August 13, 2019

e-Manifest User Fees Increasing for FY2020-2021

User fees associated with EPA’s e-manifest system will increase for FY2020-2021, the period from October 1, 2019, through September 30, 2021. Every two years, EPA is required to revise user fees according to the fee calculation methodology laid out in Parts 264/265, Subpart FF. The user fee increase is due to lower than expected e-manifest use, changes in projected system usage, and increased costs for enhancing the system’s capabilities.

In June 2019, EPA held a Hazardous Waste e-Manifest System Advisory Board meeting detailing system development, engagement, and other related issues. Only 0.26% of manifest submissions were fully electronic or hybrid in the first 10 months of system operation (see page 7 of the meeting’s report). To encourage fully electronic submittals rather than traditional paper manifest submittals, fees are increasing. Also, because approximately one million less manifests than projected were submitted in the first 10 months of system usage, “each individual manifest bears a larger proportion of the costs for operating the e-manifest program.”

Recall, user fees are invoiced from EPA to the treatment, storage, and disposal (TSD) facilities receiving the waste. In turn, most TSD facilities have begun invoicing generators to recoup these costs. Below is a comparison between the current and upcoming e-Manifest system user fees.

Manifest Submission Type

Fee per Manifest Through 9/30/19

Fee per Manifest 10/1/19–9/30/21

Mailed-in paper manifest



Scanned image upload



Data + image upload



Electronic manifest (full electronic and hybrid1)



1A hybrid manifest is a paper manifest the generator signs (and keeps a paper copy) but is subsequently converted to an e-manifest by the transporter/TSD facility. [§262.24(c)(1)]

Source: McCoy and Associates, Inc. adapted from


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