Illinois: Pollution Control Board Adds Paint Waste to Universal Waste Rules

As of August 27, 2025, Illinois Pollution Control Board expanded its hazardous waste rules to include paint and paint-related waste as universal waste.

Manufacturers selling architectural paint in the state must run stewardship programs to collect leftover products.

The change makes managing oil-based paints easier by placing them under the universal waste framework. This affects paint producers, retailers, and facilities handling paint disposal.

The new system reduces compliance burdens while promoting safer and more consistent paint waste management.

On September 12, 2025, in the Illinois Register, the Pollution Control Board adopted changes to hazardous waste rules to align with two recent state laws.

The Paint Stewardship Act requires manufacturers of architectural paint sold at retail to create and operate post-consumer stewardship programs. Another law allows oil-based paints to be collected and managed as universal waste.

What changed

The Illinois Environmental Protection Agency (IEPA) proposed amendments to add paint and paint-related waste (PPRW) to the existing list of universal wastes. This list already includes batteries, pesticides, mercury equipment, lamps, certain household wastes, and very small generator wastes. By adding PPRW, Illinois makes paint waste subject to the same streamlined requirements that apply to these other universal wastes.

Impact on companies

• Paint manufacturers and retailers must participate in stewardship programs, ensuring leftover architectural paints are collected and managed.
• Waste facilities and businesses handling paint benefit from simpler compliance rules under the universal waste system.
• Instead of full hazardous waste management obligations, they can follow the lighter requirements already applied to other universal wastes.
• The change encourages more consistent collection and disposal of leftover paints, reducing risks of improper handling.

Deadlines and enforcement

The law required IEPA to propose rules within 60 days of its effective date, and the Board had 180 days after receiving the proposal to adopt them. These steps have now been completed. The Pollution Control Board enforces the rules, and companies must comply with the new requirements as of September 12, 2025.

Reason for the change

The goal is to make paint disposal safer, easier, and more environmentally sound. Paint stewardship programs shift responsibility to producers, while the universal waste classification reduces administrative burdens for businesses and improves collection efficiency.

Compliance support

Companies can refer to Illinois Pollution Control Board guidance and IEPA resources on universal waste management for detailed instructions on how to set up paint stewardship programs and meet the new requirements.

Sources :

Adopted Rules: Pollution Control Board, Illinois Register Vol. 49 Issue 37 (September 12, 2025)