EPA Moves Forward with Revisions to RCRA Waste Handling Regulations for Retailers

The U.S. Environmental Protection Agency ("EPA") is pursuing plans to address the unique challenges faced by retailers in complying with the waste handling regulations of the Resource Conservation and Recovery Act ("RCRA"). In particular, retailers must make hazardous waste determinations for a diverse and ever-changing lineup of products, and the "reverse distribution" process raises a number of compliance questions exclusive to the retail industry.  The agency’s initiative has been in the works for a number of years (since 2008), but gained renewed momentum when EPA released its Strategy for Addressing the Retail Sector under RCRA’s Regulatory Framework1 last Fall.  Given the goal of reducing regulatory burdens, implementation of the Strategy is expected to continue with the incoming Trump Administration.