On March 5, 2026, the U.S. Environmental Protection Agency (EPA) published a proposed rule to amend the hazardous waste manifest regulations to establish a sunset date for phasing out the use of paper manifests and requiring electronic versions. It includes a compliance date that will be set at 24 months after the publication of the final regulation before eliminating paper manifest use.
On and after that date, the EPA will no longer accept paper hazardous waste manifests and will require only fully electronic or hybrid manifests. This proposed rule affects hazardous waste generators; transporters; and treatment, storage, and disposal facilities (TSDFs) that use hazardous waste manifests under the Resource Conservation and Recovery Act (RCRA) to track shipments of hazardous waste.
Background
Since the e-Manifest system launched in 2018, the EPA has taken various steps to increase the percentage of electronic manifests used versus paper. These included the promulgation of the 2024 e-Manifest Third Rule. As we talked about in our EPA’s Third Rule is Now Fully Enforced – What Waste Generators Need to Know blog, this regulation requires mandatory e-Manifest registration for large and small quantity generators, along with the use of electronic or hybrid manifests. However, these requirements were not extended to very small quantity generators (VSQGs) or polychlorinated biphenyl (PCB) waste generators.
According to the EPA, despite the implementation of the Third Rule, electronic manifests currently account for less than 1% of all manifests that have been submitted to the e-Manifest system since its launch.
Summary of the Proposed Rule
The EPA believes that switching from paper manifests to only electronic versions will save up to an estimated $28.5 million annually, resulting from the decreased burden to manifest users (e.g., costs for printing, reporting, and recordkeeping). The Agency also notes that the change will provide enhanced efficiency, accuracy, and transparency in tracking hazardous waste shipments across the United States which will result in improved human health and environmental protection.
While the main goal of the EPA proposed rule is to phase out the use of paper manifests, it is also intended to conform with changes made to requirements in the Third Rule including the following:
- Requiring waste handlers subject to manifesting, including VSQGs, as well as transporters and Toxic Substances Control Act (TSCA) regulated PCB waste handlers to be registered with the e-Manifest system.
- Adding electronic reporting requirements for VSQGs managing hazardous waste from episodic events, as well as for healthcare facilities and reverse distributors handling hazardous waste pharmaceuticals.
- Revising discrepancy reporting requirements for owners and operators of hazardous waste facilities operating under standardized permits.
- Incorporating technical corrections to the import and export requirements to update the EPA’s mailing address, remove obsolete text, and revise a citation associated with manifest corrections for export shipments.
Comment Period
Comments on the proposed rule must be received on or before May 4, 2026. For those looking to comment on the information collection provisions, the EPA recommends submitting them on or before April 6, 2026 to ensure consideration by the Office of Management and Budget (OMB).
Comments should be identified by Docket ID No. EPA-HQ-OLEM-2025-3456 and can be submitted using any of the following methods:
- Electronically via the Paper Manifest Sunset Rule; Modification of the Hazardous Waste Manifest Regulations rulemaking docket (Federal e-Rulemaking Portal comments are preferred by the EPA)
- Email and fax
For additional information on the EPA’s proposed Paper Manifest Sunset Rule; Modification of the Hazardous Waste Manifest Regulations, or for help registering with e-Manifest and managing your facility’s hazardous waste manifests—contact us!
This blog was written by Beth Graham, Safety Partners’ Director of Quality, Research, and Training.
