Back in October 2012, the EPA enacted a law creating a system to track hazardous waste manifests electronically. Now over 20 years later, we are finally seeing this come to fruition. Starting in 2018, they officially started using the e-Manifest system and every two years since have released new user fee schedules.
The expenses associated with developing and operating the new e-Manifest system are recuperated through these user fees and imposed on organizations utilizing hazardous waste manifests to monitor the cradle to grave tracking of their waste materials to off-site locations.
The new fees were announced on EPA’s June 28th e-Manifest webinar and go into effect October 1, 2023. EPA calls this the Fiscal 2024 and 2025 user fees but covers from October 1, 2023 through September 30, 2025.
New Fee Schedule
| Manifest Submission Type | Fee per Manifest |
|---|---|
| Scanned Image Upload | $22.00 |
| Data + Image Upload | $10.00 |
| Electronic Manifest (Fully Electronic and Hybrid) | $6.00 |
Fee Schedule Being Replaced
Below are the current 2022 and 2023 user fees to compare to the above 2024/2025 rates.
| Manifest Submission Type | Fee per Manifest |
|---|---|
| Scanned Image Upload | $20.00 |
| Data + Image Upload | $13.00 |
| Electronic Manifest (Fully Electronic and Hybrid) | $8.00 |
The purpose of these changing schedules are to incentivize users to use the EPA’s is preferred reporting method for hazardous waste manifests. They have phased out using any mailed manifest copies and are looking to have the system fully electronically tracked. The rates mirror that intention by upping the non-preferred reporting methods and lowering the cost of the fully electronic version.
Due to the low adoption rate of electronic manifests, which is currently below 75%, the e-Manifest Board has concluded that employing the Highly Differentiated Fee model is justified. Nevertheless, the Board has cautioned that even with this fee formula, the resultant user fees will not significantly accelerate the adoption of electronic manifests. Consequently, the Board has recommended that the EPA contemplate further reductions in electronic manifest fees to encourage a higher rate of adoption.
You can read about this decision in the “Hazardous Waste Electronic Manifest System
(e-Manifest) Advisory Board Minutes.”
Methods and How We Can Help
The transition to a fully electronic system entails the elimination of paper manifests, with generators signing documents electronically. In a recent update, there is also the provision for remote signing, allowing generators to sign electronically from a remote location. EPA’s memo regarding remote signing manifests.
The data + image upload means you either typed in the manifest data into the e-Manifest system and attached a scan or used an API to push data from a waste manifest system and a scan of the manifest to e-Manifest.
The scanned image upload method is intended for companies that prefer a convenient option, and are charged at a higher premium. These companies simply upload a scanned copy of their documents in the e-Manifest web application.
e-Manifest Automation
If you are still utilizing the scanned image upload option or manually typing data into the e-Manifest web application and are interested in automating the data push process into e-Manifest, Concertive can help. We can assist you in automating the data transfer and help in reducing your e-Manifest fees.
Our developers were some of the first (possibly the first) to integrate with EPA’s e-Manifest system back in 2017 and we can help your company, save time, reduce error and lower your manifest fees.
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