EPA e-Manifest Changes Impacting Small and Large Quantity Generators
EPA has published the e-Manifest final third rule on June 28, 2024, that amends aspects of the hazardous waste manifest regulations under RCRA concerning the e-manifest system. As your strategic partner, we're here to help explain key aspects of final rule, effective Jan 22, 2025, that require customers to act now to remain compliant.
Mandatory Account Registration
SQGs and LQGs* are required to have at least one user with e-Manifest certifier or site manager registration access. This mandatory account registration ensures all generators can receive final signed manifest copies through EPA’s e-Manifest system.
Because the final signed manifest will now be available through EPA’s website, Republic Services will no longer mail final copies to our customers. By eliminating this step, we decrease our environmental impact and reinforce our commitment to sustainability. This change also enables greater information availability, reduces manual reporting burdens, and improves compliance monitoring.
EPA has provided multiple resources for you to learn more about the changes impacting you, including the e-Manifest final rule summary, and instructions on e-Manifest user registration.
Unsure where to start to remain compliant? Watch EPA's training video on the e-Manifest registration process.
Republic Services customers will still be able to download a copy of their final manifest by logging into their Online Account.
Additional EPA Updates
Requested Mandatory Manifest Corrections
EPA and the States utilize the e-Manifest data for a variety of reasons. In the event an error is discovered, the state or EPA may contact you to correct the error. Generators, transporters and TSDFs will have 30-days to submit mandatory corrections electronically to the e-Manifest system.
Exception and Discrepancy Reporting Time Frame Changes
Large Quantity Generators will now have additional time to complete the exception reporting requirements found in 262.42(a) for missing final manifest copies.
EPA has given generators 20 days, 5 more than previous regulations, to address discrepancies with their TSDF, before a notification report is required to be submitted.
New Uniform Manifest Format
EPA is trying to save paper too, which is why the new 2025 uniform manifest will only have 4 parts. The existing 3rd part (Designated facility copy) will be eliminated since it is redundant with what is stored in the e-Manifest system. The new 4-part format will consist of:
- 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
The new 4-part manifest will be available for use beginning January 22, 2025. The EPA has stated that the existing inventory of 5-part manifests may still be used until December 1, 2025.
Look for more emails from Republic outlining the manifest changes.
*EPA is not requiring Very Small Quantity Generators (VSQGs) to register, as use of the Manifest is not required. VSQGs that use the manifest to ship hazardous waste may register with EPA or continue to use COR to secure copies of their final manifest.
Additional Questions?
If you have additional questions about EPA's final e-Manifest rule, please contact your Account Executive or call Customer Service at 800.592.5489.
