e-Manifest (Hazardous Waste)

Is e-Manifest mandatory?

No — generators may continue to use paper manifests, but paper manifests must be scanned and uploaded to e-Manifest within 30 days under 40 CFR 264.71(j). Fully electronic submission is incentivized through lower fees ($20 vs $80) and faster processing. Most large generators have transitioned to electronic submission.

Who pays the e-Manifest fees?

Designated facilities (TSDFs) — the receiving facility for the hazardous waste — pay the fees, typically passing the cost through to generators on the disposal invoice. Fees are tiered based on submission type to encourage electronic over paper formats. Fee schedule is updated periodically by EPA based on system operating costs.

How long do I retain manifests in e-Manifest?

EPA retains the manifest in the national e-Manifest system. Generators must retain a copy of each manifest signed by the transporter for at least 3 years from the date the waste was accepted by the initial transporter (40 CFR 262.40), and a copy signed by the TSDF. The e-Manifest record satisfies retention if the generator can access it.

Can I see manifests submitted by other companies?

Generators see only their own manifests. State agencies and EPA see all manifests within their jurisdiction. Aggregate national hazardous waste data is published in EPA's Biennial Reports. Specific manifest details for individual generators are not public except through Freedom of Information Act requests.