From Paper to Digital: Understanding EPA’s E-Manifest Updates

The EPA is adding new requirements related to their e-Manifest system, and they affect everyone. Whether you use paper manifests, electronic manifests, or a mix of both, there are two big changes in 2025 that you need to know about.

These updates are designed to streamline hazardous waste tracking, reduce paper handling, and give EPA faster, more accurate data. But they also shift more responsibility onto generators to actively manage their e-Manifest accounts and keep documentation current.

January 22, 2025: e-Manifest Accounts Now Required

As of January 22, 2025, Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) must maintain an active e-Manifest account in EPA’s RCRAInfo system. This requirement applies whether you submit manifests electronically or continue to use paper forms.

Why the change? EPA no longer requires treatment, storage, and disposal facilities (TSDFs) to mail back a signed paper copy of the return manifest. Instead, the signed copy may be uploaded to your e-Manifest account. That means it’s now your responsibility to log in, retrieve it, and keep it with your records. If you’re not checking your account regularly, you could miss critical documentation.

Sites need at least one user with the role of Site Manager or e-Manifest Certifier to be able to receive, review, and certify documents.

December 1, 2025: New Submission Rules Take Effect

The next wave of changes kicks in on December 1, 2025, and it includes domestic and international shipments. Any generator or TSDF that files certain manifest-related reports will need to do so directly through e-Manifest. Paper submissions will no longer be accepted.

The reports affected are:

• Discrepancy Reports – Filed when waste received doesn’t match the manifest.
• Exception Reports – Filed when a generator doesn’t receive a signed return manifest within the required timeframe.
• Unmanifested Waste Reports – Filed when waste arrives at a TSDF without an accompanying manifest.

Starting 12/1/25, EPA is also:

• Linking e-Manifest data with International Movement Documents (IMDs) for imports and exports, so records for cross-border shipments are consistent across systems.
• Aligning PCB waste requirements under the Toxic Substances Control Act (TSCA) with RCRA e-Manifest rules, so PCB shipments follow the same process as hazardous waste.
• Making technical corrections to improve clarity and fix typographical errors in existing e-Manifest and movement document regulations.

What This Means for Your Facility

These updates aim to centralize hazardous waste documentation in the e-Manifest system. That means fewer paper forms, faster data sharing, and more transparency for regulators; but it also means more responsibility for you to actively manage your account and ensure your documentation is complete.

If your team is used to waiting for paper copies of return manifests or mailing physical reports, your process will need to change before the December deadline.

How to Prepare Now

1. Confirm your e-Manifest account is active and that you have at least one Site Manager or e-Manifest Certifier role assigned.
2. Train staff on how to log in, retrieve signed manifests, and submit required reports digitally.
3. Update your SOPs to remove reliance on mailed paper returns and include procedures for checking your e-Manifest account regularly.
4. If you handle PCB waste or import/export hazardous waste, review your documentation process to ensure it will meet the new alignment and linkage requirements.

If you need help making sure your facility meets these updated requirements, contact Walden’s EHS experts at 860-846-4069. Our team can assist with e-Manifest account setup, staff training, and procedural updates to ensure you’re fully prepared before the deadline.