If a waste listed as a universal waste is not recycled, may it still be managed as a universal waste?

Yes, the universal waste rules in ch. NR 673, Wis. Adm. Code and the August 2006 Wisconsin-Specific Universal Waste Guidance Memo allow reduced hazardous waste management standards for hazardous waste batteries, certain pesticides, mercury thermostats and mercury containing equipment, antifreeze and fluorescent lamps.

The universal waste rules and the associated guidance memo are intended to facilitate collection and proper management of these types of wastes; however, the wastes are not required to be recycled to qualify as universal waste.