EPA Hazardous Waste Manifest (e-Manifest) Now in Effect
Since June 30, 2018, the Environmental Protection Agency (EPA) has required digital tracking for hazardous waste manifest shipments across the US. This includes state-regulated hazardous waste as well as federally-regulated Resource Conservation and Recovery Act (RCRA) waste. The EPA’s e-Manifest system digitizes the manifest process, helping standardize hazardous waste manifests and centralize hazardous waste tracking information in one easily-accessible database. This program eases safety and compliance for generators and treatment, storage, and disposal facilities (TSDFs) alike.
The EPA’s third “Final Rule” for e-Manifests goes into effect starting in January 2025 and includes a number of updates to the regulations. Triumvirate Environmental continues to evaluate EPA e-Manifest program updates and will work to ensure the transition into these new regulations is as seamless as possible for our clients.
What is e-Manifest?
The term “e-Manifest” describes the digital tracking system for hazardous waste shipments across the US. This digital tracking system applies to state-regulated hazardous wastes, RCRA wastes, and Toxic Substances Control Act (TSCA) wastes, for both imported and exported wastes.
This electronic manifest system seamlessly tracks waste from the time it leaves a generator, through each transporter, and up until it reaches the receiving facility.
Who regulates/mandates e-Manifest?
The EPA regulates manifests across the US, and mandates digital tracking via e-Manifest.
Who does e-Manifest apply to? Who is responsible for filing?
Very Small Quantity Generators (VSQGs) and Polychlorinated Biphenyl (PCB) generators are not required to register for e-Manifest—all other generators, transporters, and receiving facilities are. Since January 22, 2025, Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) are required to register for e-Manifest through RCRAInfo. The receiving facility must submit the electronic manifest to the e-Manifest system and pay any applicable fees.
What is RCRAInfo?
RCRAInfo is a national EPA database that tracks information about all hazardous waste handlers (generators, transporters, and receiving facilities) and their hazardous waste management activities.
What information should be included on a hazardous waste manifest?
A properly prepared uniform hazardous waste manifest will include waste details, waste handling instructions, signature lines from all involved parties, and more. For a complete list of necessary hazardous waste manifest information, refer to the EPA's website.
When did e-Manifest start?
e-Manifest went into effect on June 30, 2018.
What are the relevant e-Manifest deadlines for 2025?
A number of final third rule updates take effect starting January 22, 2025. December 1, 2025 marks the second and final regulatory deadline for the final third rule updates.
How do I register for e-Manifest?
Register for e-Manifest by first creating an account with RCRAInfo, using your facility’s EPAID number.
How soon after receiving a manifest do I need to submit to e-Manifest?
Receiving facilities must submit an electronic manifest within 30 days of receipt. Receiving facilities are the only entities that must upload manifests to the e-Manifest system; generators do not upload any manifests.
How long should waste manifests be maintained?
Generators and transporters must retain electronic hazardous waste manifests for at least three years. Receiving facilities must retain hazardous waste manifests for longer, depending on their specific situation.
What waste is manifested? What is unmanifested waste?
State-regulated hazardous wastes, RCRA wastes, and Toxic Substances Control Act (TSCA) wastes must be manifested. Household hazardous wastes (HHWs) are generally exempt from manifests.
Unmanifested wastes are hazardous wastes that were generated and not reported on the uniform hazardous waste manifest.
What is a manifest discrepancy report?
A manifest discrepancy report outlines any inconsistencies between details on a shipping manifest.
How does e-Manifest apply to wastes that are required to be manifested in the generator state, but not the receiving state?
Waste required to be manifested by federal or state law falls under the e-Manifest regulation. The regulation includes waste that is required to be manifested in the generator state only or the receiving state only. It is important to know the state regulations in both the state where you are generating the waste and the state where your facility is receiving that waste at the end of your shipment. Both of those fall under the scope of e-Manifest.
Can a transporter, broker, or receiving facility prepare and sign e-Manifests on behalf of the generator?
With fully electronic manifests, the transporter, broker, and receiving facility can prepare and sign manifests on behalf of generators as long as they have been properly certified as either a preparer or a certifier on those manifests by the site manager for the generator's site. They need to have the appropriate permissions in place and the correct EPA ID number in RCRAInfo.
Additional Resources
Last Updated: January 30, 2025
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