Hazardous Waste Electronic Manifest System Updates

Summary

The Environmental Protection Agency (EPA) or (the Agency) is finalizing certain amendments to the hazardous waste manifest regulations, and the hazardous waste electronic manifest (e-Manifest) regulations under the Resource Conservation and Recovery Act (RCRA) to increase utility of the e-Manifest system in delivering benefits to reduce administrative burden and improve tracking of hazardous waste shipments, and to various related regulations. Among other things, EPA is finalizing changes to manifest regulations for shipments of hazardous waste that are exported for treatment, storage, and disposal. EPA is also finalizing regulatory changes to the hazardous waste export and import shipment international movement document-related requirements to more closely link the manifest data with the international movement document (hereafter referred to as "movement document") data. In addition, EPA is finalizing regulatory amendments to three manifest-related reports (i.e., Discrepancy, Exception, and Unmanifested Waste Reports). EPA is also finalizing conforming regulatory changes to the manifest regulations under the Toxic Substances and Control Act (TSCA) for polychlorinated biphenyls (PCB) wastes to better align these requirements with the RCRA manifest regulations and the e-Manifest program. Lastly, this action makes technical corrections to fix typographical errors in the e-Manifest and movement document regulations.

Compliance Requirements

1. #1

   Exporters must submit export manifests and manifest continuation sheets (whether electronic or paper manifests are used) to the e-Manifest system and pay the requisite fees for those submissions; Exporters must submit export manifests to the e-Manifest system within 30 days of receipt of the export manifest signed by the last transporter who carried the export shipment to a U.S. seaport for loading onto an international carrier or to a U.S. road or rail port of exit; Exporters must pay requisite user fees for manifest submissions to EPA; Exporters must submit electronic payments to the U.S. Department of Treasury through the e-Manifest system using acceptable electronic payment options (commercial credit cards, commercial debit cards, and Automated Clearinghouse (ACH) debits); Exporters must register users with at least Certifier level permissions in the e-Manifest module (requires identity proofing and electronic signature agreement); Transporters must send signed copy of manifest and continuation sheet to the exporter (instead of generator) for hazardous waste export shipments; Entities must use electronic Exception, Discrepancy, and Unmanifested Waste Reports through the e-Manifest system; Exporters must comply with electronic signature requirements in §262.25 for export manifests; Exporters must comply with post-receipt manifest data corrections procedures for hazardous waste export shipments

   Deadline: 2025-12-01(December 1, 2025)

Market Impacts

• New requirement for hazardous waste exporters to submit export manifests to EPA's e-Manifest system and pay user fees, creating additional administrative and financial barriers for US companies exporting hazardous waste; Integration of electronic manifests for hazardous waste export shipments creates new market opportunities for e-Manifest system providers and compliance software developers; Revised transporter requirements mandate that last transporters must send signed manifests to exporters instead of generators, changing established logistics workflows and documentation processes; New requirements for exporter registration, user permissions (Certifier level requiring identity proofing), and system training create demand for consulting and training services; New electronic system requirements and user fees create disproportionate burden on small businesses and entities with limited technical capabilities; Mandatory electronic payment requirements through U.S. Department of Treasury using commercial credit cards, commercial debit cards, or ACH debits

Validated Company Impacts