August 11, 2020

Recommendations for Increasing e-Manifest Usage

Currently, e-manifests (fully electronic and hybrid) represent <0.5 percent of the approximately two million manifests EPA receives annually. One of the impediments to the use of e-manifests is the requirement for all generators, transporters, and receiving facilities that electronically sign manifests to register their e-signatures in full compliance with Cross-Media Electronic Reporting Rule (CROMERR) requirements under 40 CFR Part 3. In a meeting held April 14–16, 2020, the e-Manifest Advisory Board made many recommendations to the agency, including:

Source: Final e-Manifest Advisory Board April 2020 Meeting Report, available at


©2020-2023 McCoy and Associates, Inc. All rights reserved.

McCoy and Associates has provided in-depth information to assist environmental professionals with complex compliance issues since 1982. Our seminars and publications are widely trusted by environmental professionals for their consistent quality, clarity, and comprehensiveness.



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 RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA 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.