e-Manifest Registration Required by January 22, 2025

On January 22, 2025, the e-Manifest Third Rule will take effect, streamlining hazardous waste tracking and compliance processes. LQGs and SQGs must be registered in the e-Manifest system with a designated Site Manager or Certifier for each of their generators..

Why is EPA requiring this registration? EPA wants all correspondence and updates related to a manifest to be in the e-Manifest system. corrections and correspondence related to manifests are captured electronically within the e-Manifest system. To facilitate this process, it is necessary for an authorized representative of each regulated generator to be registered in the system. This ensures they can receive communications and make necessary updates to manifests efficiently and in compliance with the new.

For this reason registration and some reporting and corrections are required by January 22, 2025. However, many of the requirements from the Third Rule do not take place until December 1, 2025.

On July 26, 2024, the Third and final rule for the Resource Conservation and Recovery Act regarding the e-Manifest System was published by the EPA and it changes a lot for small and large quantity generators.


Additional Information

(Below information is from epa.gov)

On July 26, 2024, EPA published the final Third Rule. This rule amends certain aspects of the hazardous waste manifest regulations under the Resource Conservation and Recovery Act, specifically about the e-Manifest system. A manifest accompanies shipments of hazardous waste. 

This rule is intended to reduce the reporting burden on industry and states, increase information availability, improve compliance monitoring, and prepare for future potential integration with biennial reporting requirements. EPA aims to modernize and streamline the manifest process, increasing expected benefits of the e-Manifest system and encouraging further adoption of electronic manifests through increased utility of the system.

The final rule:

  • Incorporates hazardous waste export manifests into the e-Manifest system, which includes designating the exporter as the entity responsible for submitting the manifest and paying the requisite user fee. 
  • Expands the required international shipment data elements on the manifest form. 
  • Revises the movement document requirements to more closely link the manifest data with the movement document data for manifest tracking purposes as well as to assist with integration of EPA’s Waste Import Export Tracking System into RCRAInfo. 
  • Integrates Exception Reports, Discrepancy Reports, and Unmanifested Waste Reports into e-Manifest. 
  • Requires small and large quantity generators to register for access to e-Manifest to obtain their final signed manifest copies from the system. 
  • Requires entities to correct manifest data errors. 
  • Makes conforming changes to polychlorinated biphenyl manifest regulations under the Toxic Substances Control Act, and other technical corrections to remove obsolete requirements, correct typographical errors, establish definitions, and/or improve alignment with the e-Manifest program. 

More Information

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