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Searching for e-Manifest deadline information related to the EPA’s Third Final Rule? Managing hazardous waste is no small task. According to the EPA, the U.S. generates close to 35 million tons of hazardous waste every year. This waste requires precise tracking and reporting to ensure public safety and environmental protection. And non-compliance carries many risks to businesses beyond external impacts. It can lead to hefty fines, operational setbacks, and damage to a business’s reputation. That’s why it’s critical to adhere to all federal, state, and local regulations while keeping up-to-date on changes in policy and required actions.
Which brings us to the 2025 e-Manifest deadline. 2025 is a big year in hazardous waste management. This initiative, spearheaded by the EPA under the Third Rule, aims to modernize and streamline how hazardous waste is tracked, reported, and monitored across the country. By mandating digital documentation, the e-Manifest system is designed to help enhance transparency, reduce paperwork, and improve regulatory oversight.
With such major changes, it’s important to understand these key updates introduced by the 2025 e-Manifest deadline. Whether you’re a large or small quantity generator (LQGs and SQGs), it’s essential to know what steps your business needs to take to ensure compliance. Whether you’re new to e-Manifest requirements or looking to optimize your processes, now is the perfect time to determine how these new changes will impact your business.
01 / What is the 2025 e-Manifest deadline?
The e-Manifest system is a digital platform introduced by the Environmental Protection Agency (EPA) to track hazardous waste shipments across the United States. It replaces traditional paper-based tracking with an electronic system, creating a centralized database where waste generators, transporters, and receiving facilities can document and monitor waste movement in real time.
The EPA designed the e-Manifest system to enhance transparency, reduce errors, and streamline the hazardous waste management process. By transitioning to a digital format, the system minimizes the risks associated with lost or inaccurate records. It also promises to support regulatory compliance and simplify reporting requirements for all stakeholders involved.
Key Hazardous Waste Tracking Updates and Changes for 2025
Mandatory Registration: Starting on January 22, 2025, LQGs and SQGs must register for e-Manifest. This process begins with going to the RCRAInfo website of the EPA. The agency also provides guidelines on how to register. The only exceptions to this new rule are Very Small Quantity Generators (VSQGs) and generators of Polychlorinated Biphenyl (PCB). They must also maintain at least one user who has access to the system.
Registered generators will now access and manage their paper or electronic manifests through their e-Manifest accounts. January 22, 2025 also marks a change with manifests. From this day forward, receiving facilities will no longer mail completed manifests to LQGs and SQGs. Instead, generators must maintain e-Manifest accounts to retrieve finalized signed manifests directly from the system. Generators that use the hybrid manifest will still need to retain their paper copies for the 3-year retention period.
The July 2024 e-Manifest Third Final Rule mandates that all waste handlers using RCRA manifests under federal or state law transition to the new 4-copy manifest (EPA Form 8700-22) and continuation sheet (EPA Form 8700-22A) by January 22, 2025. The 4-copy form eliminates Page 3 (“Designated Facility Copy”) as facilities can now upload and retain completed manifests directly through the e-Manifest system. While the EPA will accept Page 1 copies of the outdated 5-copy form until December 1, 2025, users are encouraged to adopt the new form immediately, as all waste handlers must fully transition by that date. After December 1, 2025, the EPA will no longer accept obsolete 5-copy forms.
02 / EPA Third Rule Compliance
There have been two previous policy announcements by the EPA, termed respectively the One Year Rule and the User Fee Rule. The next, issued on July 26, 2024 finalized details of the e-Manifest and is fittingly referred to as the Third Final Rule.
The EPA's e-Manifest Third Final Rule incorporates hazardous waste export regulations particularly export manifests and related reports, including Discrepancy, Exception, and Unmanifested Waste Reports, into the e-Manifest system and updates manifest requirements for polychlorinated biphenyls under the Toxic Substances Control Act.
Understand the Impact of the Third Final Rule
Generator Registration Updates: Small Quantity Generators (SQGs) and Large Quantity Generators (LQGs) must register with e-Manifest to access their finalized signed manifests.
Inclusion of Export Manifests: Hazardous waste export manifests must now be submitted through the e-Manifest system, with exporters responsible for submission and user fees.
Expanded Data Requirements: Additional international shipment data elements are now required on the manifest form.
Improved Integration with EPA Systems: Manifest data and movement documents are better linked to integrate with the EPA’s Waste Import Export Tracking System (WIETS) within RCRA Info.
Electronic Reporting: Exception Reports, Discrepancy Reports, and Unmanifested Waste Reports must now be submitted electronically through e-Manifest.
Data Correction Requirements: Entities are required to correct errors in submitted manifest data.
Updates to PCB Regulations: Changes align PCB manifest regulations under the Toxic Substances Control Act (TSCA) with the e-Manifest program, along with technical corrections to improve accuracy and remove outdated requirements.
Why The 2025 e-Manifest Changes Matter
The EPA Third Rule represents a critical shift in hazardous waste management practices. By moving to a digital-first approach, the EPA is signaling a major shift that will encourage more accessibility via the electronic system. For waste generators, these changes may require some guidance and professional insight. MCF Environmental Services has the experience to help both LQGs and SQGs make a seamless transition to this new electronic format.
03 / How the 2025 e-Manifest Deadline Impacts Generators
The 2025 e-Manifest deadline introduces significant changes for both Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs), with tailored requirements to address the scale and complexity of their operations.
Large Quantity Generators (LQGs):
New Tracking and Reporting Expectations: LQGs must adopt the e-Manifest system for all hazardous waste shipments, ensuring detailed and accurate records are submitted electronically.
Additional Documentation Requirements: Compliance now demands more thorough documentation, with tighter deadlines for data entry and submission, increasing the need for operational efficiency.
Small Quantity Generators (SQGs):
Scaled Requirements for Smaller Operations: While SQGs face fewer reporting obligations than LQGs, they are still required to transition to the e-Manifest system for waste tracking and reporting,
Potential Penalties for Non-Compliance: SQGs must adhere to deadlines and documentation standards to avoid fines or operational delays, even if their processes are less complex than those of LQGs.
Export Regulations Impact:
Tracking Across Borders: Waste exporters must comply with enhanced tracking requirements to ensure hazardous waste shipments meet both domestic and international regulations.
Accurate Documentation: The e-Manifest system now integrates with export documentation, requiring meticulous attention to detail to avoid delays or legal issues during transit.
04 / 2025 e-Manifest Challenges for Hazardous Waste Generators
Your business is probably not set up to be an expert in the administrative side of hazardous waste storage, transportation and disposal. At MCF Environmental Services, we provide the expertise in all parts of the process, so your team can get back to growing your business. There are two areas waste generations should be particularly aware of as they transition to this new e-Manifest system:
Cost and Time Required for Transition
Implementing the e-Manifest system may require investment in new software, training for staff, and updates to existing workflows, which could be a financial and operational strain for some organizations. The best approach is to save time and resources and consult with an experienced full-service waste disposal service. At MCF, we offer guidance and answers to any questions along the way, positioning ourselves as a trusted partner to help you smoothly navigate the challenges of change.
Potential for Technical or Process-Related Hiccups
Adopting any new technology comes with risks, such as software glitches, integration issues, or resistance to change from employees unfamiliar with the system. While the e-Manifest system brings long-term efficiency and compliance benefits, careful planning and resource allocation will be key to overcoming these initial hurdles and ensuring a smooth transition for all hazardous waste generators.
If you’re concerned about getting all of the details correct as the 2025 deadline arrives for e-Manifest Third Rule changes, don’t stress. Reach out to MCF Environmental Services. Our team has the experience and know-how to make your transition to digital reporting smooth and worry-free. Don’t risk non-compliance penalties over a simple mistake. Schedule a consultation soon!
05 / FAQs on 2025 e-Manifest Changes
What is the EPA Third Rule compliance for hazardous waste generators?
The EPA Third Rule introduces mandatory use of the e-Manifest system, requiring hazardous waste generators, transporters, and receiving facilities to adopt digital tracking and reporting. Key updates include stricter documentation standards, enhanced export regulations, and improved transparency in waste management processes.
Who does the 2025 e-Manifest deadline affect?
The e-Manifest deadline impacts Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs), along with transporters and receiving facilities involved in hazardous waste handling. It also includes waste exporters, who must comply with updated international tracking and reporting requirements.
How can I prepare for the e-Manifest system?
To prepare, assess your current waste tracking practices, invest in digital tools that integrate with the e-Manifest platform, and train your staff on new compliance processes. Stay updated on EPA guidance and take advantage of webinars, workshops, and professional consultations to ensure a smooth transition.
Robert Losurdo
President, COO
