EPA: 5-Copy Hazardous Waste Manifest Form OK to Use Until Further Notice

In updated guidance posted on September 10, 2025, EPA states that the agency will continue to accept the 5-copy hazardous waste manifest form “until further notice.” The 5-copy manifest form was set to become obsolete on December 1, 2025, when EPA’s “third rule” concerning e-Manifests enters full effect. Some provisions of this rule have been in effect since January of this year.

Per the updated EPA guidance, stakeholders can expect 90 days advance notice before EPA will stop accepting the “old” 5-copy paper manifest form. 

From the updated guidance on EPA.gov: 

EPA is announcing updated guidance regarding the use of old 5-copy paper manifest forms following the third rule’s effective date of January 22, 2025.

...EPA will accept 5-copy paper manifest forms until further notice. EPA will provide a 90-day advance notice of when we intend to cease acceptance of the 5-copy forms.

The updated guidance is included in the e-Manifest frequently asked questions (FAQ) page on EPA.gov. The new policy is addressed in Question 4–Can I use old manifest forms after the final rule's January 22, 2025 effective date?

Note: For hazardous waste export and import shipments, EPA's guidance includes details about how to fill out the 5-copy manifest form during the transition from the 5-copy form to the 4-copy form. 

EPA's "Third Rule" for E-Manifests

EPA’s “third rule” related to electronic manifests or e-Manifests, published in July 2024, revised the RCRA regulations to facilitate the transition to electronic records to track the transportation of hazardous waste within, into, and out of the US. One of many updates in the rule added a requirement for generators to create accounts in the RCRAInfo system, giving them access to online e-manifests added to the system by the designated facility/receiving facility (e.g., TSDF). 

Until the third e-Manifest rule, the RCRA regulations required the use of a 5-copy paper manifest form to document the movement of hazardous waste. The 5 paper copies of the Manifest were distributed this way:

• 1 copy uploaded by the designated facility to EPA’s e-Manifest system 
• 1 copy mailed by the designated facility back to the generator 
• 1 copy provided to the transporter by the designated facility 
• 1 copy kept by the generator (the initial copy) 
• 1 copy kept by the designated facility 

Because generators can now access manifests online, the third rule eliminated the requirement for the designated facility to mail a paper copy of the manifest back to the generator.

From EPA's "third rule" on electronic Manifests:

“ …the removal of the existing paragraph (a)(2)(iv) of these sections would improve e-Manifest functionality by allowing generators to receiving final manifest copies from the system. Therefore, this final rule removes the existing final copy transmittal requirements at §§264.71(a)(2)(iv) and 265.71(a)(2)(iv)…" 

[US EPA. Final Rule, “Integrating E-Manifests…” 89 FR 60701.]

With the “final copy transmittal” requirement removed, only four copies of the manifest are needed, not five. EPA will continue accepting the 5-copy version of the Manifest for now, because some stakeholders may not yet have the 4-copy version to use.

DOT Hazmat Training to Sign the Manifest

When you sign hazmat shipping papers or the Hazardous Waste Manifest, you certify that the shipment is in full compliance with all applicable hazardous materials requirements—from classification and naming to packaging, marks, labels, placards, and more. To do this with confidence, you need a strong background in the 49 CFR Hazardous Materials Regulations (HMR).

The Hazmat & Waste Ground Shipper Certification Online Course is used by shippers nationwide to develop a complete understanding of the regulations for shipping hazardous materials and waste. Online hazmat training makes it easier to fit learning into your schedule, without putting your operations on hold. Start and stop as needed throughout the course and download resources that simplify compliance—including relevant sections of the 49 CFR regulations.  
 

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