Types of nicotine products
- Gum and lozenges
How to designate nicotine waste
The active ingredients in a product determine how a product will designate:
- Products where the sole active ingredient is nicotine or nicotine salt: When discarded or unused for its intended purpose, it becomes a P-listed waste with waste code P075.
- Products with another active ingredient besides nicotine or nicotine salt: When discarded or unused for its intended purpose, will likely designate as state-only dangerous waste for toxicity.
Nicotine patches, gum, and lozenges
- If opened and unused, the item and its wrapper are a P075-listed waste.
- If it has been used for its intended purpose, it is no longer a P075-listed hazardous waste. However, it still may be considered state-only dangerous waste for toxicity.
- The product wrapper would not carry the P075 assuming that the nicotine patch is being administered and therefore still a product when removed from the wrapper. No listing would apply. The packets (container/inner liner) would be a solid waste.
Nicotine inhalers and sprays
- If opened and unused, the entire cartridge is a P075-listed waste.
- If it has been used for its intended purpose, but there is still a residue of nicotine remaining inside the cartridge or bottle, it is still a P075-listed hazardous waste. It may also be dangerous waste for toxicity under our state-only criteria.
How to manage nicotine waste
Nicotine products that are eligible for credit from a manufacturer, wholesaler, or reverse distributor are viable pharmaceuticals and not considered waste.
Viable pharmaceuticals include:
- Unused pharmaceuticals that receive a credit.
- Unopened pharmaceuticals that receive a credit.
Items not receiving a credit must be managed as waste.
RCRA hazardous nicotine waste
Manage as a dangerous waste at a RCRA permitted facility. This includes:
- Non-viable formulations of nicotine and nicotine salts that designate as listed wastes or under the RCRA characteristics of ignitability, corrosivity, reactivity, or toxicity.
- Any discarded containers with nicotine residue that have not been triple-rinsed.
Under the dangerous waste regulations, accumulating more than 2.2 pounds of any P-listed waste, including nicotine, will make you a large quantity generator with additional requirements.
State-only dangerous waste nicotine
You can assume nicotine formulations that are not RCRA hazardous waste are state-only dangerous waste. To determine the waste is not a state-only dangerous waste, you must know the:
- Remaining concentration of the nicotine and other ingredients.
- Acute toxicity information of the nicotine and other ingredients.
Manage as either dangerous waste at a RCRA permitted facility or as excluded waste at an incinerator meeting the criteria of the Conditional Exclusion.