Nicotine and vape waste

Businesses that handle nicotine-containing vape waste must manage and dispose of these wastes properly. This applies to:

Convenience stores.
Grocery stores.
Other vape retailers with nicotine-containing waste.

Many products that contain nicotine designate as a dangerous waste when discarded. Businesses must handle these wastes as dangerous waste.

This includes:

FDA-approved nicotine-replacement therapies: Nicotine-containing patches, lozenges, and gums (these may designate as a Washington state-only dangerous waste).
E-cigarettes and vape pens: Electronic nicotine delivery systems that contain a battery, tank, or cartridge that delivers nicotine as a vapor.
E-liquids and vape liquids (or, what is referred to as "vape"): Nicotine-containing liquids or prefilled cartridges added to e-cigarettes for consumption of the vapor.

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How do you know if a nicotine waste is dangerous waste?

Businesses need to designate their waste in order to determine this. Part of the designation process includes determining if the waste is one or more of the following:

These wastes will designate as P-listed wastes and carry the waste code P075:

Unused commercial products that become waste AND contain nicotine or nicotine salts as the sole active ingredient.
Note: These wastes may also be considered a pharmaceutical waste as described below.

These wastes are NOT listed wastes:

FDA-approved over-the-counter nicotine replacement therapy patches, gums, and lozenges.
Products completely used for their intended purpose.
Products with more than one active ingredient.

Nicotine wastes are pharmaceutical wastes

These nicotine-containing wastes meet the definition of a pharmaceutical (WAC 173-303-555):

Any drug or dietary supplement sold for human or animal use
Any liquid nicotine (e-liquid) packaged for retail sale for use in electronic nicotine delivery systems (e.g., pre-filled cartridges or vials) as a P075 listed dangerous waste

It is important to note that the EPA definition of pharmaceutical, which determines how e-cigarettes are regulated when they become waste, does not alter and has no bearing on how FDA or others regulate e-cigarettes as products.

How do businesses manage vape waste properly?

Retailers that qualify as health care facilities

If you sell or distribute pharmaceuticals, including nicotine-containing products, you are considered a health care facility.

Health care facilities must manage pharmaceutical waste under the special requirements (WAC 173-303-555).

Retailers that qualify as non-health care facilities

If you manufacture, mix, or package electronic nicotine device system liquid products (e-liquid), then you are a non-health care facility.

Non-health care facilities must manage their waste nicotine under the Dangerous Waste Regulations (Chapter 173-303 WAC).

How do businesses dispose of vape waste properly?

Businesses must ship nicotine dangerous waste to a permitted treatment, storage, and disposal facility.

Do not put vape liquid wastes in the trash.
Do not burn vape waste.
Do not pour vape waste down the drain, sink, or toilet.

Unused nicotine products have the potential to be legitimately recycled into new nicotine products.
Batteries removed from devices can be disposed of as universal waste.

Contact information

Need help?
Contact a dangerous waste inspector in your region.

Lisa Perle
Southwest Region
lisa.perle@ecy.wa.gov
360-522-0538

Jenny Yoo
Northwest Region
jenny.yoo@ecy.wa.gov
425-457-3636

Eric McConnell
Eastern Region
eric.mcconnell@ecy.wa.gov
509-279-3025

Katherine Gauthier
Central Region
katherine.gauthier@ecy.wa.gov
509-406-6851

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