How to Fill Out EPA Form 8700-12 (w/ Examples) + FAQs

If your business so much as touches a drum of solvent, a pail of used oil, or a bin of expired chemicals, the U.S. Environmental Protection Agency probably wants to know about it. The vehicle for that introduction is EPA Form 8700-12, also known as the RCRA Subtitle C Site Identification Form, the federal notification form that assigns your facility an EPA ID Number and tells regulators exactly what kind of hazardous waste activity happens on your site.

This guide walks you through the form item-by-item, shows real-world examples for Very Small, Small, and Large Quantity Generators (plus transporters and TSDFs), explains state-specific quirks, and answers the questions compliance officers ask most often. You can grab the official PDF and instructions directly from the EPA’s Hazardous Waste Generators page.

What Is EPA Form 8700-12?

EPA Form 8700-12 is the federal Site Identification (Site ID) Form that businesses use to notify the EPA — or their authorized state agency — about regulated hazardous waste activities under Subtitle C of the Resource Conservation and Recovery Act (RCRA). The form captures the facility’s name, address, contacts, NAICS codes, ownership information, and a complete inventory of regulated waste activities at the site.

Submitting an accurate 8700-12 is how a facility:

Obtains a new EPA Identification (ID) Number (sometimes called a Generator ID Number or “GIN”)
Updates previously submitted site information (a Subsequent Notification)
Re-notifies the agency as a Small Quantity Generator (SQG) or Large Quantity Generator (LQG)
Registers as a hazardous waste transporter, importer, recycler, or Treatment, Storage, and Disposal Facility (TSDF)
Notifies for episodic generation, electronic manifest broker activity, or other specialized RCRA programs

Most filers today submit electronically through the EPA’s myRCRAid module inside RCRAInfo Industry Application, although paper submissions are still accepted by many states.

Who Has to File Form 8700-12?

You must file the form if your site falls into any of the categories defined in 40 CFR Part 262. The most common triggers:

Large Quantity Generators (LQGs) — generate ≥ 1,000 kg/month of hazardous waste, > 1 kg/month of acute hazardous waste, or > 100 kg/month of acute spill cleanup material
Small Quantity Generators (SQGs) — generate > 100 kg but < 1,000 kg/month of hazardous waste
Very Small Quantity Generators (VSQGs) — generate ≤ 100 kg/month (notification optional federally, required in some states)
Transporters of hazardous waste
Treatment, Storage, and Disposal Facilities (TSDFs)
Recyclers of hazardous secondary materials, including those operating under the Definition of Solid Waste (DSW) rule
Importers and exporters of hazardous waste
Universal waste handlers above large-handler thresholds
Used oil transporters, processors, re-refiners, burners, and marketers
Anyone filing an Episodic Generation notification under the Generator Improvements Rule

Renotification deadlines are a moving target — SQGs must renotify every four years by September 1, and LQGs renotify with their Biennial Report by March 1 of every even-numbered year, as outlined by EPA’s biennial reporting program.

Where to Send the Completed Form

Whether you mail the form, hand-deliver it, or upload it through myRCRAid depends on your state’s authorization status. The EPA’s State Authorization page lists which agencies have primacy. For example:

California filers submit through DTSC and use additional state forms like DTSC 1358
Texas filers go to the TCEQ and may use Core Data Form 10400
New York filers route through NYSDEC
Florida uses the FDEP Hazardous Waste Program
New Mexico still requires original ink signatures mailed to the NMED Hazardous Waste Bureau

When in doubt, route via the EPA Regional Office locator.

Step-by-Step: Filling Out Every Item on Form 8700-12

The PDF (downloadable from the Texas RRC mirror or the EPA site) contains 18 numbered items plus signature blocks. Here is a field-by-field walkthrough with example entries for “Acme Auto Body, Inc.”, a fictional SQG in Ohio that strips paint, generates spent solvents, and ships waste off-site quarterly.

Item 1 — Reason for Submittal

Check all boxes that apply. Options include:

Initial Notification (first-ever submission for this address)
Subsequent Notification (updating existing information)
Site was an LQG in one or more months of the report year
Notifying as part of the Biennial Report
Notifying for an Episodic Event
Notifying as an Electronic Manifest Broker

Example: Acme Auto Body is filing for the first time after a 12-month review found average monthly generation of 250 kg of F005 spent solvents — mark “Initial Notification.”

Item 2 — Site EPA ID Number

Leave blank for initial notifications; the state will assign a 12-character ID (two letters + nine digits, e.g., OHD987654321). Subsequent filers enter the existing ID.

Item 3 — Site Name

Enter the legal operating name, not a parent company. Acme writes: Acme Auto Body, Inc.

Item 4 — Site Location Information

Use the physical street address, not a P.O. Box. Include city, county, state, country, and ZIP+4. Example:

Street: 1421 Industrial Parkway
City: Springfield   County: Clark   State: OH   ZIP: 45504-1102

Item 5 — Site Land Type

Choose one: Private, County, District, Federal, Tribal, Municipal, State, or Other. Acme marks Private.

Item 6 — NAICS Codes

Provide up to four 6-digit NAICS codes describing on-site activity. Acme enters 811121 (Automotive Body, Paint, and Interior Repair). A multi-process plant might list manufacturing primary code plus secondary maintenance codes. Look up codes via the Census Bureau NAICS search.

Item 7 — Site Mailing Address

If different from Item 4, enter a P.O. Box or corporate address. Acme uses P.O. Box 88, Springfield, OH 45501.

Item 8 — Site Contact Person

The day-to-day environmental contact — not necessarily the owner. Include first/last name, title, mailing address, phone, fax (optional), and a monitored email. Acme lists Jordan Patel, EHS Manager, jpatel@acmeauto.com, 937-555-0142.

Item 9 — Legal Owner and Operator of the Site

Two sub-blocks: Owner (Item 9A) and Operator (Item 9B). Provide each entity’s name, ownership type (Private, County, Federal, Tribal, Municipal, State, Other), date became owner/operator, phone, and mailing address. If owner = operator, indicate so. Acme lists itself for both, with date 06/15/2014.

Item 10 — Type of Regulated Waste Activity

The heart of the form. Mark Yes or No for every line; mark sub-categories only when the answer is Yes.

Item 10.A — Hazardous Waste Activities

Generator of Hazardous Waste — pick one: – a. LQG – b. SQG – c. VSQG
Short-Term Generator — temporary >90-day accumulation
United States Importer of Hazardous Waste
Mixed Waste (hazardous + radioactive) Generator
Transporter of Hazardous Waste — mark all that apply (Transporter, Transfer Facility)
Treater, Storer, or Disposer of Hazardous Waste
Recycler of Hazardous Waste
Exempt Boiler / Industrial Furnace (small quantity burner, smelting/melting/refining, other)
Underground Injection Control
Receives Hazardous Waste from Off-Site

Acme marks 1b (SQG) Yes, and No on the rest.

Item 10.B — Universal Waste Activities

Indicate generation or accumulation > 5,000 kg of universal waste (batteries, pesticides, mercury-containing equipment, lamps, aerosol cans). Acme marks No.

Item 10.C — Used Oil Activities

Mark Yes/No for Transporter, Transfer Facility, Processor/Re-refiner, Burner (with EPA Form 8700-12 burner type), Marketer who directs shipment, or Marketer who first claims oil meets specifications. Acme marks No.

Item 10.D — Eligible Academic Entity under 40 CFR Part 262 Subpart K — typically colleges, teaching hospitals.

Item 10.E — Episodic Generation — used when a one-time event (e.g., laboratory cleanout) would otherwise bump a VSQG/SQG into a higher category. Provide event type (planned vs. unplanned), start date, and estimated quantities.

Item 10.F — LQG Site Closure / LQG Consolidation of VSQG Waste — emerging-rule activities under the Generator Improvements Rule.

Item 11 — Description of Hazardous Wastes

Two sub-sections often handled on Addendum pages:

A. Waste Codes for Federally Regulated Hazardous Wastes — list every F-, K-, P-, U-, and characteristic D-code generated. Acme enters D001 (ignitable), D008 (lead), F003, F005.
B. Waste Codes for State-Regulated (i.e., Non-Federal) Hazardous Wastes — only used in states like California (e.g., 331 non-RCRA asbestos).

Item 12 — Notification of LQG Consolidation of VSQG Waste

LQGs that consolidate VSQG waste from sister sites mark Yes and complete the VSQG Site Information Addendum listing each VSQG site name, address, EPA ID (if any), and contact.

Item 13 — Notification of Hazardous Secondary Material (HSM) Activity

Triggered when reclaiming materials under the DSW exclusions. Identify the type of HSM activity (generator, reclaimer, intermediate facility) and complete the HSM Addendum.

Item 14 — Electronic Manifest Broker

Mark Yes if you sign manifests electronically on behalf of generators. Most ordinary generators leave this No.

Item 15 — LQG Consolidation of VSQG Waste

A redundant control box confirming the activity declared in Item 12.

Item 16 — Notification of LQG Closure of a Central Accumulation Area or Facility

LQGs closing a 90-day accumulation area complete this and submit on the schedule required by 40 CFR 262.17(a)(8).

Item 17 — Notification of Hazardous Waste Pharmaceutical Activity

Healthcare and reverse-distributor facilities indicate whether they operate as a Healthcare Facility, Reverse Distributor, or both under Subpart P.

Item 18 — Comments

Free-text field for clarifications such as “Filing in response to state SQG renotification request” or “Acquired site from XYZ Corp on 01/03/2026 — see attached deed.”

Certification & Signature

The form must be signed by an authorized representative meeting 40 CFR 270.11 — typically a corporate officer, plant manager, or duly authorized designee with written delegation on file. Paper submissions require an original ink signature in many states (notably New Mexico, per the NMED Hazardous Waste Bureau).

Example Walk-Throughs

Example 1 — VSQG Dental Office (Initial Notification, Optional)

Reason: Initial Notification
NAICS: 621210 (Offices of Dentists)
Item 10.A.1: Yes → c. VSQG
Waste Codes: D009 (mercury amalgam waste from chair-side traps)
Comment: “Filing voluntarily to obtain EPA ID required for amalgam recycler manifest.”

Example 2 — SQG Auto Body (Acme, from walkthrough above)

Item 10.A.1: Yes → b. SQG; all others No
Waste Codes: D001, D008, F003, F005
Renotification cadence: every 4 years by September 1

Example 3 — LQG Pharmaceutical Manufacturer

Item 1: Subsequent Notification + Biennial Report
Item 10.A.1: Yes → a. LQG
Item 10.A.10: No (not a TSDF)
Item 17: Healthcare Facility – No; Reverse Distributor – No; standard manufacturer
Waste Codes: D001, D002, U-codes for off-spec APIs, F003 solvents

Example 4 — Hazardous Waste Transporter

Item 10.A.5: Yes → mark Transporter and Transfer Facility if applicable
Item 10.A.1: No (unless company also generates)
NAICS: 484230 (Specialized Freight – Long Distance)

Example 5 — Episodic Generator

A VSQG paint shop performs a one-time tank cleanout producing 1,400 kg of waste in March:

Item 1: Episodic Notification
Item 10.E: Planned Event, start 03/12/2026, end 04/10/2026
Estimated Quantity: 1,400 kg D001
Per 40 CFR 262 Subpart L, the VSQG retains its status if the form is filed at least 30 days before the event.

State-Specific Notes

Even though Form 8700-12 is federal, authorized states layer their own rules on top:

California — additional non-RCRA waste codes; submit via DTSC’s Hazardous Waste Tracking System.
Texas — TCEQ assigns a separate Solid Waste Registration (SWR) number; pair Form 8700-12 with Core Data Form 10400.
New York — file through NYSDEC’s RCRAInfo portal; SQG re-notifications also accepted on paper.
Florida — see FDEP’s April 2025 Notification Form package for FL-specific addenda.
Massachusetts — uses the MassDEP myRCRAid workflow with state-specific class codes (e.g., VSQG = “Conditionally Exempt”).
Indiana — IDEM publishes detailed myRCRAid Instructions.

If your state is not authorized for a particular rule (e.g., the 2016 Generator Improvements Rule has uneven adoption), you may have to file under both the federal and state versions — the EPA’s state adoption tracker shows current status.

Submitting Electronically Through myRCRAid

The fastest path is the EPA’s RCRAInfo Industry Application. After registering for a CDX-style account and linking it to your site, you can:

Click myRCRAid → Create New Submission
Select Initial Notification or Subsequent Notification
Complete the on-screen equivalents of Items 1–18
Upload supporting documents (deed, delegation of signature authority, episodic event plan)
Electronically sign using the CROMERR-compliant eSignature workflow
Submit; the state regulator reviews and approves, typically within 10–30 business days

Your site’s history, waste codes, and contact list will then flow automatically into e-Manifest and the Biennial Report modules.

Common Mistakes to Avoid

Using a P.O. Box for the physical site address (Item 4). EPA inspectors need a geographic location for site visits.
Forgetting to mark Item 1’s “Subsequent Notification” box when only updating a contact — this stalls processing.
Listing parent company in Item 3 instead of the operating entity. The EPA ID belongs to the site, not the corporation.
Mismatched NAICS codes between Form 8700-12 and your state air/water permits — triggers cross-program audits.
Skipping signature delegation paperwork when an EHS manager (not a corporate officer) signs.
Underreporting waste codes — the form’s Item 11 must reflect all codes you might ever ship, not just last month’s manifest.
Missing the September 1 SQG renotification deadline — many states impose civil penalties beginning at $250/day.

Frequently Asked Questions

How long does it take to get an EPA ID number after submitting Form 8700-12?

For paper submissions, 4–8 weeks is typical. Electronic submissions through myRCRAid are usually approved in 10–30 business days, depending on the authorized state’s backlog.

Do VSQGs need to file Form 8700-12?

Federally, VSQGs are not required to notify, but several states (including Massachusetts, New Jersey, Rhode Island, Vermont, Minnesota, Washington, and California) require notification regardless of size. Check the state authorization map.

Is the EPA ID Number tied to the site or the company?

It’s tied to the site (physical address). If you move, you need a new EPA ID at the new address and must close out the old one using Item 1’s “Notifying that the site is no longer a regulated entity” box, plus Item 16 if it was an LQG.

How often do I have to re-notify?

LQGs re-notify every two years via the Biennial Report by March 1 of even-numbered years. SQGs must re-notify every four years by September 1, per the Generator Improvements Rule. Transporters and TSDFs renotify whenever information changes.

What’s the difference between Form 8700-12, 8700-13A/B, and 8700-22?

8700-12 — Site Identification / Notification
8700-13 A/B — Biennial Hazardous Waste Report (generator and TSDF tables)
8700-22 — Uniform Hazardous Waste Manifest, used per shipment, with sample forms on the EPA Manifest page

Can I file Form 8700-12 for a temporary cleanup project?

Yes. Apply for the EPA ID, complete the cleanup, then file a Subsequent Notification to deactivate the ID once shipments are finished — guidance is detailed in MassDEP’s myRCRAid FAQ.

What if I generate only used oil?

Used oil generators are not required to obtain an EPA ID unless they transport, process, re-refine, burn, or market used oil. Those activities are captured in Item 10.C of the form. Pure on-site used oil generation does not require Form 8700-12.

Do I need a signature from a corporate officer?

The signer must satisfy 40 CFR 270.11: a president, vice-president, secretary, treasurer, or a duly authorized representative with written delegation on file. Plant managers commonly sign with a delegation letter attached.

How do I correct a mistake on a previously submitted form?

Submit a Subsequent Notification marking Item 1 accordingly and updating only the affected fields. Keep both versions in your on-site RCRA file for at least three years.

What are the penalties for not filing?

Failure to notify is a violation of RCRA Section 3010 and can result in civil penalties of up to $83,191 per day per violation (2024-adjusted maximum under the EPA Civil Penalty Inflation Adjustment Rule), plus possible criminal prosecution for knowing violations.

Is there a filing fee?

The EPA does not charge a federal fee, but many states do — examples include California’s annual generator fee, Texas’s annual maintenance fee, and New Jersey’s filing fee. See your state’s hazardous waste fee schedule, like TCEQ’s fee summary.

Where can I get the most current version of the form and instructions?

Always download the current PDF from the EPA’s official 8700-12 page. State mirrors (like NC DEQ’s copy) can lag by a revision cycle.

Final Checklist Before You Hit “Submit”

[ ] Item 1 reflects every reason for filing
[ ] Physical address in Item 4 matches deed and air/water permits
[ ] NAICS codes match other regulatory filings
[ ] Item 10 is fully completed — every Yes/No answered
[ ] All applicable waste codes listed in Item 11
[ ] Signature authority documentation attached
[ ] State-specific addenda included (California 1358, Texas 10400, etc.)
[ ] Copies saved in your on-site RCRA recordkeeping file for at least 3 years

When the form is right the first time, you avoid the single most expensive thing in environmental compliance: the second inspection. Bookmark the EPA Hazardous Waste Generators hub, keep a calendar reminder for your next renotification cycle, and you’ll stay on the right side of RCRA Subtitle C.

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