December 1, 2025 was the second and final compliance deadline for the Environmental Protection Agency’s (EPA) Third Rule, requiring waste generators, transporters, and treatment, storage, and disposal facilities (TSDF) to now fully transition to the e-Manifest system.
Published on July 26, 2024, the Third Rule amends hazardous waste manifest regulations under the Resource Conservation and Recovery Act (RCRA). These changes aim to streamline hazardous waste management by centralizing manifest processes on a single electronic platform.
The rule took effect on January 22, 2025, which was also the first compliance deadline. The changes include:
- Waste generators must register for e-Manifest accounts if they have not done so already.
- Very Small Quantity Generators (VSQGs) located in states, such as New York and California, that do not require them to obtain an EPA ID are exempt from this requirement. VSQGs in Massachusetts are required to obtain an EPA ID.
- Exempt VSQGs can take advantage of e-Manifest if they register as a generator with the EPA.
- VSQGs who opt out of e-Manifest must arrange to receive paper copies of completed manifests from receiving facilities.
- TSDFs are no longer required to mail final manifests to generators but must instead submit manifest data electronically.
- EPA and state regulators can request corrections to manifest data, which must be completed by the generator within 30 days. Generators can delegate corrections to other parties depending on the manifest section but are still ultimately responsible.
- Waste manifests were simplified from five pages to four.
The December 1, 2025 compliance deadline focuses on digitizing manifest-related reports.
- Exception, Discrepancy, and Unmanifested Waste Reports must be submitted to e-Manifest rather than to the EPA Regional Administrator or authorized State Director. No federal filing fees are associated with submitting these reports.
- Large Quantity Generators (LQGs) now have 60 days (up from 45) to receive a final manifest before filing an Exception Report. Small Quantity Generators (SQGs) remain at 60 days.
- Receiving facilities now have 20 days (up from 15) to submit a Discrepancy Report for waste that significantly differs from what is indicated on the manifest.
The major shift to electronic manifests and related reports is largely beneficial for waste generators. Aside from eliminating the burden of keeping track of paper documents, e-Manifest features convenient functions, such as being accessible on mobile devices like tablets and smart phones and supporting electronic signatures. Users can also create manifest templates for repeat shipments, saving time and reducing data entry errors.
Additionally, RCRAInfo Web was upgraded and replaced with RCRAInfo’s Hazardous Waste Information Platform (HWIP) on September 19, 2025. The new platform provides streamlined, comprehensive access to hazardous waste data, which is now easier to compile thanks to the move to electronic manifests.
If you are a waste generator that is required to register, a VSQG considering obtaining an EPA ID to take advantage of e-Manifest, or a generator needing assistance with compliance under the Third Rule, please contact us.
This blog was written by Mutya Cruz, PhD, a Quality, Research, and Training (QRT) Specialist at Safety Partners.
