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Guidance for Managing Alcohol-based Hand Sanitizer

In July 2020, the Federal Food and Drug Administration issued a warning (leaves DEC website) about a sharp increase in hand sanitizer products (leaves DEC website) that are labeled to contain ethanol (also known as ethyl alcohol) but that have tested positive for methanol contamination. Methanol, or wood alcohol, is a substance that can be toxic when absorbed through the skin or ingested and can be life-threatening when ingested. The FDA is working with manufacturers to recall products. This guidance addresses actions that can be taken to dispose of recalled hand sanitizer.


Households with recalled hand sanitizer should take advantage of any return, takeback, or exchange programs for the products that they possess. More information on recalls (leaves DEC website) can be found on the FDA website. If takeback is not available, alcohol-based hand sanitizer generated by a household can legally be disposed of with regular trash, though DEC recommend that it be taken to a local household hazardous waste (HHW) collection event or facility. Residents can check with their municipality for available HHW collection events or facilities in the area.


Hand sanitizer is usually ignitable due to the high alcohol content and is considered to be a hazardous waste when discarded according to the Resource Conservation and Recovery Act (RCRA). There are a few options for proper management of expired hand sanitizer which are outlined below.

Prohibitions: Businesses are not allowed to put waste hand sanitizer down the drain because it's ignitable. RCRA hazardous wastes may not be put in the regular trash.

Recycling: Businesses are encouraged to take advantage of any return, takeback, or exchange programs for the products that they possess. Hazardous waste regulations provide an exemption for any amount of alcohol-based hand sanitizer that is returned to the manufacturer or to a recycler that can reclaim the material. This exemption is called the "6 NYCRR 371.1(c)(4)(iii) - commercial chemical products being reclaimed exemption." ​ Generators that send their hand sanitizer for recycling are required to notify DEC that they are taking advantage of an exemption using DEC's C7 Notification Form. Businesses can find reclaimers by searching online using the term "hand sanitizer recycler" or "ethanol recycler." Hand sanitizer managed under this exemption does not count towards hazardous waste generator status and does not need to be managed as hazardous waste. Hand sanitizer that has been recalled due to methanol contamination should either be sent back under the FDA recall or should be sent for disposal, as methanol-contaminated sanitizer is not able to be recycled by most hand sanitizer recyclers. If you have a different type of recycling or reuse option that you're considering, please contact DEC to confirm that such recycling or reuse is allowed under the RCRA regulations.

Disposal: Businesses are not allowed to bring their hand sanitizer to a household hazardous waste collection site or event unless they are a ​conditionally exempt small quantity generator of hazardous waste (CESQG). Many household hazardous waste sites and events do not accept hazardous waste from businesses, so CESQGs should always check with the entity running the site or event before they bring their hazardous waste there. If a CESQG is able to bring their hazardous waste to the household hazardous waste collection site or event, they can transport up to 220 pounds to the event without a DEC waste transporter permit. If reclamation or return to the manufacturer is not available, a business that disposes more than 220 pounds of alcohol-based hand sanitizer must ensure that the waste is transported under a hazardous waste manifest to an authorized hazardous waste disposal facility using a waste transporter that has a waste transporter permit from DEC. A business that is a CESQG may self-transport up to 220 pounds of this hazardous waste to solid waste management facilities that are authorized to receive it.

Questions from businesses may be sent to

DEC regulates waste streams produced by residents, businesses, and other organizations. Reuse, recycling, and other ways to reduce waste can save you money and are always preferred to disposal.

More about Waste Management:

  • Hazardous Waste Management - Information on all aspects of hazardous waste management.
  • Hazardous Waste Treatment, Storage, and Disposal - Managing the safe transfer, storage and disposal of hazardous waste materials.
  • Waste Transporters - The New York State Environmental Conservation Law requires that anyone engaged in the transportation of regulated waste generated or disposed of within New York State must possess a valid New York State Part 364 Waste Transporter Permit.
  • Solid Waste Management (SWM) Planning - State and Local Solid Waste Management Plans - set forth sustainable and comprehensive strategies for the following years
  • Solid Waste, Hazardous Waste, and Pesticide Forms - Forms used in the Division of Materials Management.
  • Materials Management Publications for Small Businesses - Publications for Small Businesses from the Division of Materials Management, Bureau of Waste Reduction and Recycling
  • Types of Solid Wastes - Information regarding the proper handling, disposal and treatment of various types of solid wastes, including Construction and Demolition Debris, Industrial/Commercial Waste, Waste Tires, Asbestos, Lumber Pressure Treated With Chromated Copper Arsenate, Regulated Medical Waste, Used Electronic Equipment, Fluorescent and HID Lamps, and Used Oil.
  • Solid Waste Management Facilities - General information on New York State's solid waste management facilities, including descriptions of each type of facility.
  • State Assistance Programs (Grants) for Waste Reduction, Recycling and Household Hazardous Waste Programs - Information on state assistance programs for capital projects, recycling coordinators and household hazardous waste.
  • Solid Waste Program - The New York State Solid Waste Management Program is administered as a regionalized program. All Part 360 permits, registrations, variances and other permit related determinations regarding the construction and operation of solid waste management facilities are issued on a regional basis.
  • Toxic Release Inventory - Information on toxic chemical releases and other waste management activities reported annually by certain covered industry groups as well as federal facilities.
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