Biennial Report Due March 1, 2026

e-Manifest applies to any facility shipping hazardous waste off-site using a manifest, including:

Generator categories:

• Large Quantity Generators (LQGs) producing 1,000 kg or more per month
• Small Quantity Generators (SQGs) producing 100–1,000 kg per month
• Very Small Quantity Generators (VSQGs), when a manifest is required

Transporters:



• DOT-licensed hazmat carriers transporting manifested waste
• Required to sign manifests electronically or submit paper copies to EPA Manifest Processing Center

TSDFs:

• Treatment, Storage, and Disposal Facilities receiving manifested waste
• Required to complete and submit manifests electronically within 30 days of receipt

Any facility shipping hazardous waste off-site using a manifest must comply with e-Manifest requirements, regardless of generator category.

Critical Deadline:

As of January 22, 2025, all LQGs and SQGs must be registered for e-Manifest. Facilities not registered cannot legally initiate hazardous waste shipments.

Step 1: Generator Initiates Manifest

Facility logs into EPA's e-Manifest portal through the Central Data Exchange (CDX) system. The generator creates a new manifest by entering waste type, quantity, EPA waste codes, and destination TSDF information. Manifest is saved and ready for transporter signature.

Step 2: Transporter Signs Electronically

When waste is picked up, the transporter logs into e-Manifest and signs the manifest electronically. Printed copy accompanies shipment to satisfy Department of Transportation (DOT) requirements during transport.

Step 3: Receiving Facility Completes Manifest

When waste arrives at TSDF, the facility logs in, receives the shipment, and completes the manifest by electronically signing and submitting it to the EPA. TSDF must complete the manifest within 30 days of receipt to avoid "unmatched" status.

Step 4: Data Stored in National System

All manifest data flows into EPA's central database, providing regulators and generators with real-time tracking. Generators can access completed manifests through the RCRAInfo portal; Certificates of Disposal are issued separately by receiving TSDFs when applicable.

This process eliminates paper submission requirements and provides immediate notification if discrepancies or rejections occur.

For Generators:

• Real-time tracking of waste shipments from pickup to final disposal
• Immediate access to completed manifests once TSDFs submit
• Integration with biennial reporting, reducing manual data entry
• Lower processing fees compared to paper manifests
• Faster identification and correction of manifest errors

For Transporters and TSDFs:

• Streamlined manifest completion and submission
• Reduced paperwork and filing requirements
• Improved coordination with generators and regulators

For Regulators:

• Centralized data for compliance monitoring and enforcement
• Improved accuracy in waste tracking and reporting
• Faster detection of illegal dumping or manifest fraud

Industry-Wide Impact:

EPA estimates e-Manifest saves the waste management industry $75–90 million annually in administrative costs.

To use e-Manifest, facilities must register through EPA's Central Data Exchange (CDX):

Registration Steps:

1. Create CDX account at cdx.epa.gov
2. Register for e-Manifest access under RCRAInfo program
3. Obtain signatory authorization to electronically sign manifests

Transporters and TSDFs must also register and obtain authorization to sign manifests in the system.

Important: As of January 22, 2025, all LQGs and SQGs must be registered for e-Manifest. Facilities not registered cannot legally initiate hazardous waste shipments. Registration delays cause operational disruptions—register early to ensure uninterrupted waste shipments.

EPA charges manifest processing fees to fund system operation:

Fully electronic manifest

Processing Fee: $4

Paper manifest (manual data entry)

Processing Fee: $20+

Hybrid manifest (scanned/uploaded)

Processing Fee: $10–15

TSDFs are billed monthly by EPA based on number of manifests processed. Some TSDFs pass portion of these fees to generators as part of disposal costs.

Processing fees for paper manifests are significantly higher than for fully electronic manifests. Facilities transitioning from paper to electronic manifests reduce processing fees by up to 80%.

Paper Manifest Limitations:

Facilities can still use paper manifests, but they must follow updated submission procedures:

• Top copy must be mailed or uploaded to EPA Manifest Processing Center
• EPA manually enters data into e-Manifest
• Processing fees significantly higher than electronic submission
• As of January 22, 2025, paper manifest corrections are no longer accepted by EPA; all corrections must be submitted electronically through the e-Manifest system.

Facilities using paper manifests experience longer processing times and delayed access to completed manifests.

e-Manifest integrates with EPA's biennial reporting process. Large Quantity Generators (LQGs) are required to file Biennial Hazardous Waste Report by March 1 of each even year (next deadline: March 1, 2026).

e-Manifest simplifies biennial reporting by:

• Storing all manifest data electronically in central database
• Providing pre-populated reports based on submitted manifests
• Reducing manual data entry and calculation errors

However: Facilities must still reconcile e-Manifest records with Certificates of Disposal to ensure all shipments are accounted for before filing. Unmatched manifests—shipments where TSDF has not completed manifest within 30 days—create gaps in biennial reporting data.

Facilities that reconcile manifests quarterly rather than waiting until February avoid last-minute data gaps and filing delays.

Registration Delays

Many facilities delay registration until they need to ship waste, causing operational disruptions. Register early to ensure uninterrupted waste shipments.

Manifest Corrections

Errors in waste codes, quantities, or TSDF information require electronic corrections through e-Manifest portal. Paper corrections are no longer accepted as of January 22, 2025.

Unmatched Manifests

If TSDF does not complete manifest within 30 days, shipment appears as "unmatched" in system. This creates reconciliation issues for biennial reporting and may indicate delivery problem. Generators should follow up with TSDF to resolve unmatched manifests.

Biennial Report Reconciliation

LQGs must reconcile e-Manifest data with Certificates of Disposal before filing biennial reports. Facilities that wait until January to start this process often discover missing or incomplete records.

U.S. Waste Industries helps facilities navigate e-Manifest requirements and maintain compliance with EPA tracking regulations. Since e-Manifest launched in 2018, we've worked with clients to transition from paper to electronic manifests, reconcile manifest data, and prepare for biennial reporting deadlines.

Our e-Manifest support includes:

• Manifest creation and submission—we can draft electronic manifests on behalf of clients, reducing administrative workload and ensuring accuracy
• Registration guidance—we provide support for CDX registration and signatory authorization
• Manifest reconciliation—we help clients reconcile e-Manifest data with Certificates of Disposal before biennial reporting deadlines
• TSDF coordination—we communicate with destination facilities to ensure manifests are completed and closed in EPA system
• Fee minimization—we assist clients in transitioning from paper to electronic manifests to reduce processing costs
  

Service-Driven: e-Manifest Expertise Since 2018

We've supported clients through e-Manifest transition from paper-based tracking to electronic submission, helping hundreds of facilities register, reconcile data, and prepare biennial reports. Our team understands EPA's CDX portal, RCRAInfo system, and manifest reconciliation requirements—eliminating administrative burden while ensuring complete compliance documentation.

Client-Focused: Direct Access and Proactive Support

Family-owned business with 25+ years managing hazardous waste compliance. Real people answer phones 7 AM–5 PM weekdays with direct project manager access. We proactively reconcile e-Manifest data quarterly—not in February when biennial reports are due—catching unmatched manifests and missing records before they become filing problems.

Guaranteed Compliance: Inspection-Ready Records

Every hazardous waste shipment includes EPA e-Manifest submission or proper paper manifest handling, Certificates of Disposal from receiving TSDFs, waste profiles and characterization documentation, and biennial reporting support for LQGs. This documentation satisfies EPA requirements, protects facilities during inspections, and eliminates last-minute scrambling before March 1 deadlines.