Most facilities don’t realize they’re hazardous waste generators—until a fine lands on their desk. In Wisconsin, classification isn’t just a bureaucratic label; it determines how you store, transport, report, and dispose of your waste.
Yet the rules are often misunderstood, especially when generator status can shift from month to month. At Wastebits, we’ve helped countless companies uncover hidden compliance gaps simply by re-evaluating how their waste is classified—and what that means under Wisconsin law.
What Is Hazardous Waste in Wisconsin?
In Wisconsin, hazardous waste is defined according to both federal regulations under the Resource Conservation and Recovery Act (RCRA) and additional state-level enforcement by the Wisconsin Department of Natural Resources (DNR). Waste is considered hazardous if it meets any of the following criteria:
- It appears on one of the EPA’s four hazardous waste lists: F, K, P, or U codes
- It exhibits one or more of four hazardous characteristics: ignitability, corrosivity, reactivity, or toxicity
- It is a mixture or derivative of a listed hazardous waste
These designations might seem technical, but they’re essential for determining how your waste must be handled. For example, a flammable solvent from a manufacturing process may fall under the ignitability characteristic, while expired pesticides could be listed as a P-code waste.
The key takeaway? If your facility produces waste that fits any of these descriptions, you’re generating hazardous waste—and that triggers a specific set of obligations under Wisconsin law.
What’s New in 2025: Updates to Wisconsin Hazardous Waste Regulations
As of July 1, 2025, the Wisconsin Department of Natural Resources (DNR) enacted several updates to the state’s hazardous waste regulations. These changes align Wisconsin’s rules more closely with recent federal updates, while also clarifying key definitions and expanding universal waste categories. Here’s what your facility needs to know:
- Aerosol Cans Added to Universal Waste
Wisconsin now recognizes certain aerosol cans as universal waste, making it easier for facilities to manage these common items under streamlined accumulation and labeling requirements. This change is especially beneficial for industrial and commercial operations with high volumes of pressurized containers. - Modernized Ignitable Liquids Determinations
The DNR has adopted updated criteria for identifying ignitable liquids, aligning with revised EPA guidance. This modernized approach reflects current industry practices and testing methods but may require facilities to reevaluate how they classify flammable wastes. - Technical Corrections and Clarifications
Several technical corrections have been made to improve the clarity and consistency of hazardous waste rules across Wisconsin. These include terminology updates, clearer formatting, and refinements to reporting requirements—all aimed at reducing confusion and ensuring compliance.
These updates reflect the DNR’s ongoing effort to modernize hazardous waste management while staying consistent with federal RCRA standards. You can review the updated Wisconsin hazardous waste administrative code for full details, or contact Wastebits to evaluate how these changes may impact your classification, documentation, or disposal practices.
The 3 Generator Categories in Wisconsin
In Wisconsin, hazardous waste generators are classified into three categories based on the amount of hazardous waste produced in a calendar month. These categories—Very Small Quantity Generator (VSQG), Small Quantity Generator (SQG), and Large Quantity Generator (LQG)—each come with their own regulatory obligations for storage, training, reporting, and disposal.
Very Small Quantity Generator (VSQG)
- Monthly generation: ≤ 220 lbs (100 kg) of hazardous waste
- Acute hazardous waste limit: ≤ 2.2 lbs (1 kg)
- On-site storage limit: ≤ 2,200 lbs at any time
Key obligations:
VSQGs face the fewest requirements but must still manage waste responsibly. They are not required to have an EPA ID number but must ensure proper disposal at a licensed facility.
Small Quantity Generator (SQG)
- Monthly generation: Between 220 lbs and 2,200 lbs (100–1,000 kg)
- Acute hazardous waste limit: ≤ 2.2 lbs (1 kg)
Key obligations:
SQGs must obtain an EPA ID number, adhere to accumulation time limits (usually 180 days), maintain basic records, and train employees on hazardous waste handling. Annual reporting may also be required in Wisconsin, depending on activity.
Large Quantity Generator (LQG)
- Monthly generation: > 2,200 lbs (1,000 kg)
- Acute hazardous waste limit: > 2.2 lbs (1 kg), or more than 2,200 lbs of any hazardous waste on site
Key obligations:
LQGs are subject to the highest level of oversight. They must:
- Submit annual reports to the Wisconsin DNR
- Develop and maintain a contingency plan
- Provide hazardous waste training for employees
- Maintain manifests, inspection logs, and waste determinations
- Limit accumulation to 90 days without a storage permit
Even if your facility is currently classified as a VSQG, temporary production spikes or seasonal shifts can push you into a higher generator category—triggering a new set of rules overnight. That’s why accurate tracking and proactive classification reviews are essential for staying compliant.
| Generator Category | Monthly Waste Generation | Acute Hazardous Waste Limit | Storage Time Limit | EPA ID Required | Annual Reporting | Other Key Requirements |
|---|---|---|---|---|---|---|
| VSQG(Very Small Quantity Generator) | ≤ 220 lbs (100 kg) | ≤ 2.2 lbs (1 kg) | No formal time limit | No | Not typically required | Cannot accumulate >2,200 lbs on-site; must ensure delivery to authorized facility; fewer documentation and training requirements |
| SQG(Small Quantity Generator) | > 220 lbs but ≤ 2,200 lbs (100–1,000 kg) | ≤ 2.2 lbs (1 kg) | 180 days (270 if >200 miles to TSDF) | Yes | May be required by DNR | Must maintain training records, inspection logs, and manifests; limited accumulation and storage requirements |
| LQG(Large Quantity Generator) | > 2,200 lbs (1,000 kg) | > 2.2 lbs (1 kg) or >2,200 lbs of any haz. waste on-site | 90 days | Yes | Required annually by DNR | Full compliance required: contingency plan, employee training, inspections, manifest tracking, biennial/annual reports, and documentation of waste determinations |
How to Determine Your Generator Status
Your generator status isn’t a one-time designation—it can change from month to month.
Your generator status isn’t a one-time designation—it can change from month to month depending on how much hazardous waste your facility produces. That’s why the Wisconsin DNR requires facilities to evaluate their status monthly based on actual generation activity.
To determine your status, follow these key steps:
- Track Monthly Waste Totals
Measure all hazardous waste generated during each calendar month, including both acute and non-acute waste. Pay close attention to process changes, spills, or cleanouts that might temporarily increase volumes. - Apply the Thresholds
Compare your totals to the limits for VSQG, SQG, and LQG classifications. Be sure to account for both the volumeand the type of waste—especially acute hazardous waste, which has much stricter limits. - Include All Applicable Waste Streams
This includes spent solvents, contaminated wipes, expired chemicals, and anything else that meets a hazardous listing or characteristic. Don’t forget to evaluate mixtures, residues, and materials in storage. - Keep Documentation
Wisconsin requires generators to maintain documentation of their waste determinations, including supporting lab results, safety data sheets (SDS), and monthly calculations. Even if your waste volume is low, failing to document properly can result in violations. - Reevaluate When Operations Change
New equipment, shifts in production, or changes in raw materials can impact your waste profile. Schedule periodic reviews—or use a digital tracking platform like Wastebits—to avoid accidental misclassification.
Understanding your generator status is more than just checking a box—it drives your entire compliance strategy, from how long you can store waste to which reports you must submit. A single misstep can put you on the DNR’s radar.
State-Specific Requirements You Might Miss
Even if you’re familiar with federal hazardous waste laws under RCRA, Wisconsin adds its own layer of regulations—and enforcement. These state-level nuances often catch facilities off guard, especially those managing waste at multiple locations or relying on outdated internal processes.
Here are a few Wisconsin-specific requirements to keep on your radar:
- Annual Reporting Requirements
Large Quantity Generators (LQGs) are required to submit annual hazardous waste reports to the DNR. Some Small Quantity Generators (SQGs) may also be required to report depending on past activity or generator fluctuations. - Generator Fees
Wisconsin imposes annual generator fees based on your classification. These fees vary by status and are in addition to federal obligations—missing a payment can result in enforcement actions. - On-Site Accumulation Limits
Even if you’re a Very Small Quantity Generator (VSQG), you cannot accumulate more than 2,200 lbs of hazardous waste at any time without triggering higher-level requirements. This often surprises facilities that are otherwise low-volume generators. - Transport and Disposal Standards
Hazardous waste must be transported by licensed haulers and delivered to permitted treatment, storage, or disposal facilities (TSDFs). Documentation must be maintained, including manifests and signed receipts. - Inspections and Enforcement
The Wisconsin DNR conducts routine and unannounced inspections—particularly at SQG and LQG sites. Facilities found lacking in documentation, labeling, or classification accuracy can face stiff penalties.
Keeping up with Wisconsin’s unique requirements isn’t easy—especially if your team is already stretched thin managing operations, safety, and supply chain demands. And that’s where we come in.
Compliance Without the Chaos
Hazardous waste compliance in Wisconsin is more than just knowing the rules—it’s staying ahead of them. Generator status changes. Regulations shift. Paperwork piles up.
Wastebits helps you manage all of it.
Our team of experts stays on top of state and federal regulations, so you don’t have to. With Wastebits, you get:
- Expert guidance on generator status, classification, and reporting
- Digital tools to track waste volumes and flag changes in generator category
- Compliant documentation stored securely and accessible anytime
- Sustainability-focused strategies to reduce hazardous waste volumes and cut costs
From annual reports to day-to-day compliance, we handle the stress so your team can focus on operations, not regulations.
Ready to simplify compliance in Wisconsin?
Talk to a Wastebits expert
Do you work in another state? That’s okay, your regulations change too 🙂 We’re still here to help.
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