e-Manifest Reports Must Be Submitted Online as of 12/1

December 1, 2025, marked a key compliance deadline for hazardous waste generators, receiving facilities, and exporters: As of 12/1, electronic submission of certain hazardous waste Manifest-related reports, and export manifests, is now mandatory. 

The following must now be submitted electronically via the RCRAInfo online portal: 

• Export manifests
• Exception reports
• Discrepancy reports
• Unmanifested waste reports 

The e-submission mandate comes from EPA’s “Third Rule” for electronic hazardous waste Manifests or e-Manifests, which incorporated reports and export documents into the RCRAInfo online system. 

RCRA Hazardous Waste Manifest Reports

The Hazardous Waste Manifest (EPA Form 8700-12) is a document used to track the movement and possession of hazardous waste transported in the United States. The Manifest follows a hazardous waste from the site that generated the waste, to the transporter, to the receiving facility where it can be properly recycled or disposed of (e.g., a TSDF). 

3 reports related to the Manifest—exception reports, discrepancy reports, and unmanifested waste reports—come into play when something out of the ordinary happens.  

(Video) Training to Sign the Hazardous Waste Manifest 

Manifest Exception Reports 

When a TSDF receives a hazardous waste shipment accompanied by a manifest, they must send a copy of the manifest to EPA’s online e-Manifest system (40 CFR 265.71). The generator can view the manifest online as proof that their waste was received/accepted.

A generator must submit an exception report when a signed copy of the manifest is not received “within 60 days of the date the waste was accepted by the initial transporter” (40 CFR 262.42). 

Manifest Discrepancy Reports 

A discrepancy report may be filed by a receiving facility when the waste they receive does not match what’s on the manifest. 

Potentially “reportable” manifest discrepancies, per 40 CFR 265.72, are: 

• The quantity or type of waste received is significantly different than what is on the manifest
• A load is rejected, in full or in part, because the TSDF cannot accept the waste
• Containers hold residues exceeding quantity limits for “empty containers” (Is It RCRA Empty?) 

For discrepancies related to the quantity or type of waste, the TSDF must try to clarify and/or correct this with the generator. If the manifest discrepancy cannot be resolved within 20 days, the TSDF must file a discrepancy report. 

Unmanifested Waste Reports 

A TSDF must submit an unmanifested waste report if they accept a load of hazardous waste that is not accompanied by a manifest but should be (i.e., is not excluded from the requirement). 

The report must be submitted to the e-Manifest system within 15 days after receiving the waste. The rule also requires the TSDF to inform the EPA Regional Administrator within 15 days (40 CFR 264.76). 

Sunset on Paper Hazardous Waste Manifests?

As soon as January 2026, EPA intends to establish a timeline for fully phasing-out paper hazardous waste manifests in favor of e-Manifests (RIN 2050-AH35). Since launching the e-Manifest program in 2018, EPA has established fees and taken other steps to incentivize the use of electronic manifests for all stakeholders. EPA has long said that wide adoption of e-Manifests is needed to fully realize the benefits and efficiencies of the system.

5-Copy vs. 4-Copy Manifests 

December 1 was originally the deadline for shifting from a 5-copy hazardous waste Manifest to a 4-copy form, as well. However, in September, EPA provided guidance to the regulated community to announce that they will continue accepting the 5-copy Manifest form “until further notice.” 

With the transition to the e-Manifest system proceeding step by step, Manifest copy #5 is now “obsolete.” The fifth copy is reserved to be returned to the generator with the receiving facility’s signature after the waste reaches its final disposition. Now, receiving facilities will upload the signed Manifest to the RCRAInfo system, where it can be accessed by the generator. 

Links:
More about manifest exception reports (RCRAInfo)
More about manifest discrepancy reports (RCRAInfo)
More about unmanifested waste reports (40 CFR 264.76) 
RCRAInfo Industry Help and Guidance—Reports Library 

Tags: e-manifests, hazardous waste, manifests, RCRA