E-manifest implementation

Congress enacted the Hazardous Waste Electronic Manifest Establishment Act on October 5, 2012. This legislation requires the Environmental Protection Agency (EPA) to have an electronic manifest system in place within three years of passage of the legislation (October 2015).  EPA has been working on developing a national electronic hazardous waste manifest system for over a decade. In February 2014, EPA authorized the use of electronic hazardous waste manifests, but it was still developing the information technology system to implement the program.

The electronic manifest system extends to all federal and state regulated wastes requiring manifests. The use of electronic manifests will be optional for users. EPA is authorized to collect data from electronic and paper manifests and to assess reasonable user fees for the cost of developing, implementing and maintaining the system.

On February 7, 2014, EPA issued a final regulation that authorizes the use of electronic hazardous waste manifests. This rule provides users an opportunity to complete, sign, transmit, and store manifest information electronically. States are allowed to develop electronic manifest systems that conform with the federal system.

On January 3, 2018 EPA published a final rule that established the methodology that it will use in setting and revising user fees to recover the full cost of the electronic manifest system. To simplify the system, user fees will only be assessed against facilities receiving hazardous waste.  These facilities will pass the cost of the user fees on to generators.  The electronic manifest system became operational June 30, 2018.

EPA encouraged the hazardous waste industry to adopt fully electronic manifesting as soon as possible so that industry members can take maximum advantage of the benefits and cost savings of electronic manifesting.  EPA acknowledged that it will take time for industry to fully transition to electronic manifests. Even though EPA allowed the continued use of paper manifests, it can be more expensive for firms that continue to do so.

For fiscal years 2022 and 2023 (October 1, 2021 – September 30, 2023) EPA increased the following user fees for each manifest type.

  • Mailed in paper manifest – Not an option as of June 30, 2021

  • Scanned in paper image -- $20 per manifest

  • Data and image upload -- $13 per manifest
  • Electronic Manifest (Fully Electronic & Hybrid) -- $8 per manifest


                       More information on the new user fees is available on the EPA website at https://www.epa.gov/e-manifest/e-manifest-user-fees-and-payment-information

                       In 2022 EPA issued a proposed rule that includes multiple changes to the e-Manifest system, including integration of exported hazardous waste manifests, Discrepancy Reports, Exception Reports, and Unmanifested Waste Reports into the e-Manifest system. Full text: https://www.federalregister.gov/documents/2022/05/24/2022-11081/integrating-e-manifest-with-hazardous-waste-exports-and-other-manifest-related-reports-pcb. Comment period extended to August 1, 2022.