e-Manifest Usage

On June 30, 2018, the US EPA launched a system that provides electronic tracking for hazardous waste shipments (“e-Manifest”). This system streamlines cradle-to-grave hazardous waste tracking for generators, transporters, and receiving facilities.

Use of the e-Manifest system is optional. Treatment, storage, and disposal (TSD) facilities and receiving facilities are responsible for submitting data to the US EPA for all hazardous waste manifested shipments. Manifests may be submitted through regular mail (paper manifest), by scanning a PDF image to US EPA, by a hybrid of scanning and entering data, or by creating and submitting complete electronic e-Manifests in the system.

Heritage-Crystal Clean, LLC (HCC) will continue to use paper manifests after the effective date of June 30, 2018 as the DOT still requires paper manifests for the transport of hazardous materials. HCC considers this course of action to be the most stable, safe, and compliant. This process is like our previous manifest practices and should not require additional actions by our customers or transporters. HCC will transition to a fully electronic e-Manifest when we are confident that our customers and receiving facilities are fully prepared.  

Use of e-manifest

  • e-Manifest systems will affect everyone including generators, transporters, receiving facilities, US EPA, and state agencies.
  • e-Manifest data is required to be submitted by the receiving facility to the US EPA within 30 days of waste receipt. This applies whether the generator uses the e-Manifest system or paper manifests.
  • The manifest is the only paperwork that should be submitted to the US EPA (e.g. no LDRs).
  • Manifest data will be made available to the public 90 days after receipt to the US EPA.
  • Receiving facilities are required to submit the data for state-regulated waste even if the waste is not regulated by the destination state.
  • No claims of Confidential Business Information (CBI) are allowed with limited exceptions (e.g. Homeland Security).

Manifest Form

The USA EPA requires a new, 5-copy paper manifest under the new e-Manifest requirements. The new 5-copy manifest will merge pages 1 and 2 into page 1 for submission to the US EPA (i.e., State copies are no longer required). Within 90 days of receiving manifest data the EPA will provide access to states, registered generators/customers and transporters. To view the manifest data, HCC encourages all parties to register with the US EPA’s e-Manifest system.

Generator Registration

This link to the US EPA Generators Fact Sheet provides information on how to register on the new e-Manifest system: https://www.epa.gov/sites/production/files/2018-05/documents/e-manifest_generators_fact_sheet_0.pdf In order to access e-Manifest here is a link on how to obtain an EPA ID Number on EPA Form 8700-12:  https://rcrainfo.epa.gov/rcrainfoprod/action/secured/login


According to the e-Manifest mandate, receiving facilities will be billed manifest transaction fees by EPA. The fees are based on how the information will be submitted to the e-Manifest system. For years 2020/2021, the EPA decided to increase user fees due to various factors, including changes in projected manifest usage rates as well as program costs. The new fee for processing a paper manifest is $25 and went into effect October 1, 2019. In addition, some TSDs/receiving facilities are charging a higher fee to cover the administrative costs tied to the e-Manifest requirements. Generally Heritage-Crystal Clean (HCC) will charge a fee between $25-$35 per manifest.

Helpful links:

Fact Sheets for e-Manifest Stakeholders