The Holiday Season Brings Hidden Surprises to Retail Hazardous Waste

Originally posted 12/15/2016

The Holiday season produces a lot of hot, new items on the shelf. Shoppers are clamoring to get their hands on the newest gadgets or find the best gift. But, what happens when one of these items gets damaged in the aisles by overenthusiastic shoppers and needs to be disposed of? It’s not very merry but many seasonal products may be considered hazardous waste.

EPA’s Resource Conservation and Recovery Act (RCRA) provides guidance for the proper management of hazardous waste. Under RCRA, products which are ignitable, corrosive, reactive, toxic, or contain certain listed chemicals are considered hazardous waste. In addition to RCRA’s framework, some states define hazardous waste based on other characteristics, such as a broader list of restricted chemicals or harmfulness to aquatic life. It is best to consult the appropriate state, regional, or local regulations for additional requirements. The CRC also has information on state variations in hazardous waste regulations on the State Matrices page.

Surprising seasonal products which may be considered hazardous waste include:

Holiday Gifts:

• Electronics
• Batteries may contain toxic chemicals and require important considerations for disposal or recycling.
• Electronic products, even without batteries, have disposal restrictions in many states.
• Beauty Sets
• Nail polishes and perfumes are often ignitable waste.
• Cosmetics may contain dyes with restricted chemicals.
• Body wash, soap, and bubble bath may be harmful to fish and considered hazardous waste in some states.
• Craft Kits
• Adhesives may be ignitable waste or state-regulated toxic waste due to listed ingredients or aquatic toxicity.
• Art supplies may contain pigments which are RCRA or state-regulated.

Holiday Decorations:

• Holiday lights that contain heavy metals like mercury or lead solder may be considered hazardous waste.
• Candles that contain ingredients that are considered toxic to fish are more heavily regulated in states like California and Washington.

Cold and Flu Season:

• Oral analgesics containing the active ingredient phenol are often RCRA hazardous waste
• Cough medicines containing alcohol may be ignitable waste.
• Other medicines may be harmful to fish or contain state-restricted chemicals.
• Household antibacterial cleaners are restricted in some states.

Holiday Baking:

• Cooking sprays and flavoring extracts are generally ignitable wastes.
• Whipped topping in aerosol cans may be restricted in some states

New Year’s Resolutions:

• Vitamins may be hazardous under RCRA due to their chromium or selenium content.
• Vitamins could be hazardous in some states due to listed ingredients, such as copper or zinc.
• Nutritional supplements may contain state-restricted artificial sweeteners.
• Smoking cessation products, such as nicotine gum, are RCRA hazardous waste.

So don’t forget to properly identify and manage unsalable items in the holiday rush.

Marietje Hauprich, Senior Hazard Review Specialist, UL WERCS

The UL WERCSmart platform connects manufacturers with retailers around the globe to meet critical compliance and data sharing needs.

The views and opinions expressed in this article are those of the author(s) and do not necessarily reflect the policy or position of the Center for Retail Compliance (CRC) or the Retail Industry Leaders Association (RILA). This content is obtained from sources believed to be reliable but no guarantees are made by the CRC or RILA as to its accuracy, completeness, or timeliness. For more information see the Terms of Use.