sealed vessels under a certain capacity can be recycled normally by most companies. we dont often do it because its cumbersome, and larger holding tanks are safer than random barrels that get forgotten and dont have leak alarms or overflow alarms. large tanks require certification, samples, and periodic checks to make sure we arent secretly filling them full of nacho cheese or something and not waste oil.
that having been said, we will still require an EPA site inspection, and im pretty sure when that happens theyll be rather accommodating to any lapses in certification. Id dread having to check that voicemail box though.