The US EPA utilizes the e-Manifest system to provide electronic tracking for hazardous waste shipments, streamlining cradle-to-grave tracking for generators, transporters, and receiving facilities. Treatment, storage, and disposal (TSD) facilities and receiving facilities are responsible for submitting data to the US EPA for all manifested waste shipments.
Mandatory Account Registration for SQGs and LQGs
On June 28, 2024, the EPA published the e-Manifest final third rule, changing aspects of hazardous waste regulations under RCRA and utilizing the e-Manifest system. Effective January 22, 2025, there are changes that will change how Small Quantity Generators (SQGs) and Large Quantity Generators (LQGs) use the e-Manifest system.
SQGs and LQGs are required to have at least one user with e-Manifest certifier or site manager registration access to the E-manifest system. These changes require that LQGs and SQGs obtain their final signed manifest copies from the EPA e-Manifest system and electronically submit data corrections to the system, including when requested by EPA or your state. Beginning December 1, 2025, generators will also use e-Manifest to electronically submit Exception Reports. Under federal regulations, Very Small Quantity Generators (VSQGs) and Polychlorinated Biphenyl (PCB) generators are not required to register.
Additional EPA Updates
There have been changes to the Exception and Discrepancy Reporting Time Frames. Large Quantity Generators will now have additional time to complete the exception reporting requirements for delayed final manifest copies. The Exception and Discrepancy Reporting Time Frame Changes are as follows:
Report | Scenario | Old Time Frame (Days) | New Time Frame (Days) |
---|---|---|---|
Exception | LQG must initiate search for unsubmitted manifest and file an Exception Report | 35/45 | 45/60 |
Discrepancy | TSDF must submit a Discrepancy Report | 15 | 20 |
For data corrections, generators must respond to EPA or state correction requests within 30 days.
TSDFs are no longer required to mail back final copies of the manifests to the generator, they are accessible in the E-manifest system. The new manifest format will now be a 4-part form. The new form should be available January 22, 2025. The existing form can still be used until December 2025.
- Page 1 (top copy): Designated facility or U.S. Exporter to the EPA’s e-Manifest system
- Page 2: Designated Facility to Generator
- Page 3: Transporter facility copy
- Page 4: (bottom copy): Generator’s initial copy
Helpful links:
EPA CDX Support For Accessing Their Systems
Fact Sheets for e-Manifest Stakeholders