The U.S. Environmental Protection Agency (EPA) established the e-Manifest system as an electronic tracking system for hazardous waste shipments. The system officially launched in 2018, and the Third Final Rule (an amendment designed to encourage the adoption of the electronic system) was published on July 26, 2024. A compliance deadline of January 22, 2025, was set. However, although the final rule became effective on that date, EPA needs more time to implement certain e-Manifest system changes related to the rule. (See below for more details.)
Here’s what you need to know about requirements and registration for the e-manifest system.
What the Hazardous Waste e-Manifest System Does
EPA’s e-Manifest system streamlines the traditional paper manifest process, making it more efficient, transparent, and accessible for all parties involved. The initiative aims to modernize waste tracking and improve environmental oversight. The benefits include reduced administrative burden including cost savings and improved tracking of hazardous waste shipments through efficiency and transparency.
What the Hazardous Waste e-Manifest System Means for Hazardous Waste Generators
Use of the e-Manifest system is mandatory for hazardous waste generators. All Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) must create, submit, and track hazardous waste manifests electronically through the system or ensure their transporter uses the system. Very Small Quantity Generators (VSQGs) are generally not required to register for the system; however, state regulations may vary so it’s important to check your local regulations. If your facility is a VSQG and you would like to receive final signed manifests for hazardous waste shipments, you should register. Also, VSQGs may have an “episodic event” with sudden generation of a high level of hazardous waste. Such an event could require an electronic manifest.
How Hazardous Waste Managers Should Use Electronic Manifests
Waste Managers must register on EPA’s RCRAInfo platform to create or access e-Manifests. Proper training for staff is essential to ensure accurate data entry and compliance. Some states have state-only wastes subject to RCRA manifest requirements under state law. Alabama and Tennessee do not regulate any wastes as hazardous that are not federal hazardous waste. Both states have adopted all EPA rules exempting or excluding wastes from RCRA manifest regulations.
Consequences of Not Using the e-Manifest System
Failure to use the e-Manifest system may result in violations of federal hazardous waste regulations under the Resource Conservation and Recovery Act (RCRA). Companies could face monetary fines, enforcement actions, or both, depending on the severity of the non-compliance. Without proper manifest documentation, companies may encounter shipment delays or rejection of waste at treatment facilities.
If a company or facility has not yet registered, it is essential to do so immediately to avoid further non-compliance risks. Both small and large quantity generators are subject to this requirement. Companies should also conduct a compliance audit to ensure their hazardous waste management practices align with the e-Manifest requirements.
Compliance Date Pushed for Certain Final Regulations
To implement certain e-Manifest system changes and to have adequate time to work with State regulating agencies, EPA has established a later compliance date of December 1, 2025 for some regulations. Specifically, these include regulations associated with the collection of hazardous waste export manifests, use of electronic manifests for hazardous waste export shipments, and the use of electronic exemption, discrepancy, and unmanifested waste reporting. The delayed compliance ensures completion of system updates and necessary preparations. (All affected entities must comply with existing manifest requirements for hazardous waste exports and reporting until and on November 30, 2025.)
The EPA’s e-Manifest system represents a significant shift toward modernizing hazardous waste tracking. By ensuring compliance, educating employees, and leveraging the system’s benefits, hazardous waste generators and managers can improve operational efficiency, reduce environmental risks, and maintain regulatory adherence.
Need help understanding and implementing the EPA e-Manifest system? TriHaz can help. Send us a message here or call 256-464-2546 ext 1 for customer service.