Recycling and recovery
Lamp and ballast recycling
Mercury recovery from lamps, and the PCB question in older ballasts.
Fluorescent and HID lamps are crushed and separated to recover mercury, glass, aluminium and phosphor powder. Ballasts manufactured before 1979 may contain PCBs and are handled under TSCA rather than RCRA.
Source: 40 CFR Part 273 for lamps, 40 CFR Part 761 for PCBsThe pre-1979 ballast question
Ballasts made before 1979 can contain PCB capacitors. PCBs are regulated under TSCA, not RCRA, which means a different set of rules, a different disposal route and a different cost.
Ballasts made after 1979 that do not contain PCBs are usually labeled No PCBs. An unlabeled ballast of unknown age is assumed to contain PCBs until demonstrated otherwise, which is the conservative and correct default during a retrofit.
Handling lamps properly
Lamps break, and broken lamps release mercury vapour:
- Store in closed, structurally sound containers designed for lamps
- Never crush lamps on site unless the equipment is permitted for it
- Label containers Universal Waste Lamps with the accumulation start date
- Clean up breakage promptly using mercury spill procedures
- Ship within one year to a permitted recycler
- Keep the recycling certificate, which is the evidence of proper handling
Common questions
Can I throw away a few lamps?
Federal rules provide the universal waste path and most states prohibit landfilling mercury lamps outright. The volume being small does not change the requirement, and lamp recycling is inexpensive per unit.
Are LED lamps regulated?
LEDs contain no mercury and are generally not universal waste. Some fail the toxicity characteristic for lead or copper depending on the driver electronics, so high volume LED disposal is worth testing rather than assuming.
How do I know if a ballast has PCBs?
Ballasts made after 1979 that do not contain PCBs are normally marked No PCBs. Anything unlabeled or predating 1979 is assumed to contain PCBs and handled under TSCA until shown otherwise.
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This page summarizes federal requirements and is not legal advice. State programs can be more stringent than the federal baseline. Verify against current federal and state regulations before acting. Last reviewed September 2026.