July 17, 2025

e-Manifest Rule Summaries and Fact Sheets

EPA recently published an e-manifest rulemakings and policy summary detailing the statutory and regulatory framework of the e-manifest system. Since Congress passed the 2012 Hazardous Waste Electronic Manifest Establishment Act, better known as the e-Manifest Act, EPA has issued three implementing rules:

The 2014 “One Year Rule” establishes the legal foundation and use requirements for the e-manifest system [79 FR 7518];
The 2018 “User Fee Rule” sets the fee structure to support the e-manifest systems development and operation [83 FR 420]; and
The 2024 “Third Rule” (discussed in a previous article) integrates various manifest reporting requirements into the e-manifest system. [89 FR 60692]

Full use of e-manifests has lagged since the system’s nationwide launch on June 30, 2018. To support continued adoption, the agency has provided numerous e-manifest fact sheets providing information on how specific users are impacted and what they need to know to use the e-manifest system. The fact sheets are written from EPA’s federal perspective, so users will want to check with their state for other information that may be required when using manifests.

Most notably for large and small quantity generators, their January 22, 2025 deadline for setting up an e-manifest system account has passed. If not already complete, generators may register via RCRAInfo, and account registration only takes a few minutes.

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Disclaimer

Considerable care has been exercised in preparing this document; however, McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with the publication of this information. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which this information may conflict. McCoy and Associates, Inc. does not undertake any duty to ensure the continued accuracy of this information.

This document addresses issues of a general nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with the environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.