EPA to End Use of Paper Hazardous Waste Manifests

On March 5, US EPA proposed to officially end the use of paper Hazardous Waste Manifests and require generators, transporters, and receiving facilities to use the online “e-Manifest” system following a two-year transition period. 

The proposed rule creates an end date or “sunset date” for paper Manifests, to come 24 months after a Final Rule is published, and makes other revisions to the RCRA requirements. 

EPA will accept comments on the proposed rule until May 4, 2026.

From the proposed rule: 

"On and after (the “paper sunset date”) EPA would no longer accept paper hazardous waste manifests… Waste handlers, including generators, transporters, and receiving facilities, would need to use electronic manifests, including fully electronic or hybrid manifests, for all shipments initiated on and after this sunset date."

_{91 FR 10862. March 5, 2026. "Paper Manifest Sunset Rule..."}

What is the Hazardous Waste Manifest?

The Uniform Hazardous Waste Manifest is a document used to track chain-of-custody for hazardous waste in transportation. Use of the Manifest ensures that hazardous waste is transported from a generator site to an authorized receiving facility that will appropriately treat, recycle, and/or dispose of the waste in compliance with the RCRA Land Disposal Restrictions or LDRs. 

RCRA Rule Updates to "Sunset" Paper Manifests

In addition to the proposed two-year timeframe for sunsetting paper manifests, EPA plans to make related changes throughout the RCRA regulations, adding or revising provisions related to: 

• Registration requirements for transporters 
• Registration requirements for generators and transporters of PCBs
• Exception reporting for VSQGs and hazardous waste pharmaceuticals
• Discrepancy reporting for owners/operators of permitted RCRA facilities 
• Hazardous waste import/export requirements 

The proposed rule also updates the definitions for the terms Electronic manifest and Manifest under RCRA (40 CFR 260.10) and TSCA (40 CFR 761), and eliminates provisions that call for “handwritten” forms or forms that are “signed by hand.” 

These revisions will help to clarify that, as EPA says in the proposed rule:

“Electronic manifests are not just the legal equivalent for paper manifests—they are the hazardous waste manifest.”

_{[91 FR 10866. March 5, 2026. "Paper Manifest Sunset Rule..."]} 

Read the full proposed rule in the March 5, 2026 Federal Register.

What About 49 CFR/DOT Compliance for Shippers? 

US EPA is preparing for an all-electronic future with respect to the Hazardous Waste Manifest. 

However, the US DOT Hazardous Materials Regulations (HMR) still require a paper copy of the shipping paper to accompany shipments of hazardous materials. This includes all shipments of hazardous waste(s) that require the use of the manifest under RCRA (see 49 CFR 172.205).

To comply with the HMR, shippers of hazardous waste (e.g., generators) can use the “Print” option available when creating/viewing an e-Manifest in the RCRAInfo Portal. The printed copy should be provided to the carrier/transporter to fulfill the hard-copy shipping paper requirement. 

What About Wastes Regulated by My State?

Following the sunset date for paper manifests, the e-Manifest requirement will apply to hazardous waste covered by the Federal RCRA program as well as any hazardous waste for which any State requires a Manifest. 

This is true because Congress included it in the Hazardous Waste Electronic Manifest Establishment Act (“e-Manifest Act”) passed in 2012. Section 2(g)(2) of that law provides that any new EPA regulations “relating to electronic manifesting of hazardous waste shall take effect in each State as of the effective date specified in the regulation.” 

e-Manifest Tutorials and Information 

In 2024, EPA produced several e-Manifest tutorials for hazardous waste generators, transporters, and TSDFs that include demonstration videos about signing in to the e-Manifest system in RCRAInfo, creating e-Manifests, signing e-Manifests, and more. 

There is also a Frequently Asked Questions (FAQ) webpage available with answers about e-Manifets for affected hazardous waste generators, transporters, and receiving facilities: Frequent Questions About e-Manifest.