Retailers should implement hazardous waste management plans, even for simple consumer goods, as California, New York and other states launch aggressive enforcement campaigns.

In recent years, California prosecutors have accelerated enforcement actions against California retailers who are alleged to have improperly discarded seemingly benign retail items that may nevertheless classify as “hazardous waste” under federal or state law. The California Attorney General’s Office and local district attorneys — who can use the proceeds from multimillion-dollar settlements to fund their internal operations — have settled with a number of big-box retailers that operate in-state facilities. These retailers include home improvement stores, pharmacies, supermarkets, warehouse stores and even a cable provider. Pursuant to these public settlements, California retailers have been forced to overhaul their hazardous waste management practices and pay the government tens of millions in civil penalties.