The U.S. EPA’s View on Solvents Used As Ingredients

April 1, 2021


The use of chemicals for their solvent properties is one of the most commonly employed practices in various industrial manufacturing processes and applications.  These chemicals may be harmful to human health and the environment.  The residues that are discarded after solvents are used for their intended purpose become a solid waste.  Because of their toxicity, they are regulated as listed hazardous wastes by the EPA under the provisions of RCRA. 

In many instances, chemicals that have solvent properties are also commonly used in industrial applications as ingredients in the manufacturing process.  RCRA is concerned with only regulating these chemicals solely used for their solvent properties when discarded after being used.

Solvents and Spent Solvents Defined

RCRA does not include a regulatory definition for solvents.  However, the language in the EPA’s Federal Register (see 50 FR 53315, December 31, 1985) states:

“First, the spent solvent listings cover only those solvents that are used for their "solvent" properties-that is, to solubilize (dissolve) or mobilize other constituents.  For example, solvents used in degreasing, cleaning, fabric scouring, as diluents, extractants, reaction and synthesis media, and similar uses are covered under the listing (when spent).  A solvent is considered "spent" when it has been used and is no longer fit for use without being regenerated, reclaimed, or otherwise reprocessed.”

RCRA defines a spent material in 40 CFR § 261.1(c)(1) as: 

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