Final Rule Alert: Third RCRA e-Manifest Rule

Posted on 7/8/2024 by Lion Technology Inc.

US EPA is prepared to release the third of three rules to implement the electronic Hazardous Waste Manifest (e-Manifest) system for tracking the transportation of hazardous waste shipments. 

Dubbed “the Third Rule” by EPA, the Rule revises the RCRA regulations for documenting the movement of hazardous waste within, into, and out of the United States. 

Final Rule Alert: Third RCRA e-Manifest Rule

EPA’s Third e-Manifest Final Rule: 

  • Requires exporters to submit export manifests to the e-Manifest system and pay a fee. 
  • Removes the existing requirement for receiving facilities to transmit a copy of the completed manifest by mail (40 CFR 264.71(a)(2) and 265.71(a)(2)). 
  • Makes corresponding changes related to Manifest Discrepancy Reports, Exception Reports, and Unmanifested Waste Reports.
  • Revises requirements to “more closely link” hazardous waste export and import shipment manifests with international movement documents.
  • Aligns the manifest requirements for polychlorinated biphenyls (PCBs) under TSCA to align them with the RCRA manifest regulations. 
  • Fixes typos and makes technical corrections to the manifest regulations.

New requirements for hazardous waste exports and various manifest reports will take effect on December 1, 2025. 

LQGs and SQGs Must Create RCRAInfo Accounts 

Notably, the Final Rule requires large and small quantity generators to create online accounts in the RCRAInfo Portal ( to access completed manifests. This differs from what EPA proposed in April 2022.

At that time, EPA proposed requiring generators to provide an e-mail address on the manifest for receipt of completed manifests from the online system. This would have entailed adding a field to the manifest for the generator’s e-mail address. In the proposed rule, EPA also asked for input on alternatives to the e-mail address requirement.  

Video: If you sign hazmat shipping papers or the Hazardous Waste Manifest, you need hazmat training that meets US DOT standards found in 49 CFR 172.704. 

In response to comments from the regulated community, EPA will not require receiving facilities to transmit completed manifests to the generator. Instead, EPA will require all large and small quantity generators to create accounts in the RCRAInfo Industry Application to access completed manifests. 

From the pre-publication version of the Final Rule:

“In this final rule, the Agency is not finalizing its proposal to use generator email addresses collected on paper manifests to send completed copies of manifests to generators. Rather, in 40 CFR 262.20(a), EPA is requiring large and small quantity generators (LQGs and SQGs) to register for the e-Manifest module in the RCRAInfo Industry Application to access completed copies of manifests.”

Final Rule. Docket EPA-HQ-OLEM-2021-0609. June 28, 2024.

Lion will update this blog when the Final Rule appears in the Federal Register. Except for revised export and manifest report requirements effective December 1, 2025, the Final Rule will take effect sixty days after publication.

DOT Hazmat Training to Sign Manifests 

Develop a step-by-step process to ship hazardous materials by ground —including manifested hazardous waste shipments—in full compliance with US DOT's Hazardous Materials Regulations (HMR). These upcoming workshops are built to help satisfy 49 CFR (DOT) training mandates for shippers and "hazmat employees."

See the workshop schedule or train online: 
Hazmat Ground Shipper Certification (DOT) Training

US DOT requires recurrent training every 3 years for hazmat employees (49 CFR 172.704). 

Tags: e-manifest, hazardous waste management, hazardous waste shipping, hazmat shipping

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