EPA proposes electronic-only hazardous waste manifests

On March 5, 2026, the Environmental Protection Agency (EPA) issued a proposed rule to end the use of paper hazardous waste manifests and require waste handlers to use electronic manifests on the Hazardous Waste Electronic Manifest (e-Manifest) System to track all shipments of hazardous waste regulated under the Resource Conservation and Recovery Act (RCRA).

What are the proposed changes?

EPA proposes to “sunset” (i.e., phase out) the use of paper manifests and shift to using only electronic manifests (either fully electronic or hybrid) to track RCRA hazardous waste shipments.

The sunset compliance date would be 2 years from the publication date of a final rule. On and after the sunset compliance date, EPA would no longer accept paper hazardous waste manifests (image-only and data-plus-image submission types). In other words, regulated waste handlers would have to use fully electronic or hybrid manifests on the e-Manifest System for all hazardous waste shipments initiated on and after the sunset compliance date.

Who would be impacted?

The proposed rule would affect waste handlers involved in manifesting hazardous waste, including:

• Generators,
• Transporters, and
• Receiving facilities.

Many of the proposed changes would align RCRA regulations with the shift to electronic-only manifesting and with the 2024 e-Manifest Third Rule’s changes. The proposed rule also contains technical corrections to import and export regulations.

Additionally, EPA’s proposed rule would add requirements for:

• Very small quantity generators (VSQGs) managing episodic events,
• RCRA hazardous waste transporters,
• Healthcare facilities and reverse distributors subject to RCRA’s hazardous waste pharmaceutical requirements,
• Certain polychlorinated biphenyl (PCB) waste generators,
• PCB waste transporters, and
• Hazardous waste treatment or storage facilities with standardized RCRA permits.

Examples of these requirements include:

• Mandating specific waste handlers to register with the e-Manifest System;
• Requiring VSQGs, healthcare facilities, and reverse distributors to submit data corrections to the e-Manifest System within 30 days of a request from EPA or an authorized state; and
• Requiring hazardous waste generators and PCB waste generators to identify brokers on the manifest.

EPA will accept public comments on the proposed rule (Docket ID No. EPA-HQ-OLEM-2025-3456) through May 4, 2026.

Key to remember: EPA proposes to end the use of paper manifests and require waste handlers to use electronic manifests to track all RCRA hazardous waste shipments.