RCRA Rules to Watch in 2026–2027

Hazardous waste managers have a lot to look forward to over the next two years. The 2026 Unified Agenda included US EPA's plans for the Federal hazardous waste regulations. This article highlights rules with potential to impact compliance for hazardous waste managers in the immediate future.

This article highlights rules with potential to impact compliance for hazardous waste managers in the short term.

Lion Members can log in to view a Member Bulletin that breaks down the environmental, hazardous materials, and health & safety regulations in progress on a greater scale.

Listing PFAS as RCRA Hazardous Constituents

The EPA is planning to evaluate the existing toxicity and health effects data on perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS), perfluorobutane sulfonic acid (PFBS), and hexafluoropropylene oxide dimer acid (HFPO-DA, and/or GenX) to determine if they should be listed as RCRA Hazardous Constituents in response to multiple petitions in this proposed rulemaking.

A Final Rule is anticipated for January 2027.

Paper Manifest Sunset Rule

The EPA proposed to officially end the use of paper Hazardous Waste Manifests and require sites to use the online “e-Manifest” system. The EPA plans on advancing its efforts in this rulemaking to transition from paper to electronic manifests by establishing a clear timeline for phasing out paper manifests.

A Final Rule is anticipated for January 2027.

Other RCRA Rules to Watch

Updating Universal Waste Rules for Solar Panels and Lithium Batteries

In this proposed action, the EPA would add hazardous waste solar panels to the universal waste provisions at 40 CFR 273. The EPA believes that this addition will benefit establishments that generate and manage solar panel waste by providing them with a practical system for how to handle the disposal and ultimately promote recycling.

Further, the EPA plans on proposing universal waste standards specific to lithium batteries in this same rulemaking. The standards for lithium batteries will separate from the existing regulations for general batteries that are managed as universal wastes. By doing this, the EPA hopes to improve safety standards, reduce fires from end-of-life lithium batteries, and further promote recycling.

An NPRM is anticipated to be published in August 2026. A Final Rule is planned for August 2027.

Reducing RCRA for Vessels in the Offshore Energy Sector

With this proposed rulemaking, the EPA is adapting the hazardous waste generator regulations for certain offshore vessels that relate to energy production, such as mobile offshore drilling units, used by the offshore energy production sector.

Specifically, the EPA is proposing to provide regulatory relief to this sector by adapting the requirements that apply to the hazardous waste generated aboard these vessels while at sea in hope that it will help provide a more feasible compliance pathway for offshore vessel hazardous waste.

An NPRM is anticipated to be published in December 2026, and a Final Rule is planned for June 2027.

RCRA Training for Generators

Lion offers a range of RCRA training courses for industry professionals at every stage of their career. For managers with overall responsibility for RCRA compliance, we recommend comprehensive RCRA Hazardous Waste Management training.

Tags: e-manifest, EPA, lithium batteries, PFAS, RCRA, solar panels