How to Safely Dispose of E-Cigarettes: Information for Schools and Small Businesses

On this page:

• E-cigarettes go by many names and have many designs
• E-cigarettes contain lithium batteries and nicotine
• Schools and Businesses can safely dispose of e-cigarettes and components

E-cigarettes go by many names and have many designs

E-cigarettes are sometimes called e-cigs, vapes, vape pens, e-hookahs, and electronic nicotine delivery systems or ENDS. Some e-cigarettes look like regular cigarettes, cigars, or pipes. Some look like USB flash drives, pens, and other everyday items.

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E-cigarettes contain lithium batteries and nicotine

One thing that these e-cigarettes have in common is that they contain nicotine and lithium batteries, making them hazardous waste under the Resource Conservation and Recovery Act.

Nicotine is acutely toxic. Liquid nicotine in e-cigarettes can be easily absorbed by the skin, potentially causing nicotine poisoning with symptoms that include difficulty breathing, fainting, or seizures. Nicotine can also harm fish and other aquatic organisms. Nicotine e-liquid is an acute hazardous waste with the RCRA hazardous waste code P075 (nicotine, & salts).

Lithium batteries can catch fire, especially when damaged. When placed in trash and recycling bins, lithium batteries often get damaged by trash compactors and can cause fires during transportation and at waste and recycling facilities. Most lithium batteries, when discarded, would likely be considered ignitable and reactive hazardous waste (RCRA hazardous waste codes D001 and D003, respectively).

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Schools and Businesses can safely dispose of e-cigarettes and components

Do not:

• Put nicotine e-liquids down the drain.
• Rinse or wash e-liquids out of e-cigarettes.
• Put e-cigarettes or e-cigarette components in the trash or recycling bins.
• Bring the e-cigarettes to Drug Enforcement Administration Take-Back Days, which are for individual consumers, not schools or businesses.

Do follow these three steps:

Step 1: Safely store collected e-cigarettes before disposal.

Intact e-cigarettes	E-cigarette components
	Lithium batteries	Nicotine e-liquids (vials or loose cartridges/pods)
Place each individual e-cigarette in a separate clear, sealed plastic bag to prevent the batteries from short-circuiting and catching fire.	Place each individual lithium battery in a separate clear, sealed plastic bag to prevent the batteries from short-circuiting and catching fire.	Place nicotine e-liquid vials, cartridges, and pods in a clear, sealed plastic bag. You can combine multiple items in the same bag.
	Alternative: Tape the battery terminals to prevent the batteries from short-circuiting and catching fire.	Caution: If possible, wear chemical resistant gloves (e.g., latex or nitrile) to protect your skin from nicotine poisoning.

Step 2: Determine your RCRA hazardous waste generator category.

The options that your school or business has for disposing of your hazardous waste depend on how much hazardous waste your school or business generates per calendar month.

EPA established three RCRA hazardous waste generator categories - very small, small, and large quantity generators. Below are details about these categories and the amount of hazardous waste that schools or businesses would generate per month to land in each category.

	VSQG Very small quantity generator	SQG Small quantity generator	LQG Large quantity generator
Non-acute hazardous waste generated per calendar month	≤ 100 kilograms (220 pounds)	> 100 & < 1000 kilograms	≥ 1000 kilograms (2,200 pounds)
Acute hazardous waste generated per calendar month	≤ 1 kilogram (2.2 pounds)		> 1kilogram (2.2 pounds)

You must count ALL the hazardous waste that your school or business generates on site in a calendar month – not just the e-cigarettes and e-liquids – in determining your RCRA generator category. A few examples can include:

• Lithium batteries from electronic devices.
• Laboratory chemicals.
• Expired hand sanitizer.
• Cleaning supplies.
• Pesticides.
• Vocational shop chemicals.

Help with counting hazardous waste from e-cigarettes:

Importantly, even if your school or business generates less than one kilogram (2.2 pounds) of acute hazardous waste each calendar month, your school or business could become an LQG if you accumulate more than one kilogram (2.2 pounds) of acute hazardous waste on site. We recommend that your school or business send the collected e-cigarettes off site on a regular basis to avoid accumulating one kilogram (2.2 pounds) of acute hazardous waste and becoming an LQG.

Step 3: Determine your disposal options.

Your disposal options will depend on:

1. The RCRA generator category of your school or business, and
2. Whether your school or business is a healthcare facility (e.g., retail pharmacy or vape shop) or has an on-site healthcare facility (e.g., nurse’s office or clinic).

If the school or business is a VSQG:

Disposal Options	What to Do and Know
1. Small Business Collection Program	Contact a locally-run small business collection day for hazardous waste (often run by the county or municipality). The programs are often co-located with household hazardous waste collection sites. The school or business will probably incur a fee for managing and disposing of the hazardous waste in an environmentally protective manner.
2. Off-site Consolidation if the school or business: is not a healthcare facility and does not have an on-site healthcare facility.	Contact the school district or parent company to find out if there is a location that is owned by or under the control of the same entity and that is an LQG that could temporarily consolidate the hazardous waste and manage and dispose of the hazardous waste in an environmentally protective manner. Refer to 40 CFR Section 266.504(b)(2). Refer to 40 CFR Section 262.14(a)(5)(viii) for what the VSQG must do. Refer to 40 CFR Section 262.17(f) for what the receiving LQG must do. Refer to EPA’s Summary of Requirements for Very Small Quantity Generators.
3. Off-site Consolidation if the school or business: is a healthcare facility (e.g., retail pharmacy or vape shop) or has an on-site healthcare facility (e.g., nurse’s office or clinic).	Contact the school district or parent company to find out if there is a healthcare facility that is owned by or under the control of the same entity or that is the supplier of the pharmaceuticals, that could temporarily consolidate the hazardous waste and manage and dispose of the hazardous waste in an environmentally protective manner. Refer to 40 CFR Section 266.504(b)(1). Refer to 40 CFR Section 266.502(l) and 40 CFR Section 266.503(b) for what the receiving healthcare facility must do.

If the school or business is not a VSQG:

Disposal Options	What to Do and Know
1. If the school or business: is not a healthcare facility and does not have an on-site healthcare facility.	The school or business must manage their e-cigarettes, along with any other hazardous waste that the school generates, in accordance with the RCRA hazardous waste generator regulations for SQGs or LQGs. For SQGs, refer to EPA’s Managing Your Hazardous Waste: A Guide for Small Businesses. For LQGs, refer to EPA’s Hazardous Waste Requirements for Large Quantity Generators (pdf)(343 KB). Most hazardous waste generators hire a hazardous waste vendor to help.
2. If the school or business: is a healthcare facility (e.g., retail pharmacy or vape shop) or has an on-site healthcare facility (e.g., nurse’s office or clinic).	The school or business must manage their e-cigarettes as hazardous waste pharmaceuticals under 40 CFR Part 266 Subpart P. Refer to EPA’s FAQs for vape shops. The school or business must manage their other hazardous waste in accordance with the RCRA hazardous waste generator regulations for SQGs or LQGs. For SQGs, refer to EPA’s Managing Your Hazardous Waste: A Guide for Small Businesses. For LQGs, refer to EPA’s Hazardous Waste Requirements for Large Quantity Generators (pdf)(343 KB).