Introduction
Ever since the EPA introduced hazardous waste manifests back in 1984, generators, transporters, and receiving facilities have had to work with paper printouts they would sign by hand. Those days are rapidly coming to an end.
Over the past two years, the agency has published and proposed a couple of rules regarding its e-Manifest system that seek to gradually transition all regulated entities from paper to electronic manifests. This article presents a summary of those rules, as well as recommendations for ensuring a smooth transition for when the deadline inevitably arrives.
Table of Contents
EPA's e-Manifest System: How it works, benefits, and fees
What is the EPA's Third Rule for e-Manifests?
What is the EPA's Paper Sunset Rule for e-Manifests?
Software Solutions for Managing e-Manifest Compliance After Transition
How does a waste manifest work and what is the EPA e-Manifest system?
Before we dive into the specificities of the EPA's new rules and the impact they will have 
on regulated entities, let's take a moment to outline the way waste manifesting is currently done.
Up until recently, a waste manifest was exclusively a paper form (or multiple forms) that accompanied any hazardous waste (or waste otherwise subject to federal or state regulations) to document its type and amount, instructions for handling it, and who shipped it (the generator), who transported it, and who received it (a Treatment, Storage, and Disposal Facility, or TSDF).
The form is officially called the "Uniform Hazardous Waste Manifest" and is available for purchase from any source approved to print and distribute them by the EPA Manifest Registry. Take a look at a sample manifest, instructions for completing it, or the list of approved printers.
When the generator transfers the waste to the transporter, they both sign a hard-copy of the Uniform Hazardous Waste Manifest to acknowledge the transporter has legal responsibility over it while in transit. Each side keeps a copy for their records, as mandated by law. The transporter delivers the waste to the waste processing facility, and both parties again sign the manifest as proof of delivery. The receiving facility then mails a copy of the final manifest to the generator for recordkeeping purposes.
With the launch of the national Hazardous Waste Electronic Manifest (e-Manifest) System in 2018, the EPA made it possible to digitize every step of the process.
Generators and transporters log into RCRAInfo to create, edit, view, or sign manifests. TSDFs can sign those manifests too, and they are the party responsible for submitting the final versions to the EPA. All of them can also file corrections to submitted manifests electronically.
Entities making use of a third-party waste management system like ERA's can create a manifest within their system, benefitting from automatic data retrieval (including RCRA IDs, DOT shipping names, and waste codes), and then simply click on a button to instantly submit it to RCRAInfo.
If you plan on starting to make use of this system, we highly recommend you read the fact sheet for your user type (ex: transporter) and watch the demo videos on the EPA website.
Benefits of Electronic Hazardous Waste Manifests
The primary justification for creating the e-Manifest system and enforcing its use
is the time and money saved by the transition. The EPA estimates that electronic manifests, once widely adopted by state and industry users, will reduce the annual burden associated with paper manifests by 175,000 to 425,000 work hours and over $50 million.
Beyond these cost savings, its users benefit from more timely access to accurate information on waste shipments, including notifications of discrepancies or any other shipment issues.
Collecting and compiling all shipment data into a single database is also an asset for external parties who wish to access it for non-industry purposes.
State and tribes inspectors and regulators have an easier time monitoring the compliance status of any entity conducting hazardous waste activity in their state/area. Similarly, the general public can view manifests and manifest data through e-Manifest's public-facing webpage (without having to register for the system), enabling them to make more informed decisions regarding pollution prevention and associated municipal/local regulations.
What are e-Manifest user fees?
Developing and operating the e-Manifest system has a cost, and the EPA recovers this cost by charging user fees.
For the fiscal years 2026 and 2027—starting October 1st, 2025, and ending September 30th, 2027—the user fees are:
- Scanned Image upload: $25
- Data + Image upload: $7
- Electronic Manifest (either Fully Electronic or Hybrid): $5
Note that the EPA is offering a discount on Data + Image uploads, relative to last fiscal year's cost, as a means to empower companies to save and incrementally invest in the electronic manifesting infrastructure that will soon be obligatory.
Understanding the EPA's Third Rule for e-Manifests: What Businesses Need to Know
At the time of writing, the EPA has promulgated three final rules on the e-Manifest system. The first two, the "One Year Rule" (2014) and the "User Fee Rule" (2017), both predate its launch and concern logistics of its use.
That makes the "Third Rule", published on July 26th, 2024, the first one with the explicit goal of increasing the system's adoption.
Summary of EPA Third Rule
Officially titled the "Final Rule for Integrating e-Manifest with Hazardous Waste Exports 
and Other Manifest-related Reports, PCB Manifest Amendments and Technical Corrections", the Third Rule's primary provision was obligating Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) to register into the e-Manifest system.
Small Quantity Generators are those that produce between 100 and 1,000 kilograms of hazardous waste per month. Large Quantity Generators produce over 1,000 kilograms of hazardous waste per month OR more than 1 kilogram of acutely hazardous waste (also per month).
Both LQGs and SQGs were required to be registered for access to the e-Manifest system starting January 22nd, 2025.
Another key provision is that, as of December 1st, 2025, domestic exporters are now responsible for submitting manifests accompanying exported hazardous waste to the e-Manifest system, as well as for paying the requisite user fee. This requirement follows the EPA's efforts to incorporate its Waste Import Export Tracking System into RCRAInfo.
Lastly, the Third Rule also integrates three other manifest-related reports into the system.
The Exception report must be filed by an LQG or SQG when they have not received a final signed manifest from the destination TSDF within the required timeframe of 60 days (deadline increased from 45 days for LQGs).
The Discrepancy report is submitted by a TSDF whenever there is a significant difference between the quantity and/or type of hazardous waste listed on the manifest and the waste it received. These facilities now have 20 days, rather than the original 15, to file it.
The Unmanifested Waste report is used by any facility that receives hazardous waste without the required shipping paper or manifest.
All three of these reports can no longer be sent to the EPA Regional Administrator or authorized State Director. Submission is done strictly on the e-Manifest platform and entails no federal filing fees.
Other key changes from Third Rule that improve hazardous waste reporting
Here are a few of the other important changes put in place by the EPA's Third Rule that hazardous waste generators and TSDFs should know about.
- TSDFs can now submit manifest data electronically and are therefore not required to mail copies of final signed manifests to generators
- The paper manifest form has been revised from a 5-copy form to a 4-copy form
- EPA and state regulators have been tasked with regulating entities to make data corrections. When requested, waste generators must make corrections to manifest data errors within 30 days
- Waste generators may discard the initial signed copy of a paper manifest once the final image is available in the e-Manifest system, unless they are working with a hybrid manifest, whose initial hand-signed copy must be retained for three years
Entities targeted for hazardous waste manifest system use
The EPA's Third Rule affects all Large Quantity Generators and Small Quantity Generators, transporters who wish to electronically create and sign e-manifests, domestic exporters of hazardous waste, and all facilities that receive manifested waste under federal or state law.
Brokers who wish to create manifests for their clients and state inspectors reviewing manifest data are also affected by some of the provisions in the rule.
However, it's worth noting that, despite being published mid-2024, the Third Rule has not yet been adopted by any US state (at the time of writing). Ratification into state law may bring about changes to the rule's requirements affecting the operations of the targeted entities.
What is the Paper Sunset Rule?
Having passed a rule to ensure all generators were registered to its e-Manifest system, 
the EPA took another vital step in the transition to electronic manifests: setting a date for phasing out paper manifests altogether.
Considering e-Manifests currently account for less than 1% of all manifests submitted to EPA's system since its launch in 2018, it's no surprise the agency felt a stronger stance on e-manifest adoption was necessary.
Summary of Paper Sunset Rule: Does e-Manifest replace all paper manifest requirements?
The "Paper Manifest Sunset Rule", proposed earlier this year (2026), aims to establish a fixed compliance date—two years after the publication of the final rule—on which hybrid and fully electronic manifests become the only legally valid mechanisms of tracking hazardous waste shipments under federal and state law.
Shipments initiated on or after that date would not be able to select the Scanned Image upload and the Data + Image upload options in the system, and using paper manifests would constitute a violation of 40 CFR Part 262 or 263, punishable by fines of up to $70,117 per day, per violation, or by criminal liability (for willful violations).
Generators, transporters, and TSDFs that are already relying on a waste management software to automate the e-manifesting process and communicate directly with RCRAInfo will be best positioned to absorb demand from other regulated entities looking to proactively adapt their cradle-to-grave (and cradle-to-cradle) process into an electronic system.
The rule also aims to subject entities not targeted by previous rulemaking to the same requirements as LQGs and SQGs. Namely, specific waste handlers, Very Small Quantity Generators (VSQGs) managing episodic events, hazardous waste transporters, PCB waste generators and transporters, and healthcare facilities and reverse distributors would all be required to register into the e-Manifest system and submit electronic reports.
The good news is that the additional burden of transitioning to an electronic system comes with the removal of the reverse burden: paper recordkeeping requirements under the RCRA and TSCA would become obsolete after the paper manifest sunset date is in effect. Regulated entities would only have to retain a copy of a manifest (for three years) when using a hybrid manifest and in the rare event that the e-Manifest system experiences an outage.
Other key changes introduced by the Paper Sunset Rule
PCB waste generators and transporters should be aware that they would be allowed to register for the e-Manifest system using an EPA ID obtained via either of the two forms they fill out: the "Site Identification Form" under the RCRA or the "Notification of PCB Activity" under the TSCA. EPA IDs would be mandatory even for currently exempt PCB waste generators, but thanks to the EPA's delayed compliance timeline, these entities could register as late as 24 months after the rule's publication, rather than on the effective date.
PCB annual reports would also transition to electronic submissions, eliminating the need for physical address submissions.
Similarly, healthcare facilities and reverse distributors would be required to submit exception reports electronically. The same would apply to manifest data corrections, which would have to be submitted to the e-Manifest system within 30 days of the regulator's request; this requirements extends to VSQGs managing episodic events as well. Moreover, confirmation of delivery of hazardous waste pharmaceuticals would be extended by 10 days, to 45.
Who is required to use e-Manifest after Paper Sunset Rule?
The Paper Sunset Rule affects practically all entities currently abiding by the EPA's hazardous waste regulations, as it does not expand the scope of entities subject to manifesting or add requirements to non-manifested waste. These entities are:
- Large Quantity Generators (LQGs)
- Small Quantity Generators (SQGs)
- Very Small Quantity Generators (VSQGs) managing hazardous waste from episodic events
- Hazardous waste transporters
- Treatment, Storage, and Disposal Facilities (TSDFs)
- Healthcare facilities and reverse distributors subject to the hazardous waste pharmaceutical requirements
- Generators, transporters, storers, and disposers of PCB waste
Software Solutions for Managing e-Manifest Compliance After Transition
Don't worry if you are one of the vast majority of regulated entities that is still using paper manifests for its hazardous waste shipments. The Paper Sunset Rule has a number of hurdles to clear before becoming official, giving you ample time to revamp your operations.
If you're a waste generator just starting out, your first order of business should be conducting an audit to determine which of your company's sites/facilities are already registered into the EPA's e-Manifest system and which ones aren't. For those pending registration, come up with a remediation plan, obtain EPA IDs where necessary, and communicate with the employees overseeing the waste processes at those sites to put the plan in motion.
Assuming there are sites not yet utilizing e-Manifests, the crucial thing to do would be to evaluate the entire lifecycle of your hazardous waste and pinpoint every instance where a paper manifest is created, signed, or conveyed to another party.
Make a list of each of these and the stakeholders involved, including transporters and disposal partners. You will have to work with each stakeholder at every point of paper manifest use to implement the remediation plan, which might even entail switching transporters or receiving facilities (TSDF) if these lack a concrete transition timeline.
Arguably the most important measure to guarantee a successful change would be to train all responsible personnel to use the e-Manifest system according to the requirements for their user type.
Site Managers must be capable of supervising user access, creating and signing manifests, viewing invoices and compliance records, and handling data corrections. All other employees participating in hazardous waste shipments should at least know how to access the EPA's system to view and sign manifests.
Lastly, companies making use of an environmental or waste management software should speak to their providers if they don't already integrate with the e-Manifest system via the EPA's published API.
Nowadays, there are plenty of EHS software options out there designed to expedite the submission of electronic manifests to the EPA. ERA's waste management module, for example, not only makes the manifest creation and digital signature process seamless, but it also combines all relevant information into a single platform.
Our software automatically retrieves EPA IDs, the RCRA IDs of any generator, transporter, or treatment facility, DOT shipping names, packing groups, hazard classes, UN numbers, waste codes, and any other regularly inputted data, reducing the administrative burden of an e-manifest to a simple form that can be submitted to the EPA with the click of a button. All for as little as $99/year USD for a single emission unit/waste stream.
See for yourself how ERA's software can save you time and money in the lead-up to the Paper Sunset Rule's compliance date by scheduling a discovery call with one of our Project Analysts.
Contributing Scientist:
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