• You are correct that the universal waste regulations are an option to managing a waste as a hazardous waste.  Therefore, in order to be a universal waste it must first meet the definition of a hazardous waste.
• USEPA (and state) regulations allow for the generator of a waste to determine if it is a hazardous waste based either on generator knowledge (no testing but other forms of information) or analysis of a representative sample by a lab using the approved test methods.  Either method is acceptable.  Read:  The Hazardous Waste Determination
• the Toxicity Characteristic Leachate Procedure (TCLP) is an analytical method used to determine the leachable concentration of toxins in a representative sample of a waste.
• In the case of a manufactured article like an LED bulb it is highly unlikely it will be possible to collect a representative sample.  Therefore, analysis may not be possible.
• Instead, I suggest you refer to the Safety Data Sheet or technical data sheet or some other manufacturer information for the bulb.  It may indicate that the LED is a hazardous waste.
• USEPA regulations at 40 CFR 273.9 define a lamp as:

Lamp, also referred to as “universal waste lamp” is defined as the bulb or tube portion of an electric lighting device. A lamp is specifically designed to produce radiant energy, most often in the ultraviolet, visible, and infra-red regions of the electromagnetic spectrum. Examples of common universal waste electric lamps include, but are not limited to, fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide lamps.

• Though not cited in the, “…include, but are not limited to,…” it is reasonable to think an LED is included in the definition of a universal waste lamp.

My suggestion:  Manage your LED bulbs as a universal waste.  Base the determination on generator knowledge.  Analysis is not required.  Maintain documentation of your determination.

I hope this helps.  Please contact me with any other questions.

And that did it!

With technology changing as fast as it does, there may be another type of lamp or bulb in use by the time you read this article.  USEPA defines a universal waste lamp broadly enough, “…include but are not limited to,…” to include pretty much any bulb or tube, “designed to produce radiant energy,…”  I will add that I have never had experience with a generator being told they can’t manage a type of lamp – even incandescent – as a universal waste.  I have had experience with generators facing real penalties for not providing the required initial and annual training for their hazardous waste personnel.