Update: New Manifest Exemption for California Hazardous Waste Generators

Update 1/28/2026:

The California Department of Toxic Substances Control (DTSC) extended the public comment period for the proposed exemption to the hazardous waste requirements an additional fifteen days. Written comments may now be submitted until February 17, 2026.

California DTSC will accept public comments until February 2, 2026, on a proposed exemption to the hazardous waste Manifest requirements for waste transported between contiguous properties owned or controlled by the same “person.”  

The proposed exemption is already available to hazardous waste generators under Federal RCRA regulations, which do not require a Manifest for shipments of hazardous waste sent “within or along the border of contiguous property under control of the same person", even if the property is divided by a public road [40 CFR 262.20(f)].

New California Hazardous Waste Manifest Exemption 

Announced in July 2025, the DTSC rule for shippers of hazardous waste in California would add a paragraph to the state's Title 22 regulations, 22 CCR 66262.20(f), to read in part: 

“the requirements of this article and subsection 66262.32(b) do not apply to the transport of hazardous waste on a public or private right-of-way within or along the border of contiguous property under the control of the same person, even if such contiguous property is divided by a public or private right-of-way…” 

Industry stakeholders and the public had an earlier opportunity to comment on the proposed manifest exemption in Summer 2025. DTSC opened the additional 15-day comment period (as required by State law) because information was added to the rulemaking file after the initial comment period closed—namely a 10-year summary of hazmat transportation incidents published by US DOT/PHMSA in September 2025 and some related correspondence between DTSC and PHMSA. 

California Hazardous Waste Updates (2026)

The proposed manifest exemption is one of three new regulatory reliefs DTSC has put forth recently. The agency has also: 

• Finalized a rule to permanently exempt industrial ethyl alcohol from the hazardous waste management standards (when legitimately reclaimed), effective 11/17/25, and 

• Taken steps to permanently adopt streamlined standards for managing defective/recalled car airbags (e.g., Takata airbags). DTSC’s emergency rule for airbag wastes expired in March 2025. 

Evolving RCRA Manifest Regulations

As of December 1, 2025, electronic submission of certain hazardous waste Manifest-related reports, and export manifests is mandatory. US EPA intends to establish a timeline for phasing-out paper hazardous waste manifests in favor of e-Manifests in 2026.

The Agency has also phased out the 5-copy hazardous waste Manifest in favor of a 4-copy form. The 5-copy form will be accepted until further notice, but the fifth copy is now obsolete.

May 2026: California Hazardous Waste Training

Did your latest hazardous waste training address major revisions and new rules in California's State regulations? Lion delivers recently updated training backed by resources that highlight the important changes generators need to know when it comes to the RCRA Generator Improvements Rule, contingency planning and emergency planning, managing waste containers, treatment standards, and much more.

Join Lion for the two-day California Hazardous Waste Management workshop for annually required training to get you up to speed with the latest state and Federal requirements your site must follow to prevent releases, civil penalties, and future liability.

Can't wait for the workshop? Sign up for a live webinar or self-paced online course.