This article provides an update on RY2025 Hazardous Waste reporting for the state of Wisconsin, as the WDNR has announced that the state will transition from Switchboard to RCRAInfo for Annual Hazardous Waste Reports, summarizing the regulatory requirements and process to prepare for reporting in RY2025.
WI Hazardous Waste Reporting Requirements
Hazardous waste reporting is required by the United States Environmental Protection Agency (USEPA) on a biennial (every other year) basis per 40 CFR Part 262.41 for Large Quantity Generators (LQGs), with no federal requirement for reporting placed on Small Quantity Generators (SQGs). Federal rules require that states meet federal minimum standards, but allows states to adopt more stringent requirements, which Wisconsin has done for hazardous waste reporting. Per the Wisconsin Administrative Code section for Natural Resources (NR) 662.040, Wisconsin requires annual reports for both small and large quantity generators. Although reporting occurs more often in Wisconsin than at a federal level, the state still follows the federal biennial cycle in even numbered years and uses a shorter, less strenuous annual report for LQGs in odd numbered years. Other facilities, such as publicly owned wastewater treatment works (POTWs), permanent household collection facilities, and any facilities that performed hazardous waste treatment, storage, or disposal are also required to report annually. However, Very Small Quantity Generators (VSQGs) are not required to submit hazardous waste reports.
WI Annual Hazardous Waste Reporting
Historically, hazardous waste generators have prepared and submitted annual hazardous waste reports to the WDNR via the Switchboard portal on the WDNR website. Switchboard was introduced by the WDNR to allow facilities to utilize a single online system for reporting, compliance, and facility information. Similarly, under the Resource Conservation and Recovery Act (RCRA), the USEPA implemented RCRAInfo, a webpage accessed via the USEPA Central Data Exchange (CDX), designed to allow hazardous waste generators single source access to important hazardous waste information. The USEPA has expanded the function of RCRAInfo, primarily with the introduction of the e-Manifest system in 2018, and the Annual Report module in 2020. Wisconsin has already adopted the RCRAInfo e-Manifest system to allow generators and transport, storage, and disposal facilities in the state to easily and reliably transmit hazardous waste manifests, as such, all existing facilities in the state should be familiar with the program.
On November 3, 2025, the WDNR announced the transition to RCRAInfo from Switchboard for reporting year (RY) 2025, due on March 1, 2026. This change should not greatly impact SQG and LQG facilities in Wisconsin that have previously filed annual hazardous waste reports, as the report in both RCRAInfo and Switchboard are functionally the same. The same information will be required in RCRAInfo but will be in a slightly different format than Wisconsin facilities are used to, however, RCRAInfo has functionality that is beneficial to users, such as the lookup function for TSDFs and easy access to manifests in the same system.
RY2025 Preparation
The USEPA recently required that CDX users access the portal via Login.gov, the U.S. General Services Administration secure government website access program. This change now requires users have a CDX account, as well as a Login.gov account, which also requires multi-factor authentication (MFA). Users can choose multiple MFA options, including an authenticator app, a physical security key, or one-time codes provided via text message or a phone call. This login procedure is required for both hazardous waste report preparers, and certifiers, which means your responsible official (RO) will need to setup an account in both CDX and Login.gov to access the facility’s report. It is recommended to do this process early, as delays can occur, and could cause a facility to miss the March 1 deadline. What should facilities do to prepare?
- Create a CDX and Login.gov account for both the report preparer and RO, including backups if possible, following the RCRAInfo and Login.gov new user setup guides
- Verify your existing accounts and MFA methods work and are accessible
- New accounts will need to add the RCRAInfo Service in CDX via the Add Program Service tool in CDX
- Add your site to your sites in RCRAInfo via the Select Existing Site tool in the My Sites tab of RCRAInfo
The Overview tab in the Home screen of RCRAInfo allows for both biennial and annual reports, your facility will be assigned the correct report based on your generator status. Once the report is open on January 1, 2026, facilities will be able to complete the report as soon as all manifests shipped in RY2025 are returned to the generator.
Additional Updates
The USEPA has introduced new Management Method codes for wastes that are temporarily stored at a receiving facility before being sent for final treatment, storage, or disposal. There are 24 new codes, all starting with the letter “S” that are optional for facilities to utilize in RY2025 and RY2026, however, they will be mandatory starting in RY2027, when the USEPA will retire H141 – Storage and Transfer. The new S-codes will provide more information on how the wastes are stored, allowing better tracking and recordkeeping for facilities and the agencies.
The change from Switchboard to RCRAInfo should be an easy switch for facilities and provide better functionality in the future, but will take some preparation by facilities prior to March 1, 2026. Make sure both the preparer and certifier have access to the new system and the facility to ensure prompt submittal. Request information from your TSDFs and waste vendors on what S-codes your current H141 waste could have in the future to make sure you track and report your waste correctly for RY2027. Please reach out to Steve Tasch, Harrison Rae, or the Trinity’s Wisconsin Office to discuss the specifics for your facility.
