Hazardous Waste Manifest System (e-Manifest) Support

What is Hazardous Waste Manifest System?

The Hazardous Waste Manifest System is a federally regulated tracking program under the Resource Conservation and Recovery Act (RCRA) that follows hazardous waste from point of generation through transportation to final treatment, storage, or disposal facility (TSDF). This is jointly overseen by the Environmental Protection Agency (EPA) and Department of Transportation (DOT).

This “cradle-to-grave” process refers to the continuous tracking of hazardous waste from its creation to its final disposal. The main purposes are to:

• • Provide legal record of hazardous waste management
  • Allow regulatory agencies to monitor waste movement and compliance
  • Prevent illegal dumping and mismanagement
  • Verify waste reaches intended destination
  • Support enforcement actions as necessary

UPDATE: Final Third Rule & e-Manifest System

The e-Manifest was launched in July 2018 to modernize the manifest process through EPA’s RCRAInfo system. This system digitalizes the Unform Hazardous Waste Manifest (UHWM), the standardized document for any hazardous waste shipment off-site of a TSDF.

The “Final Third Rule” took effect in January 2025 and represents the third major set of amendments issued by the EPA to improve the e-Manifest program. Key changes include:

1. 1. Update Exception & Discrepancy Timeframes
      1. Large Quantity Generator (LQG)
         1. Must contact the transporter or TSDF if the final signed copy is not received within 45 days
         2. Must file an exception report within 60 days of shipment if no final copy is received
      2. Small Quantity Generator (SQG) – Maintain the existing 60-day window to file an exception report if no final copy is received
   2. Discrepancy Investigation & Report Timeline
      1. TSDFs must investigate and attempt to reconcile any significant discrepancy in waste type or quantity within 20 days of receiving the waste (40 CFR §264.72(c)(1)).
      2. If the discrepancy cannot be resolved within 20 days, the TSDF must immediately submit a Discrepancy Report describing the discrepancy and reconciliation efforts, along with a copy of the manifest or shipping paper, to EPA e-Manifest system (40 CFR §264.72(c)(2)).
      3. Note: The 20-day period applies to reconciliation efforts, not to the timing of the report submission.
   3. Mandatory e-Manifest Registration for Certain Generators
      1. SQG and LQG must have active e-Manifest accounts
      2. VSQGs and PCB-only generators generally not required unless specified by state
   4. Electronic Correct Process – All corrections processed through e-Manifest
   5. EPA User Fees – Per-manifest fees are required for 2026 and 2027 submissions

Who Uses e-Manifest?

Categorized by generators:

1. 1. Large Quantity Generators (LQG) – Required to register for e-Manifest and comply with all reporting timelines
   2. Small Quantity Generators (SQG) – Required to register for e-Manifest
   3. Very Small Quantity Generators (VSQG) – Not federally required to register unless state rules apply, but still responsible for ensuring proper disposal
   4. Polychlorinated Biphenyl (PCB) Only Generators – Not federally required to register for e-Manifest unless state regulations apply, but proper Toxic Substances Control Act (TSCA) documentation and disposal requirements still apply
      1. If mixed with RCRA hazardous waste, states may require e-Manifest submissions

What is on the Manifest System?

Manifest requirements vary by state, but typically include:

1. 1. Generator Information
      1. EPA ID number, name, address, phone, emergency contact
      2. Manifest tracking number
      3. Waste description (codes, container type, weight/volume)
      4. Special handling instructions
      5. Certification (signature and date)
   2. Transporter Information
      1. Name
      2. EPA ID
      3. Signature and date at each transfer
   3. Designated Facility Information
      1. Name, address, phone, EPA ID
      2. Treatment and disposal codes
      3. Certification of receipt