed to delegate submittal and certification authorities to outside consultants.

Additional Resources

• North American Industry Classification System (NAICS)
• Toxics Release Inventory (TRI) reporting
• EPA Biennial Hazardous Waste Report
• RCRAInfo’s Hazardous Waste Information Platform (HWIP)

Site ID Notification Form

The Site ID Form is required every reporting year. It is the equivalent of a RCRA Subtitle C (8700-12) Form, also known as a "notification" or a "myRCRAid notification."

• The Site ID Form is used to collect information about the hazardous waste activities associated with the facility and information about the facility's name, owner, operator and contacts.
• Completing a Site ID form as a component of the hazardous waste report and submitting the report by March 1 will satisfy SQG and LQG re-notification requirements under s. NR 662.018(4), Wis. Adm. Code.

Updating Facility and Contact Information in the Report

The Site ID Form will pre-fill with current facility data found in RCRAInfo. You can update your facility's name, owner, operator, primary contact and other information, directly in the Site ID Form.

Reporting the Generator Category

On the Site ID Form, there are two sections asking about generator category. One is Question 10.A.1 (in the middle of the form) and the other is within the Wisconsin State Addendum (near the bottom of the form). Please see the Wisconsin State Addendum tab for more instructions on answering the “Reporting Year Generator Category” question.

On Question 10.A.1, indicate the facility's current generator category at the time of completing the Site ID Form. This may be the same as the generator category for the report year, or it may indicate that your generator status has changed. You must provide both the Federal and State generator category. In Wisconsin, generator categories are equivalent to federal generator categories and so the Federal and State generator category shall match.

Once your report has been accepted by the DNR, your facility's generator category will be updated in state and federal databases to the generator category you reported on question 10.A.1 of the Site ID Form.

For example: If your facility was an SQG in the report year but is now a VSQG during the year you are submitting the report, you shall indicate "VSQG" as the generator category on 10.A.1 of the Site ID Form.

Fee or Exemption Form

Wisconsin State Addendum

The Wisconsin State Addendum is a component of the Site ID Notification Form. It collects additional information about the facility and will also include either a Fee Worksheet or an exemption justification.

Reporting Year Generator Category

The Reporting Year Generator Category is where a facility reports the highest attained generator category in the report year. This determines whether a facility must complete a fee worksheet or answer the exemption question and whether GM forms may be required. When reporting as a:

• Large Quantity Generator
  • You will be directed to complete a Fee Worksheet. On odd-numbered report years, you must also provide GM form(s).
• Small Quantity Generator
  • You will be directed to complete a Fee Worksheet. You do not need to complete GM forms.
• Very Small Quantity Generator or “Not a Generator”
  • You will be directed to answer an exemption question. A facility that is categorized in the federal and state database as operating at a small or large quantity generator would typically receive a notice that they need to report. If you were not generating hazardous waste at those levels during the report year, you will answer the exemption question.

Fee Worksheet

The fee worksheet is required every report year, for facilities that do not file “exempt” from reporting requirements. The form includes a calculation of the fee owed, but you will not pay the fee at the time of report submittal. You do not need to pay the fee until you receive an environmental fee statement from the DNR in May. That statement will include the hazardous waste generator fee and other DNR environmental fees you may owe.

Annual fees are calculated based on activity, generator category and the amount of hazardous waste generated during the reporting year. For generators, fees are as follows:

• The base fee is $470 for a large quantity generator (LQG).
• The base fee is $350 for a small quantity generator (SQG).
• The tonnage fee portion is $20 per ton, with some exemptions.

The maximum total hazardous waste generator fee that may be assessed is $17,500 per year, regardless of the amount of hazardous waste generated.

Wastes exempt from tonnage fees include the following:

• Waste recovered for recycling or reuse (including hazardous wastes burned for the purpose of energy recovery).
• Hazardous waste leachate that was transported to a wastewater treatment plant or discharged directly to a domestic sewer pipe.
• Hazardous waste removed from a site to repair environmental pollution (soil or groundwater remediation).
• Hazardous waste collected by a municipality under its household hazardous waste collection program or by a county under its agricultural chemical waste collection program.

Even though certain hazardous wastes are exempt from the tonnage fee, they must still be reported on the Fee Worksheet as hazardous waste generated and tonnage fee exempted. For more information, see ss. 289.67(2)(a) through (e), Wis. Stats.

Reporting Exemption

If you received a notice to complete the hazardous waste annual report and your facility did not fit any of the reporting requirements during the report year, you will be directed to answer the exemption question. Choose the reason for not generating and provide any relevant comments.

Reasons for not generating may include:

• Hazardous waste minimization activities changed the facility's generator category.
• The facility only generated hazardous waste that is excluded or has been delisted by the EPA.
• For the reporting year, the facility was a very small quantity generator.
• Other reasons not listed above. You will be required to justify in comments.

DNR regional staff will review your exemption explanation and compare it with additional known information about the facility, including manifest records. You may be contacted to provide additional information.

Waste Generation and Management (GM) Forms

GM forms are required from large quantity generators on odd-year reports (i.e., for activity conducted in 2023, 2025, etc.), and every year from licensed hazardous waste treatment, storage or disposal facilities.

The GM form records the following information:

• The source, characteristics and quantity of hazardous waste generated on-site.
• Waste minimization activities and results, for each type of waste generated on-site.
• The quantity of hazardous waste managed on-site and the on-site management methods.
• The quantity of hazardous waste shipped off-site and the off-site management methods.

GM Form Instructions

Detailed instructions for completing a GM form, including examples and descriptions of available codes, can be found in the RCRA Subtitle C Reporting Instructions and Forms document.

Waste That Must Be Reported on the GM Form

Each type of hazardous waste generated on-site must be reported, including those generated from production processes and the treatment of non-hazardous waste, and hazardous waste residuals generated from the management of a hazardous waste.

A separate and independent GM form must be submitted for each type of hazardous waste generated at the facility, including hazardous waste that was:

• Generated on-site from production processes or service activities.
• Generated as the result of a spill cleanup, equipment decommissioning or other remedial cleanup activity.
• Generated from the management of a non-hazardous waste type.
• Shipped off-site; received from off-site and not recycled, blended or otherwise treated on-site.
• Residuals generated from the on-site treatment, disposal or recycling of hazardous waste.
• Removed from on-site storage for treating, recycling or disposal on-site or shipment off-site.
• Imported from a foreign country during the report year.

Wastes That Do Not Need to be Reported on a GM Form

The following wastes should NOT be reported on a GM form:

• Materials that are excluded from being a solid waste.
• Solid wastes that are excluded from being hazardous waste.
• Waste exempt from regulation because it has not exited the raw material storage or production unit yet.
• Hazardous waste that is a specified recyclable material.
• Hazardous waste exported directly to a foreign country.
• Hazardous waste that has been collected as a sample(s) for the purpose of determining its characteristics or composition.
• Waste sample(s) undergoing treatability studies.
• A residue of hazardous waste in an empty container or in an inner liner removed from an empty container.
• Any PCB waste regulated under the Toxic Substance Control Act.
• Wastes managed immediately upon generation only in on-site elementary neutralization units, wastewater treatment units or totally enclosed treatment facilities. Note: Any hazardous waste residues generated from these units, however, must be reported on GM section.
• Wastes recycled, without prior storage, only in an on-site process subject to regulation.
• Used oil that is recycled.
• Spent lead-acid batteries. Note: Any hazardous waste generated during battery reclamation, must be reported on GM section.
• Wastes managed as part of an episodic event in compliance with the conditions of Wis. Admin. Code NR 662.232, Subchapter L.
• Hazardous waste pharmaceuticals when managed in accordance with Subchapter P, NR 666, Wis. Adm. Code.
• Hazardous waste pharmaceuticals that are controlled substances, managed under Drug Enforcement Administration (DEA) requirements of s. NR 666.506, Wis. Adm. Code.
• Universal hazardous wastes.

See ss. NR 661.0004, NR 661.0007, NR 661.0008 and NR 661.0009, Wis. Adm. Code, for more information.

For more information and examples, see Biennial Report Reportable and Non-Reportable Wastes.

Waste Received From Off-Site (WR) Section

The WR Form identifies hazardous wastes that were received from other hazardous waste sites and the method(s) used to manage them. The 2016 Hazardous Waste Generator Improvements Final Rule requires facilities that receive and recycle regulated hazardous wastes, without first storing, to complete a WR form for each type of hazardous waste they receive.

A WR form is required from any facility that is required to complete the biennial report and that received hazardous waste from off-site during the report year. It may include a facility that is a:

• Commercial TSD facility.
• Non-commercial TSD facility that receives hazardous waste only from generators owned/controlled by the TSD facility.
• Central wastewater treatment facility treating hazardous wastewaters (who do not have a TSD license, because all hazardous wastes treated are not stored before treatment).
• Hazardous waste recycler that does not have a TSD license (because all hazardous waste are only treated and not stored before treatment).
• LQG receiving hazardous waste from VSQGs that are under the same ownership.

A separate WR form must be filed for each hazardous waste received from each off-site handler. Hazardous waste from the same off-site handler may be aggregated so long as a single form code describes the physical form or chemical composition and all received waste is managed in a single process system (i.e., same management method code).

WR Form Instructions

Detailed instructions for completing a WR form, including examples and descriptions of available codes, can be found in the RCRA Subtitle C Reporting Instructions and Forms document.

Wastes That Do Not Need to be Reported on a WR Form

Do not complete a WR form for hazardous waste when received from:

• 10-day transfer facilities.
• Household Hazardous Waste and VSQG collection facilities.
• Generators that received hazardous waste after a shipment was rejected from a TSD receiving facility.
• Recyclers of legitimate Hazardous Secondary Materials.

Special Waste Types

The following information pertains to specific waste types that may or may not need to be included in the report, including asbestos, PCBs, waste oils, groundwater contaminated by leachate, hazardous waste pharmaceuticals, hazardous/radioactive nuclear mixed wastes, lab packs and waste from foreign countries.

Asbestos, PCBs and Used Oils

In most cases, do not report asbestos, PCBs or used oil. When these wastes meet the following conditions, they must be reported:

• If a listed hazardous waste (a waste whose hazardous waste code begins with "F," "P," "U," or "K") is mixed with the asbestos, PCBs or waste oil. In this case, the entire mixture becomes a hazardous waste.
• If the waste possesses one or more of the characteristics that result in assigning a hazardous waste code beginning with "D."
• Used oil that exhibits one or more of the characteristics of hazardous waste must be reported when the waste is burned or disposed of.

However, when used oil exhibiting hazardous waste characteristics is recycled in accordance with NR 679, Wis. Adm. Code, it does not have to be reported on a hazardous waste annual report.

Contaminated Groundwater

Groundwater that is contaminated by hazardous waste is not considered a solid waste while it remains in the ground (in situ) and is, therefore, not classified as a hazardous waste. However, when the groundwater is removed from the ground for treatment or disposal it may require management as a hazardous waste. Report the quantities of extracted contaminated groundwater on the hazardous waste annual report if it is:

• Managed onsite.
• Shipped offsite.
• Received from offsite.

Hazardous Waste Pharmaceuticals

Healthcare facilities do not count non-creditable hazardous waste pharmaceuticals (PHRM) or potentially creditable hazardous waste pharmaceuticals for annual reporting purposes when they are managed under Subchapter P. Recordkeeping requirements for these wastes are found in ss. NR 666.502(10) and NR 666.503(5), Wis. Adm. Code.

All other hazardous wastes generated by LQGs and SQGs must be included in the annual report.

Hazardous/Radioactive Nuclear Mixed Wastes

By themselves, source material, special nuclear material or byproduct materials as defined by the Atomic Energy Act of 1954, as amended, 42 US Code 2011 et. seq, are not classified as solid or hazardous waste under hazardous waste regulation. However, if these materials are mixed with a hazardous waste, the material is controlled under hazardous waste regulation, as well as under the Atomic Energy Act (DOE, NRC and EPA) regulations, and must be reported in the hazardous waste annual report.

Lab Packs

The following rules should be applied to the reporting of lab pack wastes in the hazardous waste annual report.

1. You may aggregate lab pack waste containers in most cases. However, you must report them as separate waste types under the following conditions:
   • if they contain acute hazardous wastes (hazardous waste codes F020, F021, F022, F023, F026, F027, and all "P" waste codes). Report separately from lab packs containing other hazardous wastes (all other hazardous waste codes); or
   • if they are managed differently from each other. For example, report lab packs that are shipped to landfills separately from those that are incinerated.
2. Enter a form code indicating lab packs ("W001" or "W004") in generated and managed (GM) section. These form codes are to be used with any lab pack, whether the wastes are gaseous, liquid, solid or sludge.
3. It is not necessary to report every hazardous waste code included in a batch of lab packs. Record one hazardous waste code in the space for primary hazardous waste code GM section, if there are many hazardous waste codes enter "LABP" in GM section.
4. When reporting quantities for lab packs:
   • include the weight of the containers if they are disposed (e.g., landfilled) or treated (e.g., incinerated) along with the wastes; and
   • exclude the weight of the containers if the waste is removed from the containers before treatment or disposal.

Wastes from Foreign Countries

• Report in GM section - If your facility was the generator of record and was the U.S. importer for hazardous waste received from a foreign country, complete GM section for this waste. Enter the appropriate source code, either G62 or G68. Identify the name and address of the foreign generator in the comment section. Also verify you indicated “Yes” for United States importer of hazardous waste on the Site ID form “Other regulated waste activities.”
• Report in WR section - If your facility received hazardous waste directly from a generator in a foreign country, complete a WR section for the waste treated, recovered or disposed at your facility (This waste was not shipped to your facility by a U.S. importer).
• Foreign Site Identification Numbers - If the foreign site has a foreign site identification (ID) number, it can be used wherever an EPA ID number is required. If the site does not have a foreign site ID number, enter "FC" followed by the name of country. A list of common foreign site ID numbers is found in the RCRA Subtitle C Reporting Instructions and Forms document.