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The Hazardous Waste Manifest System is a set of forms, reports, and procedures designed to seamlessly track hazardous waste from the time it leaves the generator facility where it was produced, until it reaches the off-site waste management facility that will store, treat, or dispose of the hazardous waste. The system allows the waste generator to verify that its waste has been properly delivered, and that no waste has been lost or unaccounted for in the process.
The key component of this system is the Uniform Hazardous Waste Manifest which is a form prepared by all generators who transport, or offer for transport, hazardous waste for off-site treatment, recycling, storage, or disposal. Currently, the manifest is a paper document containing multiple copies of a single form. When completed, it contains information on the type and quantity of the waste being transported, instructions for handling the waste, and signature lines for all parties involved in the disposal process. The manifest is required by both Department of Transportation and EPA. Each party that handles the waste signs the manifest and retains a copy for themselves. This ensures critical accountability in the transportation and disposal processes. Once the waste reaches its destination, the receiving facility returns a signed copy of the manifest to the generator, confirming that the waste has been received by the designated facility.
The U.S. Environmental Protection Agency (EPA) proposed a significant update to the hazardous-waste manifest regulations under the Resource Conservation and Recovery Act (RCRA), primarily affecting the manifesting requirements in 40 CFR Parts 260–265 and related sections. The proposal, published March 5, 2026, is commonly referred to as the “Paper Manifest Sunset” rule and is intended to complete the transition from paper manifests to the EPA’s electronic tracking system, e-Manifest.
For more than four decades, hazardous-waste shipments have been tracked using the paper EPA Form 8700-22 hazardous waste manifest and continuation sheet 8700-22A. Since the e-Manifest system launched in 2018, users have been able to submit manifests electronically, but paper forms have remained permitted. The new proposal would eliminate paper manifests entirely after a transition period, making the electronic system the sole legally accepted tracking method. The EPA states that the change would improve data accuracy, reduce administrative burden, and streamline regulatory oversight nationwide. (US EPA)
If finalized, the rule would establish a 24-month phase-out period after publication of the final rule. After that date, all hazardous-waste shipments requiring a manifest would have to be created, signed, transmitted, and retained through the EPA’s e-Manifest system. Paper manifests would only be allowed in limited contingency situations, such as temporary system outages. The proposal also introduces related regulatory amendments affecting recordkeeping, reporting, and e-Manifest registration requirements for generators, transporters, and facilities. (Justia)
Sunset of paper manifests
Paper hazardous-waste manifests (EPA Forms 8700-22 and 8700-22A) would be eliminated 24 months after the final rule is published.
After that date, electronic manifests become the only authorized method for tracking hazardous-waste shipments. (Justia)
Mandatory use of the EPA e-Manifest system
All shipments requiring manifests must be created and signed electronically within the EPA e-Manifest system.
Hybrid manifests (electronic record with limited paper components) may still be used in some cases.
Required e-Manifest registration
Hazardous-waste generators, transporters, and receiving facilities that handle manifested waste must maintain active e-Manifest user accounts.
Registration requirements would also extend to certain TSCA PCB waste generators and transporters. (Justia)
Changes to recordkeeping
Instead of keeping paper copies of manifests for three years, facilities would meet recordkeeping requirements by maintaining electronic records within the e-Manifest system.
The requirement for facilities to mail replacement paper manifests to generators would be eliminated. (Justia)
Electronic reporting requirements
Exception reports, discrepancy reports, and other manifest-related reports would be submitted electronically through e-Manifest.
Some timelines and procedures are updated to align with electronic reporting workflows.
Updates to regulatory definitions
Definitions of “Manifest” and “Electronic Manifest” in 40 CFR 260.10 are revised to reflect that the manifest is fundamentally an electronic document.
Limited contingency use of paper
Paper replacement manifests may still be allowed if the e-Manifest system is unavailable, but they must later be uploaded to the system and may incur fees.
Technical and conforming amendments
Minor regulatory corrections affecting import/export provisions, reporting procedures, and references within the manifest regulations.
Public comment period
EPA is accepting public comments on the proposal until May 4, 2026.
EPA – e-Manifest rulemakings and policy information
https://www.epa.gov/e-manifest/e-manifest-rulemakings-and-policies (US
EPA)
Federal Register – Proposed Rule: Paper Manifest Sunset; Modification of the Hazardous Waste
Manifest Regulations
https://www.govinfo.gov/content/pkg/FR-2026-03-05/pdf/2026-04366.pdf (GovInfo)
Federal Register summary (Justia mirror of the proposal)
https://regulations.justia.com/regulations/fedreg/2026/03/05/2026-04366.html (Justia)
Specific sections of 40 CFR (e.g., 262.20–262.27, 264.71–264.72, etc.) are being amended,
This is useful for tracking compliance impacts for generators, TSDFs, or transporters.
The U.S. Environmental Protection Agency (EPA) proposed the “Paper Manifest Sunset” rule on March 5, 2026 to complete the transition to a fully electronic hazardous-waste manifest system under the Resource Conservation and Recovery Act (RCRA). The proposal amends multiple sections across 40 CFR Parts 262–267 (hazardous waste regulations) and 40 CFR Part 761 (TSCA PCB waste) to eliminate paper manifests and require use of the EPA’s e-Manifest system.
Historically, hazardous waste shipments have been tracked using the paper Uniform Hazardous Waste Manifest (EPA Form 8700-22) and continuation sheet 8700-22A. Since the electronic system launched in 2018, facilities have been able to submit manifests electronically, but paper forms remained permitted. The proposed rule would sunset paper manifests 24 months after publication of the final rule, making electronic manifests the only standard compliance method for generators, transporters, and receiving facilities. (Justia)
To implement this change, EPA proposes revisions and additions to specific regulatory provisions governing manifest preparation, signing, transport, receipt, reporting, discrepancy handling, and recordkeeping. These amendments also revise language throughout the regulations to treat the electronic manifest as the manifest itself, rather than merely the legal equivalent of a paper form. (Justia)
Below is a complete breakdown of the specific 40 CFR sections being amended, grouped by regulatory program and describing what changes EPA is proposing.
Change: Revised language requiring generators to prepare and use electronic manifests through the EPA e-Manifest system.
Effect:
Eliminates the option for paper manifests after the sunset date.
Clarifies that the manifest must be prepared electronically before shipment unless a contingency situation exists.
New paragraph added.
Purpose:
Ensures generators obtain manifest tracking numbers through the e-Manifest system rather than preprinted paper forms.
Revision.
Change:
Removes legacy language stating that electronic manifests are merely the “legal equivalent” of paper manifests with handwritten signatures.
Effect:
Establishes that the electronic manifest itself is the official legal document.
Revision.
Purpose:
Updates procedures generators must follow if the e-Manifest system becomes unavailable.
Key change:
Allows temporary use of a printed copy of an electronic manifest or a replacement paper manifest during outages.
Update to align with electronic reporting.
Effect:
Exception reports (when a generator does not receive a signed manifest) must be submitted electronically through e-Manifest.
New paragraphs added.
Purpose:
Ensures international shipments of hazardous waste also use the e-Manifest system for tracking and reporting.
New paragraph added.
Purpose:
Extends the electronic manifest requirement to additional generator programs regulated under Subpart K or other special provisions.
New paragraph added.
Effect:
Requires transporters to sign and transmit manifests electronically in the e-Manifest system.
Revision.
Purpose:
Updates the process transporters must follow when the e-Manifest system is temporarily unavailable.
Key elements:
Use printed electronic manifests or replacement manifests.
Upload final electronic record once the system is restored. (Justia)
Removed and reserved.
Reason:
Outdated language related to older manifest system implementation dates.
Revision.
Key change:
Facilities must register and use the EPA e-Manifest system for:
Manifest submission
Data corrections
Record retention
New paragraph added.
Effect:
After the sunset date, facilities must submit electronic manifests to the e-Manifest system.
Paper manifests only allowed during system outages.
Revision.
Purpose:
Removes references to electronic manifests as substitutes for paper forms.
Revision.
Effect:
Removes distinctions between paper and electronic submission fees, since paper manifests will be eliminated.
Emphasized usage.
Change:
Facilities must correct manifest data electronically through e-Manifest.
Revision.
Effect:
Exception reports must be submitted electronically.
Facilities may rely on records stored in e-Manifest to meet recordkeeping requirements. (Justia)
Revision.
Effect:
Manifest corrections must be completed through the electronic data correction process in e-Manifest.
Clarification.
Change:
Facilities satisfy record retention requirements by maintaining manifests in the e-Manifest system.
Removed and reserved.
Reason:
Eliminates outdated provisions requiring written paper reports.
New provision added.
Effect:
Requires submission of Unmanifested Waste Reports electronically via e-Manifest.
Revisions and new paragraphs:
Added:
(a)(4)
(a)(5)
(b)(3)
(c)(4)
Purpose:
Removes fee structure distinctions between paper and electronic manifests.
Result:
Fees apply only to electronic submissions or replacement manifests during outages.
Part 265 changes mirror the Part 264 revisions.
§265.70(b)
§265.71(a)(1)
§265.71(a)(2)(v)(C)
§265.71(f)
§265.71(j)(1)
§265.71(l)
§265.72(f)(8)
§265.72(g)
§265.74
§265.76(a) (removed)
§265.76(c) (added)
§265.1311 (fee revisions)
Purpose:
Align interim-status facilities with the fully electronic manifest system.
Revisions.
Effect:
Requires facilities operating under standardized permits to register with and use the e-Manifest system.
New paragraph added.
Purpose:
Establishes mandatory electronic manifest submission requirements for standardized-permit facilities.
Revisions.
Effect:
Aligns healthcare-facility hazardous waste manifest reporting with electronic exception reporting requirements.
To ensure consistency with PCB manifest requirements, EPA proposes revisions to:
Purpose:
Extend electronic manifest requirements to PCB waste shipments regulated under TSCA. (Justia)
Paper manifests (Forms 8700-22 and 8700-22A) would be prohibited 24 months after the final rule.
Entities that handle manifested hazardous waste must maintain active EPA e-Manifest accounts, including:
Generators
Transporters
TSDFs
Certain healthcare waste handlers
PCB waste handlers
Facilities satisfy record retention requirements by maintaining records in the e-Manifest database.
The rule moves several reporting processes fully online:
Exception reports
Discrepancy reports
Unmanifested waste reports
Manifest corrections
Paper manifests may only be used when:
The e-Manifest system is temporarily unavailable
The shipment must proceed due to operational necessity
Even then:
The paper record must later be entered into the e-Manifest system.
Federal Register Proposed Rule
Federal Register summary
EPA e-Manifest Program
If useful, I can also produce a practical compliance impact summary for generators, transporters, and TSDFs (what each group must change operationally before the paper sunset date).
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Specifically, the current paper system works as follows:
Many States also require the TSDF to send the State a copy of the manifest signed by the TSDF. Approximately 26 States require manifest copies from generators, TSDFs, or both. The requirement to submit copies to States is not based on Federal requirements, but on the needs of State programs that use manifest data for purposes of compliance monitoring, capacity planning, and program management.
If a generator does not receive a copy of the manifest signed by the designated facility owner or operator within 45 days of the date that the waste was accepted by the initial transporter (60 days for small quantity generators), the generator must file an exception report (Section 262.42). Conditionally exempt small quantity generators (CESQG's) are not required by federal regulations to use a manifest when shipping their waste off-site. CESQG's are defined under Section 261.5 as generators that produce, monthly, 100 kg or less of hazardous waste; 1 kg or less of acutely hazardous waste; or 100 kg or less of contaminated soil, waste, or debris resulting from clean-up of an acute hazardous waste spill.
NOTE: The regulations outlined above only apply to domestic shipments of hazardous waste by road. Domestic shipments made by rail or water are subject to streamlined manifesting requirements, and hazardous waste shipments exported from the US are subject to additional requirements. The information on this website pertains to federal regulations only. Contact your authorized State program for the RCRA regulations that apply in your State. Please also note that the description above is only a summary of the regulations and should not be used as a substitute for the regulations themselves. To review the full text of these regulations, click on
40 CFR Part 261
or
40 CFR Part 262
.
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Who is responsible for the Hazardous Waste Manifest?
Does EPA currently collect manifests?
The current Hazardous Waste Manifest is a joint undertaking by EPA and the Department of Transportation (DOT). EPA is responsible for regulating hazardous waste under a Federal statute known as the Resource Conservation and Recovery Act (RCRA). This Act requires that all hazardous waste shipped off-site be tracked from "cradle-to-grave" using a manifest that provides information about the generator of the waste, the facility that will receive the waste, a description and quantity of the waste (including the number and type of containers), and how the waste will be routed to the receiving facility. Because hazardous waste is also regulated by the DOT under its hazardous materials laws, the Manifest was developed to meet both EPA's requirements for a manifest, and DOT's requirements for "shipping papers
No. The Federal regulations do not require the routine submission of manifests to EPA, except when there are problems with a shipment which the generator and receiving facility cannot reconcile. Moreover, the hazardous waste regulatory program has been largely delegated to the state level, so most day-to-day implementation and inspection activities are carried out by "authorized states", rather than by EPA. However, about 30 States do routinely collect manifests, and these State programs now enter the data contained in these paper manifests into their databases for tracking purposes. The data is used by the states for estimation of hazardous waste management capacity, compliance targeting and enforcement, program management, and to generation of revenue.
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