Nicotine, cannabis, and vape waste

Nicotine is a P-listed acute hazardous waste (P075) under the Dangerous Waste Regulations. The P-listed code applies to pure or commercial grade unused products where the listed chemical is the sole active ingredient.

Nicotine vape devices

Because nicotine is P-listed (P075), the residues inside the vape cartridge (container), are also P-listed (P075) even if the device is empty and fully used. If the battery cannot be separated from the vape device, the device will also designate with the hazardous waste codes of D001 (ignitable) and D003 (reactive).

FDA-approved over-the-counter nicotine replacement therapies

While most nicotine wastes are a P-listed acute hazardous waste (P075), FDA-approved over-the-counter nicotine replacement therapies (e.g., patches, gums, and lozenges) DO NOT designate as an an acute hazardous waste (P075). However, you must still fully designate these wastes to determine if they are a Washington state-only dangerous waste. 

Designate all cannabis wastes. Be aware that some wastes may designate solely as a Washington state-only dangerous waste. For example, any processed, concentrated cannabis waste with 10% THC or greater will designate as a state-only toxic waste (waste code WT02 based on book designation).

If the battery cannot be separated from the cannabis vape device, the device will also designate with the hazardous waste codes of D001 (ignitable) and D003 (reactive).

Batteries separated from a vape device can be managed as universal waste. Universal waste is a common category of dangerous waste that has simpler rules to follow, and allows for recycling of certain wastes, such as batteries.

If batteries are not removed from vape devices, they need to be managed as dangerous waste with the D001 and D003 waste codes.

Single-use (disposable) nicotine vapes are often opaque, meaning you cannot see inside. The container is usually hidden within the vape housing. To count how much nicotine (and therefore acute hazardous waste) you have from these vapes, you can either log the exact amount that a specific vape contains at its fullest or count the maximum amount possible.

Which option should you choose?

Counting the exact amount gives you precision but could take time and research, while using the maximum amount is faster and can make your count easier. You are allowed to use both options if desired. Just ensure you log everything accurately.

Helpful math

Most vapes are sold in milliliters (mL):

• 1 mL = 1 gram of nicotine.
• 998 grams of nicotine = 2.2 pounds of acute hazardous waste.

Option 1: Count the exact amount

Not all disposable vapes come in the same size. Most are sold with 1 to 2 mL of nicotine. Other larger devices can contain 6 mL or more. To count the exact amount, look for the amount printed on the product. If it says it’s a 1 mL vape, then you have 1 gram of nicotine. Even if the vape seems empty or partially empty, count how much the vape holds at its fullest.

If you can’t find the amount on the product itself, look up the specific vape model information. If you still can’t find the exact amount, use Option 2 and count the maximum.

Option 2: Count the maximum amount

Generally, the maximum amount a disposable vape can contain is 18 mL (which is 18 grams of nicotine). To use this method, you multiply every disposable vape onsite by 18.

For example, if you have 50 disposable vapes (50 x 18 grams), you have 900 grams of nicotine.

Refillable (or reusable) vapes often have a transparent window, meaning you can visibly see the tank that holds the e-liquid (nicotine-containing liquid). They are also bigger than disposable vapes. To count how much nicotine (and therefore acute hazardous waste) you have from these vapes, you can either log the exact amount that a specific vape contains or count the maximum amount possible.

Which option should you choose?

Counting the exact amount gives you precision but could take time and research, while using the maximum amount is faster and can make your count easier. You are allowed to use both options if desired. Just ensure you log everything accurately.

Helpful math
Most vapes are sold in milliliters (mL):

• 1 mL = 1 gram of nicotine.
• 998 grams of nicotine = 2.2 pounds of acute hazardous waste.

Option 1: Count the exact amount 

Not all refillable vapes have the same tank size. Some hold 2 mL while others can hold upwards of 10 mL or more. To count the exact amount, look for the tank size printed on the product. If you can’t find the tank size on the product, look up the specific vape model information. If you still can’t find the exact amount, use Option 2 and count the maximum.

You are allowed to estimate the amount inside (provided you know how big the tank is), since you can visibly see it. For example, if you have a refillable vape with a 5 mL tank, and it appears the liquid is half used, you can log 2.5 grams of nicotine.

Option 2: Count the maximum amount

Generally, the maximum amount a refillable vape can contain is 24 mL (which is 24 grams of nicotine). To use this method, multiply every refillable vape you have onsite by 24.

For example, if you have 10 refillable vapes (10 x 24 grams), you have 240 grams of nicotine.

To track your nicotine vape waste, we recommend that you log the following:

• Date you accumulated (acquired) the vape waste.
• Type of vape device.
• Daily total nicotine weight in grams (g).
• Running total (this is the most important). This tells you how much you have onsite.
  Note: Reset your running total when you ship your waste off-site, but continue to count your monthly total.

For example:

Be sure to:

• Keep all logs of nicotine vape waste.
• Ship waste off-site before totals exceed 998 grams or 2.2 pounds.

Nicotine vape devices (with or without batteries) must be disposed of as dangerous waste. Proper disposal will depend on the type of waste and your generator category. Most dangerous waste generators choose to hire a waste service provider, however small quantity generators (SQGs) can dispose of nicotine waste at moderate risk waste (MRW) facilities if they accept this type of waste from businesses.

Many health care facilities (and those that qualify as health care facilities) often choose to manage nicotine wastes as dangerous pharmaceutical waste under the special requirements for the management of dangerous waste pharmaceuticals (WAC 173-303-555).

What’s the benefit of managing nicotine as dangerous pharmaceutical waste?

These rules allow for greater flexibility, such as consolidation and longer accumulation periods. Go to our Managing Pharmaceutical Waste webpage for more details or take a look at our How Do I Manage My Dangerous Waste Pharmaceuticals? poster for a visual breakdown.

Nicotine-containing wastes, such as nicotine-containing oral pouches, are either:

• Dangerous waste.
• Washington state-only extremely hazardous dangerous waste. 

For any FDA-approved over-the-counter nicotine replacement therapies, follow the guidance on our Managing Pharmaceutical Waste webpage. 

Note: We don’t regulate waste that contains tobacco.

Batteries separated from vape devices can be managed as universal waste. Universal waste is a common category of dangerous waste that has simpler rules to follow, and allows for recycling of certain wastes, such as batteries.

Some cannabis vape devices have an easily removable battery which can be separated by simply unscrewing it. If the battery is removed, you can dispose of the battery as universal waste and the cannabis portion can be disposed of in-state (in accordance with the Dangerous Waste Regulations and DEA requirements).

However, be aware of the following:

• For disposable cannabis vapes, we recommend you hire a waste service provider to separate the battery from the vape device.
• If you don't remove the battery, out-of-state options may be available if you follow DEA transportation and disposal requirements.

There are several options for cannabis vape waste disposal where the batteries have been removed:

• Small quantity generators can dispose of cannabis vape devices (without any batteries) in the garbage.
• Medium or large quantity generators can either hire a treatment, storage, and disposal facility to treat and dispose of this waste or manage it as special waste and dispose of it at a local solid waste landfill that accepts these items. Read our Focus on: Special Waste Exclusion for more details.
• Any health care facility or dangerous waste generator can manage this waste under a conditional exclusion (WAC 173-303-071(3)) or conditional exemption (WAC 173-303-555(7)), which requires disposal at a permitted incinerator that meets certain criteria. A vendor authorized by the DEA to handle Schedule I controlled substances may require special transport and witness destruction of this waste.

There are several options for non-vape cannabis waste disposal:

• Small quantity generators can dispose of non-vape cannabis wastes in the garbage.
• Medium or large quantity generators can either hire a treatment, storage, and disposal facility to treat and dispose of it, or manage it as special waste and dispose of them at a local solid waste landfill that accepts these items. Read our Focus on: Special Waste Exclusion for more details.
• Any health care facility or dangerous waste generator can manage it under a conditional exclusion (WAC 173-303-071(3)) or conditional exemption (WAC 173-303-555(7)), which requires disposal at a permitted incinerator that meets certain criteria. A vendor authorized by the DEA to handle Schedule I controlled substances may require special transport and witness destruction of this waste.

Batteries separated from vape devices can be managed as universal waste. Universal waste is a common category of dangerous waste that has simpler rules to follow, and allows for recycling of certain wastes, such as batteries

We don't regulate:

• Nicotine cigarettes or raw tobacco.
• Waste cannabis plant material not contaminated with solvent.
• Waste cannabis edibles or e-liquids with concentrations under 10% THC.

Cannabis vape liquids are generally thicker, more viscous, and darker in color than nicotine vape liquids, which are generally thinner and lighter in color.

If the contents aren’t visible or you’re unsure, you can use the label on the vape device to look it up online.

Follow EPA’s vape waste storage guidance for schools and small businesses on how to safely store collected vape products before disposal. In general, you can store:

• Vape waste with embedded batteries in a closed metal container, such as a 5-gallon metal bucket with a lid.
• Vape waste without embedded batteries in a closed plastic or metal container, such as a 5-gallon bucket with a lid.

Yes, however, due to complications with disposal, we recommend storing nicotine and cannabis waste in separate metal containers. Cannabis vape wastes are not accepted at some treatment, storage, and disposal (TSD) facilities in Washington. Because cannabis is a Schedule I controlled substance, cannabis waste is not allowed to cross state lines, even between two states where it’s legal, unless approved from the Drug Enforcement Agency (DEA) TSD facilities that don’t accept cannabis waste will likely screen this out and send the entire waste shipment back to you or charge you high fees for another facility to treat and dispose.

Your generator category is based on the amount of dangerous waste you have. Removing the batteries and managing them as universal waste lessens your overall monthly dangerous waste count and saves you money on waste disposal fees.

However, for disposable vape devices, we recommend you hire a waste service provider to remove these batteries. If you choose to remove batteries yourself, review EPA’s vape waste webpage for safety and best management practices. The casing of each individual battery cell must not be breached in the removal process. It must remain intact and closed.

Nicotine vapes contain hazardous waste — lithium-ion batteries and nicotine:

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

Nicotine is an acutely toxic listed waste and dangerous waste pharmaceutical. Therefore, it’s not allowed to be disposed of down the drain or in the standard garbage.