Frequent Questions about e-Manifest

On this page:

General
Generators
Receiving Facilities
Manifest Preparation, Brokers
Transporters
Federal and State Implementation
Fee Obligations
Record Retention and Distribution
Data Policy and Data Correction
System-Specific Questions
User Registration
Invoices/Payments
Polychlorinated Biphenyls (PCBs)

General

1. What is an electronic manifest?

An electronic manifest is the electronic format of the uniform hazardous waste manifest obtained and completed through the e-Manifest system. (Manifests obtained through registered printers are referred to as paper-based manifests.)

The manifest is used to track hazardous waste from the time it leaves the generator facility where the waste was generated until it reaches the designated receiving facility that will treat, store, or dispose of the hazardous waste.

Electronic manifests can also be updated, signed, corrected, and stored in the EPA’s e-Manifest system (also referred to as e-Manifest), which acts as the national repository and central hub for manifest data for use by EPA, states, and industry.

2. How can I access the e-Manifest system?

The e-Manifest system is a module component of the Resource Conservation and Recovery Act (RCRA) Information System (RCRAInfo), an IT system used by EPA, states, and industry to report and track RCRA regulated hazardous waste activity. To access your manifests through RCRAInfo, you’ll need the following:

An EPA RCRA site identification number (EPA ID)
1. This is a unique twelve-character alphanumeric assigned to a physical location (or transporter) that identifies a site where hazardous waste activity is conducted.
  Learn more about obtaining an EPA ID.
A RCRAInfo user account
1. After you’ve obtained an EPA ID, register for a free account on our RCRAInfo webpage. You’ll need to request access to your EPA ID, which will be approved by state regulators or an existing Site Manager if one is present.
  Learn more about permission levels.

After the above pre-requisites have been met, you will be able to find all manifests associated with your EPA ID in RCRAInfo under the e-Manifest module.

3. Does the e-Manifest system collect paper manifests?

Yes, the e-Manifest system stores final copies of all manifests, both electronic and paper. Receiving facilities that receive waste that must be manifested under federal, or state law must submit those manifests to EPA using one of the available submission options. Once submitted, states and industry can make corrections to their paper manifest data electronically in e-Manifest through the post-receipts corrections process; the system retains an auditable record of all such corrections.

4. Is the e-Manifest system free?

Users are not charged a fee for registering or using the e-Manifest system to create, update, sign, view, or correct their manifests. However, receiving facilities are responsible for paying a per manifest user fee that accrues when they submit the final signed manifest to EPA’s e-Manifest system. EPA sets user fees based on the costs of processing manifests and according to a formula in the RCRA regulations. EPA updates these user fees every two fiscal years.

5. Can I sign electronic manifests without registering?

Yes, there are a couple ways that field personnel, employees and contractors with direct physical responsibility for the waste shipment, can sign electronic manifests through a Remote Signer, a registered user in RCRAInfo with sufficient access to sign electronic manifest. The field personnel does not need to be registered in either scenario:

The field personnel can communicate with another employee (a Remote Signer) who is registered and can execute the electronic signature in the e-Manifest system
Field personnel may use their site’s waste management software to execute electronic signatures through system-to-system communication with the e-Manifest system. In this instance, the Remote Signer is the individual whose credentials are used for system-to-system communication.

Either method requires that the site seeking to sign an electronic manifest must have a registered user in RCRAInfo prior to the shipment. For additional information, refer to the Remote Signer Policy (pdf)(376 KB).

6. What documents besides the manifest form and continuation sheets are collected by EPA? What about land disposal restriction (LDR) notices?

The e-Manifest system currently focuses only on manifests and continuation sheets involving the shipment of wastes that require a manifest under federal law (federal RCRA or regulated polychlorinated biphenyl waste) as well as the manifests and continuation sheets involving state-only regulated wastes subject to manifest requirements under state law. We do not process LDR notices or any other non-manifest documents.

7. What is a hybrid manifest?

The hybrid or mixed paper/electronic manifest is a specific manifest approach that EPA adopted to assist generators who are not able to fully participate in electronic manifesting at the time of system launch. The hybrid manifest allows transporters to initiate an electronic manifest in e-Manifest and use this manifest with their non-participating generator customers. The initial transporter may print a copy of the electronic manifest for the generator, and the generator may sign the paper copy, obtain the initial transporter's ink signature on this paper copy, and then retain this paper copy on-site as the generator's initial manifest copy as is done under traditional manifest requirements. Thereafter, the initial transporter and subsequent waste handlers complete the remainder of the tracking of the shipment electronically in e-Manifest with electronic signatures and electronic transmissions to the system. Hybrid manifests are charged the same fee as a fully electronic manifest.

8. What manifests are required to be submitted to e-Manifest?

E-Manifest collects manifests that contain any of the following waste:

Federal hazardous waste.
TSCA waste (e.g., PCB waste).
Waste that is regulated as hazardous waste by either the generator's state or the receiving facility's state.

If either the generation state or receiving state requires a manifest during the movement of the waste shipment, then the receiving facility must submit the manifest to the system and pay any applicable fees associated with that manifest. For more information visit: State-only Hazardous Waste Subject to RCRA Manifests webpage.

Manifest requirements of transit-only states (states through which waste is transported in route to a designated facility) do not trigger e-Manifest submission requirements.

If the wastes listed on a manifest are not required by federal or state law to be shipped under a manifest, then there is no requirement that such manifests be submitted to EPA. However, please refer to the “Receiving Facilities” section for further explanation of manifest requirements when a generator relies on waste determinations from the receiving facility.

9. Are imported and exported wastes shipped on a manifest included in e-Manifest?

Yes. The e-Manifest system tracks import manifests and, beginning on December 1, 2025, the system will also track export manifests. Import manifests are initiated by the domestic importer; their tracking is not that different than any other domestic waste shipment. Beginning on December 1, 2025, domestic exporters must submit export manifests to e-Manifest and pay the requisite user fees.

10. How do the e-Manifest requirements apply to VSQGs who ship their hazardous waste to a LQG for consolidation?

In the Generator Improvements Rule, EPA promulgated a regulation to allow VSQGs to ship their hazardous waste off-site to an LQG for consolidation if the VSQG and the LQG are under the control of the same person, and the VSQG complies with specific conditions for marking its containers. Under the federal rules, if a VSQG meets the conditions for shipment to LQGs under control of the same person, the shipments to the LQG are not required to use a RCRA manifest to track these shipments. Shipments of waste not subject to the manifest under either federal or state law are not subject to e-Manifest requirements.

Note that states authorized for the RCRA program must adopt the provision allowing consolidation of VSQG waste at an LQG before entities within that state can start operating under the provision. In addition, states can be more stringent in their regulations. For site-specific questions, please contact your authorized state.

11. How does e-Manifest apply to rail shipments?

Current regulations require the rail company receiving hazardous waste for transport to sign the manifest at the rail company office and then forward the manifest copies to the next non-rail transporter or to the receiving facility. Rail companies that receive electronic manifests are able to designate a company official to register with e-Manifest and to sign manifests received at the rail company electronically rather than with ink signatures. Also, the signed manifests may then be forwarded electronically by e-Manifest to the next non-rail transporter or the receiving facility.

12. When a shipment involves multiple rail transporters, what are the procedures for identifying the transporters on the manifest and obtaining rail transporter signatures?

Transportation of hazardous waste by rail involves special manifest procedures. Under Title 40 of the Code of Federal Regulations (CFR) sections 262.23(d) and 263.20(f) (and equivalent authorized state regulations), only the initial rail transporter must be listed in the transporter fields of the manifest. The initial rail transporter must sign and date the manifest (typically from the rail company’s office) to acknowledge accepting the waste for transportation in the rail system and then return a signed copy to the generator or non-rail transporter from which it accepted the waste. The remaining copies of the manifest are then forwarded to the next non-rail transporter or to the designated facility for further manifest tracking after the waste shipment leaves the rail system. Thus, when there are multiple rail transporters involved with the transport of hazardous wastes, the manifest only tracks delivery to the first rail transporter, and there is no identification on the manifest of the subsequent rail transporters nor collection of signatures from them when they take custody of the hazardous wastes within the rail system.

13. Have the data elements applicable to paper manifests changed with the use of electronic manifests?

No, the basic regulations and instructions for completing an electronic manifest are not materially different from a paper manifest. The data elements remain the same; however electronic manifests can contain additional information (e.g., more than six hazardous waste codes, information for biennial reporting) that would not fit on a paper manifest. Electronic manifests that are obtained from e-Manifest are the legal equivalent to paper manifests for all RCRA purposes.

14. Are "milk-run" or "consolidated waste" manifests subject to e-Manifest's submission and fee requirements?

No. Receiving facilities need only submit manifests that apply to waste shipments for which the RCRA manifest is required under either federal or state law. “Milk run” or “consolidated waste” manifests are separate tracking documents required by states for certain state-only regulated wastes. These “milk run” manifests typically involve consolidating waste shipments from multiple generators on one manifest document, a practice that is not supported by the RCRA manifest. The user should follow state law requirements on the disposition of these manifests.

15. Are Very Small Quantity Generator (VSQG)/Conditionally Exempt Small Quantity Generator (CESQG) waste shipments subject to e-Manifest?

This answer depends on the state and if the waste contains PCBs subject to the manifesting regulations and policies per title 40 CFR part 761. In general, VSQG/CESQG waste are exempt federally from the RCRA manifest, provided the regulatory conditions for the exemptions are met. Where these exemptions are applicable (i.e., in unauthorized states and in authorized states that have adopted these manifest exemptions), these wastes are exempt from manifest requirements and therefore are not subject to e-Manifest.

However, in some authorized states, the states have elected to require manifests for VSQG/CESQG waste shipments. In such cases, the manifests required by the states to track these shipments are subject to e-Manifest.

With regards to PCB shipments, unless specifically exempted from the requirements in 40 CFR part 761 subpart K, the PCB regulations require generators to prepare a manifest on EPA Form 8700-22, and, if necessary, a continuation sheet prior to transporting regulated PCB waste. Regulated PCB waste(s) means those PCBs and PCB Items that are subject to the disposal requirements of 40 CFR part 761 subpart D. Refer to 40 CFR section 761.207 for more information.

Additionally, the federal rules addressing VSQGs require manifests for certain episodic waste events at VSQGs. When such an episodic event occurs, and the VSQG rules apply, then these shipments and their manifests would be subject to e-Manifest.

16. Are Household Hazardous Waste (HHW) shipments subject to e-Manifest?

Generally, Household Hazardous Wastes (HHWs) are exempt federally from the RCRA manifest, when the regulatory conditions for the HHW exemption are met. In those cases where the HHW exemption applies and the regulatory conditions are met, these HHW shipments are exempt from manifest requirements and are therefore not subject to e-Manifest.

However, in some authorized states, the states have elected to require manifests for some HHW shipments (e.g., shipments that occur after HHW has been collected from HHW collection programs). In such cases, the manifests required by the states to track such HHW shipments are subject to e-Manifest.

17. Are wastes managed under the RCRA precious metals exemption subject to e-Manifest submission and fee requirements?

Yes. Wastes that are subject to the RCRA precious metals exemption are required to use a RCRA manifest, thus, the receiving facility must submit these manifests to EPA and pay the applicable user fee.

18. Are low-level mixed waste shipments subject to e-Manifest?

No. Low-level mixed radioactive/hazardous wastes are subject to a conditional exemption from the definition of hazardous waste that is codified at 40 CFR part 266, subpart N. Among these Subpart N provisions is a conditional exemption at 40 CFR section 266.305 et seq. that applies to the transportation and disposal of these wastes. These low-level mixed wastes are exempt from RCRA transportation requirements, including the RCRA manifest, when they are shipped for disposal to designated low-level radioactive waste disposal facilities (LLRWDFs) under the conditions of the exemption. These conditions include the use of the NRC’s Uniform Low-Level Radioactive Waste Manifest for tracking the transportation of these wastes. Since these low-level mixed waste shipments are subject to the NRC’s manifest, and not the RCRA manifest, these waste shipments are not subject to e-Manifest. Those involved in the transportation and receipt of these radioactive wastes should not submit the NRC manifest to e-Manifest.

Generators

1. Do generators have to register for e-Manifest?

Beginning January 22, 2025, Large and Small Quantity Generators (LQGs and SQGs) are required to register for e-Manifest through RCRAInfo. For more information, refer to How to Register.

However, Very Small Quantity Generators (VSQGs) and Polychlorinated Biphenyl (PCB) generators are not required to register.

2. How do generators, who are not required to register in e-Manifest, receive a copy of the completed manifest?

Generators that are not required to register for e-Manifest must make arrangements with their receiving facilities to supply the generators with paper copies of completed manifests. The e-Manifest system can be used to supply electronic copies of completed manifests to generators with an EPA ID and a registered user.

3. Does the generator have to submit the generator copy of the manifest to EPA?

No, generators do not have to submit paper manifests to EPA. EPA only collects paper manifests from the receiving facility.

4. What happens if a generator is ready to sign manifests electronically in EPA's e-Manifest system, but the transporter or receiving facility is not set up to sign electronically?

For a generator to sign electronic manifests in e-Manifest, all other entities in the chain must also be able to sign electronically in e-Manifest. If the transporter or receiving facility is unable to sign electronically, the generator must use a paper manifest.

5. Can generators use the e-Manifest system to keep records of their manifests?

Yes. Registered generators can use their e-Manifest accounts to store and retrieve their manifest copies for paper and electronic manifests. Starting January 22, 2025, receiving facilities will no longer be required to mail completed manifests back to LQGs and SQGs. Additionally, LQGs and SQGs are required to maintain e-Manifest accounts to access their final signed manifests from the e-Manifest system.

For paper manifest users, an image of the final manifest copy is uploaded to e-Manifest. Copies of the image are available for registered generators to view and correct. Under the federal manifest regulations, the generator’s initial paper copy may be discarded and replaced by the final manifest copy in e-Manifest to meet their recordkeeping requirements once the image file of the final manifest is available in their account.

Note, however, that this policy (discarding the initial paper copy) does not apply to generators that use the hybrid manifest. Such generators must retain their initial paper copy among their records for the entire 3-year record retention period, since this initial, paper copy is the only copy of the manifest that includes the generator’s signature on the generator/offeror certification. Also, generators should take into consideration any additional reporting requirements relevant to their state before discarding the initial copy, such as sending the generator initial copy directly to the state.

6. Can generators use e-Manifest for RCRA inspections?

Yes. Generators that are registered and maintain access to e-Manifest can use the records stored in e-Manifest to satisfy the manifest recordkeeping requirements. (Note that, beginning January 22, 2025, LQGS and SQGs are required to maintain an e-Manifest account). Generators can also print hard copies of their manifests from the system at the request of a federal or state inspector. Federal or state inspectors can also use e-Manifest to perform manifest reviews prior to conducting an on-site inspection, and obtain copies of the manifests prior, and subsequent, to the inspection.

7. Is there an explicit regulatory requirement that generators are monitoring their manifests in the system and verifying the receipt of their wastes by receiving facilities?

Under the manifest regulations, there is an explicit requirement that generators conduct exception reporting, and this requires the generators to monitor their electronic and paper manifests to verify that all their waste shipments are received in a timely manner by the facility designated on their manifests. With both paper and electronic manifests, the generator is obliged to inquire of transporters and receiving facilities when their final manifest copies appear overdue, and to report exceptions to state or regional officials when these shipment exceptions cannot be reconciled within regulatory time frames.

8. How does e-Manifest affect Exception Reporting by generators?

Beginning December 1, 2025, generators must submit all Exception Reports electronically through e-Manifest unless the generator is categorized as a VSQG or PCB generator.

Also, as of January 22, 2025, the timeframe requirements for Exception Reports have changed to be:

If a signed copy of the manifest has not been submitted within 45 days of the date the waste was accepted by the initial transporter, LQGs must inquire of the transporter or designated facility on the status of its waste.
If a signed copy of the manifest has not been submitted within 60 days of the date the waste was accepted by the initial transporter, LQGs and SQGs must submit an Exception Report.

Please note, with paper manifests, receiving facilities have up to 30 days from delivery to submit its final copy to e-Manifest. After being received by EPA, scanned image uploads of the paper manifests need additional time to be processed and entered into the system.

9. Must I get an EPA ID Number for emergency response, remediation sites, or other transitory generation sites?

Yes. The RCRA regulations generally require that generators must not transport or offer hazardous waste for off-site transport unless the generator has obtained an EPA Identification Number. Further, the transporter requirements state that a transporter must not transport hazardous waste without having received an EPA Identification Number.

The RCRA Subtitle C regulations generally do not distinguish between sites at which hazardous waste is generated on an ongoing basis versus waste generated from a single event. Thus, on-scene coordinators, other generators, or transporters responding to emergency response sites, remediation sites, or spill/discharge events must typically submit the EPA Site ID Form (Form 8700-12) to their EPA Region or authorized state agency to obtain an EPA ID Number, or where appropriate, request from their regulator a provisional or emergency ID Number.

Provisional or temporary ID Numbers are issued to sites that are not sites of ongoing industrial processes but are instead remediation sites or sites involved with “one-time” generation events. Provisional ID Numbers are issued after submission of the Site ID Form, but they may be of limited duration. Emergency ID Numbers are for those spill or discharge events where the generation of waste is unforeseen and short-term. One responding to such an emergency typically would not need to submit a complete Site ID Form to obtain an Emergency ID Number but could instead provide provisional details over the phone about the incident and obtain an Emergency ID Number for use on its manifests.

In addition, EPA has implemented in RCRAInfo a means for states to opt into a process for the immediate, electronic issuance of ID Numbers in response to emergencies. Where states opt into this electronic process, users needing ID Numbers in the face of emergency circumstances will have another, expedited means for obtaining an ID that will not necessitate even a phone call to their regulator.

An existing federal transporter regulation (40 CFR section 263.30(b)) provides authority for EPA or state officials to waive manifest preparation requirements and the requirement to use transporters with EPA ID Numbers to respond to certain discharge events during transportation for which it is determined by the government official that the immediate removal of the waste is necessary to protect human health and the environment. This authority is seldom used however, because the more common practice in such cases is to instead promptly issue provisional or emergency ID numbers for these sites and events, rather than waivers. Nevertheless, in exceptional cases where time is of the essence, and an immediate response to a spill or other emergency is necessary to protect human health or the environment, existing EPA policy provides that officials may waive the EPA Identification Number requirements for the generators and transporters that are engaged in immediate hazardous waste removal in response to a discharge or other emergency incident. Refer to Program Implementation Guidance on Issuance of Provisional EPA I.D. Numbers, RCRA Online # RO 12016, November 26, 1980. Such waivers should be reserved for those emergency events for which it would not be reasonable to defer the response action until an ID Number is issued.

Otherwise, when an EPA ID Number, or provisional or emergency ID Number is obtained for the affected site, the person responsible as generator or offeror for off-site shipments from the remediation, discharge or other transitory site must use the ID Number issued to it in completing its paper or electronic manifests.

If the response action is an emergency removal action for which a waiver of the ID number requirement has been granted, then in these circumstances, the paper manifest should be used, with the Generator ID Number field left blank, and a statement in Item 14 explaining that an ID Number waiver was granted because of the emergency, and a brief description of the emergency event justifying the waiver.

10. Are temporary or provisional facilities without EPA IDs subject to e-Manifest?

If a manifest is required for shipments from these facilities under federal or state law, then these facilities are subject to e-Manifest. However, without an EPA ID the temporary site will only be able to complete hybrid manifests (or continue to use paper), as an EPA ID number is required for fully electronic manifests. If it is desired to use fully electronic manifests, then these sites must obtain an EPA ID before completing any electronic manifests by filing EPA Form 8700-12 with the EPA Region or authorized state or requesting one through the myRCRAid module in RCRAInfo.

11. Do VSQGs need EPA ID Numbers?

VSQGs (formerly CESQG) are generally exempt from needing EPA ID numbers. However, in some authorized states, the states have elected to require VSQGs to obtain EPA ID numbers. Additionally, federal rules require manifests for certain VSQG episodic waste events, and in these cases, the VSQG must also obtain an EPA ID Number by submitting the EPA Site ID Form 8700-12. If a VSQG has obtained an EPA ID number, it should be used on all manifests.

In those circumstances where e-Manifest applies to VSQG shipments (other than for episodic event shipments), an EPA ID Number is not required if the VSQG uses a paper manifest to track its waste. In such cases, the VSQG generator could complete its paper manifest by supplying all the other information required on the manifest form to identify the generator. However, if a VSQG wishes to use electronic manifests or have the ability to correct manifests post-receipt, then it must obtain an EPA ID Number. To do this, a VSQG should file the Site ID Form (refer to the link above). (If a VSQG/CESQG has a unique state-issued ID, please contact your state on whether this could be transferred to EPA for use for electronic manifesting.)

12. How many waste codes must be entered on electronic manifests?

The regulations provide that the generator must include the federal and state waste codes that best represent the waste and its hazards on the manifest. Where there are multiple codes that apply to a waste, the regulations provide that up to six federal and state codes can be entered on the form, and the paper form provides six data fields per waste for this purpose.

Electronic manifests, however, are not limited by the physical space constraints that limit paper form users to entering at most six codes. While entering six waste codes per waste for electronic manifests will suffice for regulatory compliance, users of electronic manifests may enter more than six waste codes, if so desired.

13. What is required on the manifest for shipment of non-creditable hazardous waste pharmaceuticals?

For more information refer to: Frequent Questions about Manifesting Non-creditable Hazardous Waste Pharmaceuticals.

Receiving Facilities

1. How soon after receiving a manifest do I need to submit to e-Manifest?

Receiving facilities must submit paper manifests within 30 days of the delivery of the waste to the receiving facility. Electronic manifests, of course, are created, transmitted, and signed in the e-Manifest system.

However, a receiving facility may reject a waste shipment immediately in full and use the original manifest to forward the waste shipment to an alternate facility or generator. In such cases, the receiving facility must sign and date the original manifest. However, the manifest is not completed by the execution of the signature and should not be submitted to the e-Manifest system at that time.

An alternate facility must submit the completed, original manifest to the e-Manifest system within 30 days of delivery of the waste to the facility. The generator must return the completed, original manifest to the rejecting facility that returned the shipment to the generator within 30 days of receipt of the rejected shipment. The rejecting facility must submit the completed, original manifest to the e-Manifest system within 30 days of receipt of the manifest from the generator.

2. Can a receiving facility sign for a transporter?

No. The "on behalf of" signature authorities only apply in limited instances to generator signature requirements.

3. How can receiving facilities supply generators with the required final copies of their paper manifest?

If the generator has an EPA ID and is registered with e-Manifest, then the image file submitted to the e-Manifest system is delivered to the generator’s e-Manifest account when the image file is uploaded by the receiving facility. Beginning January 2025, LQGs and SQGs are required to maintain an e-Manifest account; receiving facilities are no longer required to mail completed manifests back to LQGs and SQGs.

For VSQG and PCB generators who do not have an EPA ID and a registered user, the receiving facility may satisfy the requirement by sending the final manifest copy in the mail, as has been the practice for many years. Receiving facilities can use e-Manifest to determine when a VSQG or PCB generator is able to use e-Manifest to meet their recordkeeping requirements. Receiving facilities can search for the generator’s EPA ID in RCRAInfo, there is a Yes/No flag showing whether or not a site has a registered e-Manifest user.

example of what it looks like to type in generator information

4. Can I certify receipt of a manifest with a bulk waste discrepancy of less than 10%? Does this manifest require a correction?

The e-Manifest requirements, including the post-receipt data corrections process, do not alter the existing discrepancy reporting requirements. In other words, for bulk wastes, there is not a “significant discrepancy” requiring follow-up and reporting if the receiving facility finds that the quantity it measures as received is within 10% of the quantity on the manifest. The receiving facility may in such instances sign the manifest and certify to the quantities shown on the manifest, and this manifest does not require a correction. However, a correction may be advisable to ensure greater accuracy and precision with respect to manifest data reporting. The e-Manifest system is being developed to place a greater emphasis on accuracy in reporting quantities shipped and received, and as e-Manifest integrates in the future with the RCRA biennial report, data corrections may be necessary if the accuracy of manifest data is to be assured.

5. If a generator initiates its shipment under a manifest and relies on the receiving facility to determine whether the waste is hazardous on receipt does the receiving facility need to submit the manifest to the e-Manifest system if it determines the waste shipment is not a federal or a state-regulated hazardous waste?

Yes. At the point of generation, the generator completed a manifest for the off-site shipment, because based on the generator’s process knowledge, the waste could likely be a hazardous waste. Although the waste is being shipped to a facility that will test the material and determine conclusively whether the material is a hazardous waste under federal or state law, the test result will not be available in time to affect the generator’s determination at the point of generation. In such cases, it is necessary to manage the material as a regulated hazardous waste and ship it off-site accordingly with a manifest. The manifest was thus required for this shipment, based on the generator’s process knowledge at the point of generation. The fact that the receiving facility could test the materials and determine at receipt that the material was not in fact regulated does not retroactively cancel the manifest or alter the fact that it was required when shipped off-site by the generator. Since any manifest that is required for off-site transportation under federal or state law must be submitted to the e-Manifest system by the receiving facility, the facility cannot decline to submit it to the system because of information it acquired post-receipt.

6. How does e-Manifest integrate with Discrepancy Reports?

Beginning December 1, 2025, receiving facilities must submit all Discrepancy Reports through the e-Manifest system. States can access manifest-related reports directly through the e-Manifest system.

7. If a facility returns rejected wastes or a regulated container residue to the entity named as the generator on the original manifest, but the generator named on the original manifest is in fact a treatment, storage, or disposal facility (TSDF), which party is responsible for the payment of the fee for the return manifest?

In the User Fee Rule, EPA provided that in the case of rejected wastes (or residues) that are returned to the generator named on the original manifest, the rejecting facility, and not the generator, is responsible for submitting the return manifest and the payment of the fee for the return shipment manifest. This requirement is determined by the specific manifest transaction at hand -- i.e., in this instance, a rejected waste or residue is being sent by the original TSDF back to the generator client named on the original manifest. The fact that this particular generator happens to be a TSDF and thus could be registered in the system already for user fee purposes is not relevant for this particular billing question. The rejecting facility is responsible for the submission and payment regardless of the generator’s status as a TSDF.

8. When hazardous waste is rejected, should a new manifest be used for the return shipment?

The hazardous waste rejection regulations for full, immediate rejections of shipments while the transporter is still on site require generators to sign Item 18c of the manifest. If the shipment is rejected in part or after the transporter has left the receiving facility, it requires a new manifest on which the generator would sign Item 20.

9. When rejected hazardous wastes are returned to generators on a manifest, what management method code should be entered on that manifest?

On a rejected shipment, the generator must complete Item 19 because Item 19 is customarily completed by the receiving facility. The manifest regulations grant generators a 90-day or 180-day accumulation period to make new arrangements with a hauler to transport the waste off-site and arrange an alternate facility to receive the shipment (refer to accumulation time limits and other generator requirements at Hazardous Waste Generator Regulatory Summary). The rejection regulations also provide that generators receiving returned shipments must accumulate the returned waste on-site in accordance with the provisions of 40 CFR section 262.16 (small quantity generators) or 40 CFR section 262.17 (large quantity generators), depending on the amount of hazardous waste on-site in that calendar month. Therefore, generators must enter management method code H141 for storage.

Residue shipments that are returned to a generator also require a management method code, specifically, H141 for storage, in Item 19.

Manifest Preparation, Brokers

1. Can a transporter, broker, or receiving facility sign manifests ‘on behalf of’ the generator?

While any waste handler (or broker) can prepare a manifest "on behalf of" a generator, the authority to sign manifests is more limited. The generator block can be signed by the generator, an agent of the generator (e.g. a contractor operating on-site and performing generator responsibilities), or an offeror. An offeror is a person, typically the representative of the initial transporter, who performs the pre-transportation functions (e.g., packaging waste in containers, preparing and affixing labels, preparing the manifest) on-site, and has personal knowledge of the facts involved with the preparation of the waste for transportation.

2. How do I register as a broker?

A broker may prepare manifests in e-Manifest for its generator clients. Because a broker may service multiple clients, EPA requires that brokers obtain an EPA ID Number. Once an EPA ID is issued, brokers can draft manifests for their clients. Brokers may not sign manifests in e-Manifest on behalf of generator clients, unless the broker is operating at the generator site and can sign the manifest as an offeror.

Transporters

1. Do transporters need to register individual drivers in order to sign electronically?

No. As of February 10, 2023, EPA allows a Remote Signer, who is a registered user with sufficient permissions in e-Manifest to sign electronic manifests, to execute electronic signatures for contractors and employees of the same transporter who may not be registered or have network access at the time of shipment.

This policy is applicable to generators and designated receiving facilities as well. You can read the Remote Signer policy on RCRA Online (pdf)(376 KB).

2. Can the generator sign a manifest on behalf of a transporter?

No. While a transporter can sign a manifest on behalf of a generator. if the initial transporter is acting as the offeror, there is no similar authority for generators to sign manifests on behalf of transporters.

Federal and State Implementation

1. Is the EPA or the states required to enforce the e-Manifest system?

The e-Manifest system is an extension of the existing manifest system, which involves compliance and enforcement responsibilities for both EPA and the authorized states. There are certain fee-related aspects of the e-Manifest requirements that are exclusively federal responsibilities and that are not authorizable or enforceable by the authorized states.

EPA has developed a separate Q&A that discusses in greater detail the e-Manifest User Fee Rule and its authorization requirements.

2. Can states continue to collect paper manifests after e-Manifest launches?

States may continue to collect generator or transporter copies of paper manifests where the generator signs on paper, including hybrid manifests. However, the receiving facility copies of manifests may only be collected by e-Manifest. States can obtain their receiving facility data from the e-Manifest system.

For electronic manifests, states can obtain any handler copy from the e-Manifest system and states cannot require handlers to supply a paper or other copy of electronic manifests directly to the states.

3. How will use of e-Manifest relate to the Department of Transportation (DOT) hazardous material regulations (HMR) requirement to use a shipping paper?

DOT currently requires that a hard copy shipping paper be placed in the cab of the transport vehicle during transportation. The system allows users to print electronic manifests that satisfy the DOT HMR requirement for a shipping paper.

E-Manifest can be used to satisfy DOT requirements to retain shipping papers since DOT allows companies to retain shipping papers electronically, as long as a hard copy (e.g., printed from the e-Manifest system) is provided to an authorized representative upon request.

Fee Obligations

1. Is there a fee to use the e-Manifest system?

Yes, the e-Manifest Act requires EPA to collect reasonable user fees for system-related costs, including development and maintenance. Receiving facilities pay a per manifest fee that covers the costs of the e-Manifest system.

2. Do I have to pay a fee if I make corrections in e-Manifest?

No. There is no fee associated with data corrections which may be submitted any time after an original manifest has been submitted to e-Manifest.

3. Who pays the manifest user fees when a shipment is rejected by the designated facility? What about partial rejections?

If the entire shipment is rejected to an alternate facility on the original manifest, the alternate facility is responsible for submitting the manifest to the e-Manifest system and paying the fee.

If a waste is partially rejected by the original facility, the original facility is responsible for submitting the original manifest to the system and paying the related fee. The re-shipment of the rejected portion of wastes to another receiving facility requires a second manifest, and the receiving facility designated on the second manifest (to receive the rejected wastes) is responsible for submitting this second manifest to the system and paying its associated fee.

If the entire shipment is rejected, the manifest regulations allow these wastes to be returned to the generator under the original manifest. In that case, the rejecting facility is responsible for submitting to e-Manifest the copy of the return manifest signed by the generator, which current manifest regulations require the generator to send back to the rejecting facility within 30 days. When submitting this return copy to the system, the rejecting facility must also pay the processing fee for the return manifest.

For partial rejections returned to the generator, the receiving facility of the original manifest is responsible for submitting the signed copy showing its waste receipts to e-Manifest and paying this manifest’s processing fee. Since the return of the rejected portion of the waste shipment requires a second manifest to be completed by the rejecting facility to track the return shipment back to the generator, this facility is also responsible for submitting the return manifest copy (signed by the generator) to e-Manifest and paying the fee for the processing of the return shipment manifest. So, a partial rejection by a receiving facility that also involves a return shipment to the original generator can cause the rejecting facility to be responsible for two distinct manifest submissions and their related processing fees:

The submission of the original manifest showing waste receipts by the receiving facility.
The submission of the copy of the return shipment manifest signed by the original generator.

4. If the system is not available through no fault of the user, and a shipment’s tracking must be completed with a paper manifest, will I be charged the paper submission fee or the electronic manifest fee?

The e-Manifest regulations provide that in certain instances where the system goes down, such that the system is unavailable to complete the tracking of a shipment that was initiated with an electronic manifest, a paper “replacement manifest” must be used to complete the shipment’s tracking. Temporary system outages should not affect paper manifest submissions since the receiver can often defer uploading the data files or image files until the system has been restored.

For extended system outages that are not scheduled and necessitate the use of a paper replacement manifest, EPA will invoice these shipments based on their submission to the system as paper manifests. EPA is obliged by law to recover its full costs for operating e-Manifest, so the Agency must generally charge the paper processing fee for paper manifests.

Receiving facilities may dispute invoices they believe are unfair or improper (e.g., a system outage of unusual length) through the invoice dispute process. EPA may adjust fee invoices to address such circumstances where good cause is shown.

To initiate this invoice dispute process, please email [email protected].

Record Retention and Distribution

1. How long does EPA’s e-Manifest system keep manifest data?

EPA intends for the e-Manifest system to keep manifest data indefinitely until a formal records schedule can be established. EPA expects to consult with the e-Manifest System Advisory Board and obtain the Advisory Board’s advice regarding record retention protocols.

2. If I upload a paper manifest to EPA, what is considered the “legal” record of shipment? Do I need to retain my paper copy?

For electronic manifests, all manifest record retention and inspection requirements are satisfied electronically by users being able to access their copies of record through their accounts in e-Manifest.

For paper manifests, the manifest retention and distribution requirements of e-Manifest are more focused. The e-Manifest system collects and distributes only the final signed copy from the receiving facility. LQGs and SQGs must retain, on site, the initial paper copy bearing the generator/offeror signature and the signature of the initial transporter until they can obtain their final copies from their registered accounts with e-Manifest. Unlike, LQGs and SQGs, transporters are not required to register with e-Manifest unless they must submit manifest data corrections to the system. Therefore, unregistered transporters should retain any paper copies they obtain in executing waste shipments that involve paper manifests, as these paper copies will be viewed as their legal copies of record.

Note that transporters and other waste handlers that have e-Manifest accounts but choose to use paper manifests may rely on the scanned image submitted by the receiving facility. This image replaces the paper copy that previously would have been mailed to the generator by the receiving facility and suffices as the copy of record.¹ Note that this does not apply to hybrid manifests. Generators who use the hybrid manifest option – and keep a hand signed paper copy as their initial generator copy – cannot replace their initial paper copy with the final signed by the receiving facility since it is not an image that displays the hand signatures of all the waste handlers.

¹ EPA determined in 1996 that scanned images that bear the handwritten signatures of waste handlers are legally sufficient for record retention and inspection purposes, if the record retention systems used to produce, store, and retrieve these records are secure and provide reliable access. The e-Manifest system is designed to meet and exceed these requirements.

3. How does the Third e-Manifest Final rule affect the manifest form and continuation sheet?

The July 2024 e-Manifest Third Final Rule requires that waste handlers who are required to use the RCRA manifest under federal or state law must use the new 4-copy manifest (EPA Form 8700-22) and continuation sheet (EPA Form 8700-22A) beginning on the effective date of the final rule, January 22, 2025. Among other things, the new 4-copy manifest forms present accurate information regarding the submission of the hazardous waste exporter and receiving facility copy to the e-Manifest system.

The International Shipment Field has also been moved from the manifest (EPA form 8700-22) (Item 16 of the 5-copy manifest form) to the continuation sheet (EPA form 8700-22A) (new Item 33). The International Shipment Field has also been expanded by designating space within the field (new Item 33b) for exporters and importers to record the consent numbers that correspond to the hazardous waste streams recorded in Item 9 of the manifest. The International Shipment Field also designates space for an exporter to record its EPA ID number, if that EPA ID number is not recorded in Item 1 of the manifest. In addition, the manifest form, continuation sheet, and the instructions on the reverse side of the respective copies have been revised to inform hazardous waste exporters that they must submit the top copies (Page 1) of the manifest and continuation sheet to EPA either as paper or electronic manifests and will be required to pay an associated fee for each manifest submission.

Lastly, the 4-copy form removes Page 3 (“Designated Facility Copy”) from the manifest because this copy is no longer needed since a completed, top paper copy of the manifest is uploaded to the e-Manifest system and can be retained by the receiving facility through the e-Manifest system.

4. Can I use old manifest forms after the final rule’s January 22, 2025, effective date?

For domestic shipments (before December 1, 2025):

EPA will accept Page 1 copies of the obsolete 5-copy manifest (EPA Form 8700-22) and continuation sheet (EPA Form 8700-22A) for domestic shipments after January 22, 2025, until December 1, 2025. However, we strongly recommend that users transition to the 4-copy manifest as quickly as possible.

For export and import shipments (before December 1, 2025):

EPA will not accept Page 1 copies of the obsolete 5-copy continuation sheet for hazardous waste export and import shipments after January 22, 2025, unless the international shipment was initiated by an exporter or importer prior to that date. As explained above, in order to comply with the new regulations effective January 22, 2025, exporters and importers must record the consent numbers for their wastes in the new International Shipment Field of the continuation sheet and if necessary, the exporter must enter its EPA ID number in this field as well. Therefore, exporters and importers must use the new 4-copy continuation sheet starting on January 22, 2025.

If a user wishes to continue to use the obsolete 5-copy manifest (EPA Form 8700-22), they should undertake measures to minimize confusion. For example, one approach (although not a requirement) could include crossing out the Item 16 (the International Shipment Field) of the 5-copy manifest. Facilities should train their manifest personnel to inspect manifests carefully to ensure they are routed properly and that export and import shipments waste handlers are using the new 4-copy continuation sheet during the time any of the obsolete manifest form remains in use.

Although users may continue to use the 5-copy manifest form after January 22, 2025, approved printers must make available to users a printed 4-copy continuation sheet that indicates that hazardous waste exporters and importers must complete the International Shipment Field (Item 33) of the new manifest.

No later than December 1, 2025:

In any case, all waste handlers (e.g., hazardous waste generators, transporters, hazardous waste permitted treatment, and receiving facilities) must fully transition to the new 4-copy manifest forms no later than December 1, 2025. After this date, EPA will not accept the 5-copy obsolete form.

5. If I am an exporter, and I need a copy of the paper form to send to the foreign consignee facility, how do I do this if the manifest forms do not provide extra copies for this purpose?

When using the manifest, an exporter should simply make photocopies of the top copies (Page 1) of the manifest form and continuation sheet and send the photocopies to the foreign consignee. This is the standard manifest procedure when there are insufficient copies in the form set to supply all handlers or interested parties with a copy of the manifest.

Note the manifest and continuation sheet have been revised to align the forms with the final rule changes in the Third e-Manifest Final Rule to capture export manifests in the EPA e-Manifest system and to better track hazardous waste export and import shipments using the manifest forms. These changes include removing the International Shipments field (Item 16) from the manifest form, and re-designating it on the continuation sheet and adding new fields for consent numbers and the exporter’s EPA Identification (ID) Number to the International Shipments field. Therefore, both the manifest and continuation sheet must now be used to track hazardous waste export and import shipments.

6. For paper manifests, is the data file or the scanned image the legal copy of record?

The data file, scanned image, and any post-receipt corrections submitted through the e-Manifest corrections process all comprise the e-Manifest copy of record, and all components are relevant for state and federal enforcement purposes.

EPA has received questions regarding the language in paragraph (3) in the definition of “user of the electronic manifest” at 40 CFR section 260.10. EPA is clarifying that the above language refers to the actual physical paper copies mailed to EPA’s paper processing center (PPC); these physical paper copies were not official copies of record and were recycled once the PPC completed processing the manifest in e-Manifest (note that EPA no longer receives mailed paper manifests as of June 30, 2021).

Data Policy and Data Correction

1. How do I submit manifest corrections? Who can correct a manifest?

The data corrections process is conducted electronically among the waste handlers listed on a manifest and state regulators after the receiving facility copy and data have been entered in the system. It is available to e-Manifest registered users who have the e-Manifest Certifier or Site Manager role for their site in RCRAInfo.

After the receiving facility submits its signed copy of a manifest (whether paper or electronic) to e-Manifest, all waste handlers listed on the manifest as well as state regulators performing Q/A activities from the generation or destination states, may submit data corrections to the system. Waste handlers must certify that the corrected data are accurate and complete, and the submission of a correction generates an automatic notice to the other handlers associated with the manifest. These other interested persons may then respond to a correction notice with their own data corrections. The system retains an auditable record of all such correction submissions, and the latest correction made with respect to a manifest is regarded as the final and correct representation of the data.

2. When does e-Manifest data become available to the public?

The public generally has access to manifest data 90 days after the date of receipt at the receiving facility. EPA believes that 90 days is a generally sufficient time for the waste handlers involved with manifests to sort out discrepancies, correct data, and address other issues connected with a manifest, although there is no fixed time limit on data corrections.

In addition, certain data from manifests that may involve the shipment of Chemicals of Interest (COI) under chemical security rules issued by the Department of Homeland Security (DHS) are redacted from manifests before they are made available to the general public.

3. Does EPA disclose Chemicals of Interest (COI) as part of a Freedom of Information Act (FOIA) request?

EPA will not publicly disclose through the e-Manifest system certain information from manifests involving P-List and U-List RCRA wastes if they are included on the Department of Homeland Security (DHS)’s Chemicals of Interest list found at the appendix to 6 CFR part 27. These data would not be available for disclosure to the public under a FOIA request.

4. How are discrepancy reports handled in e-Manifest?

Starting December 1, 2025, If receiving facilities cannot reconcile discrepancies with the waste generator or transporter within 20 days after receiving the waste, the receiving facility must submit a discrepancy report through the e-Manifest system, which were previously mailed to the state or EPA regional administrator.

EPA expects use of the data corrections process to result in fewer discrepancy reports needed since waste handlers have the opportunity to participate in an open corrections process after the manifest is submitted. Waste handlers are expected to reconcile data errors, including discrepancies, as part of the corrections process.

However, there is still a role for the discrepancy reports to address significant discrepancies in quantity and type that are not resolved by the corrections process. If the generator and the receiving facility do not agree to a facility’s correction, then the facility should submit the discrepancy report when there is an unresolved discrepancy in piece count, or difference that is greater than 10% with respect to a received bulk shipment. This has the effect of elevating unresolved discrepancies to the attention of regulators and remains necessary in those cases where corrections are not able to provide a satisfactory resolution to a shipment discrepancy.

5. After I make corrections, what version of the manifest will be used in an enforcement case?

Both the final copy of the manifest signed by the receiving facility (including the image and data files) and corrections introduced later by the corrections process may have relevance. The original manifest document is a shipping paper, and the copy of the manifest signed by the TSDF at receipt represents the facility’s certification of receipt. The data corrections process is intended to provide an orderly process for correcting data records in the system, and all corrections certified and entered will be retained and audited by the system, with the original records including any uploaded images of the paper manifests.

6. How should discrepancy, exception, and unmanifested waste reports be submitted?

Beginning December 1, 2025, these three reports are submitted through the e-Manifest system. Users are required to be registered and have at least the Certifier role in the e-Manifest module for their site.

There are no fees associated with submitting these manifest-related reports.

7. When do Exception and Discrepancy Reports need to be submitted?

Beginning January 22, 2025, generators must submit an Exception Report 60 days after the initial transporter has taken custody of the waste shipment. If the generator is an LQG, the generator must also initiate a search and document their efforts to locate the manifest, 45 days after the manifest was signed for offsite shipment. Discrepancy reports must be submitted by the designated receiving facility 20 days after receipt of a manifest that contains a significant discrepancy.

Beginning December 1, 2025, Exception and Discrepancy Reports need to be submitted through the e-Manifest system.

8. What are the responsibilities of the EPA Regions and authorized states for handling discrepancy reports that are filed by the receiving facilities?

Discrepancy reports are required from a receiving facility under 40 CFR section 264.72 (and equivalent authorized state regulation) when the facility discovers there is a “significant discrepancy” in the quantity or type of waste received that cannot be reconciled with either the generator or transporter within the period allowed by the regulations (which, beginning January 2025, is 20 days). Prior to December 1, 2025, a discrepancy report, consisting of

A letter describing the discrepancy and reconciliation attempts.
A copy of the manifest at issue, must be mailed to the Regional Administrator, or State Director (if the state is authorized to implement the RCRA program).

Beginning December 1, 2025, all Discrepancy Reports must be submitted electronically to the EPA e-Manifest system. At that time, Discrepancy Report submissions will no longer be accepted via postal mail. The electronic Discrepancy Reports must describe the discrepancy and attempts to reconcile the it, and a copy of the manifest at issue.

The Discrepancy Report is intended to bring to the attention of the regulator that there was a shipment that presented a significant discrepancy which could not be resolved through the efforts of the affected waste handlers. The agency officials receiving the Discrepancy Report may choose to engage in follow-up with the waste handlers to determine the reasons for the discrepancy and its consequences.

Similar considerations apply to Exception Reports and Unmanifested Waste Reports, which like the Discrepancy Report, are intended to alert the EPA Region or state that an irregular event in the manifest process occurred, and that this event may merit some follow-up action at the regulator’s discretion.

9. For state-only hazardous wastes transported out of the generator state, can an interim facility, listed as the designated facility on the generator’s manifest, close out that manifest and re-ship the waste to another designated facility on a bill of lading?

For purposes of this question, EPA intends for the term “interim facility” to mean any facility that receives waste prior to the shipment of waste to an ultimate management facility. If the interim facility is permitted, licensed, registered, or otherwise authorized by a state to manage non-hazardous waste, then the interim facility may close out the manifest. To properly close out the manifest, the interim facility must take the following actions:

The interim facility must receive prior approval from the generator to be named as the designated facility on the manifest.
The manifest must list the interim facility—rather than the originally named receiving facility -- as the designated facility.

After the interim facility takes these actions, then it can close out the manifest, and the wastes can be subsequently re-shipped to an ultimate management facility (also located in a state in which the waste is non-hazardous) on a bill of lading. The interim facility must sign and date the manifest and submit it to EPA for data processing. The interim facility must register in e-Manifest to submit the manifest and pay the associated fee for the manifest submission.

10. How is the above answer affected if the interim facility is a transfer facility?

A transfer facility cannot close out the manifest even if the generator designates the transfer facility on the manifest as the receiving facility. EPA defines “transfer facility” to mean: “any transportation-related facility, including loading docks, parking areas, storage areas and other similar areas where shipments of hazardous waste or hazardous secondary materials are held during the normal course of transportation.” Refer to 40 CFR section 260.10. A transfer facility does not meet the definition of a designated facility for purposes of the manifest because it can only store waste shipments temporarily, up to ten days, without a permit during the normal course of transportation to the designated facility. Refer to 40 CFR section 263.12(a). The original manifest remains active during the time that waste is temporarily stored at a transfer facility, so the waste shipment must leave the transfer facility under the same manifest under which it arrived. Thus, a transfer facility cannot be the designated facility on the original manifest, and the manifest cannot be closed out at a 10-day transfer facility. A transporter must transport the waste and the accompanying manifest from the transfer facility to a receiving facility designated on the manifest.

System-Specific Questions

1. Is e-Manifest accessible on mobile devices, like a tablet or smart phone?

Yes, e-Manifest is accessible on mobile devices through your favorite browser on our RCRAInfo webpage.

2. Can you print out a hard copy of an electronic manifest?

Yes. You can print a hard copy of an electronic manifest by selecting the printer icon in the top right corner of the manifest (shown below).

3. Can e-Manifest be used for both hazardous waste and non-hazardous waste shipments on the same truck?

Yes.

4. What is the difference between Quick Sign and CROMERR signatures?

The Quick Sign signature applies to electronic signatures executed on the e-Manifest for initial receipt of shipments by generators, transporters, and receiving facilities. The CROMERR-compliant signature applies to electronic signatures for receiving facilities submitting the final manifest to EPA or any user (e.g., generators, transporters, and receiving facilities) submitting post-receipt corrections. CROMERR-compliant signature method requires a higher level of identity proofing.

Quick Sign is available for users with Preparer permission. Quick Signatures can also be completed through system-to-system integration. CROMERR-compliant signature methods require users to have the Certifier or Site Manager role and to complete an Electronic Signature Agreement. Certifiers and Site Managers can also Quick Sign.

5. Can I sign electronic manifests in my company’s system?

Yes. Sites can use their company’s software to initiate the electronic signature process through the RCRAInfo application programming interface (API). Developers and IT personnel can find documentation on using the API in the USEPA/e-Manifest GitHub repository. The Remote Signer Policy (pdf)(376 KB) describes how sites can build their systems to sign electronically through system-to-system communication.

The e-Manifest system also provides a service that returns a hyperlink and allow industry systems to send their users directly to the manifest(s) they need to sign in RCRAInfo. The users will still need to log in to the system, but they will save themselves time by going directly to the manifest(s) they need to sign.

6. Will Quick Sign and CROMERR signatures be shown differently on the printed PDF of the electronic manifest?

No. Quick Sign and CROMERR electronic signatures are identical on the printed manifest.

7. Can I bulk sign manifests?

Yes. Manifests can be bulk Quick Signed through RCRAInfo, or through the API. Manifests can also be bulk CROMERR Signed through RCRAInfo.

8. If there are more than four waste line items, does the system create a continuation sheet?

Yes. The continuation sheet can be printed as well.

9. If drivers do not have network access, how do they sign electronically?

EPA’s Remote Signer Policy (pdf)(376 KB) allows personnel to execute electronic signatures through their employees or contractors who are remotely located from the hazardous waste shipment. If a driver can communicate the necessary information to a Remote Signer, which is a remotely located individual with network access and sufficient permissions in e-Manifest to electronically sign, then the Remote Signer can execute the electronic signature in the e-Manifest system for the driver.

If the driver otherwise has access to a computer or smart phone, they can sign electronically in EPA’s e-Manifest system.

10. Does e-Manifest use EPA's Central Data Exchange (CDX)?

Yes. e-Manifest is part of the RCRAInfo Industry Application which utilizes CDX for its registration. Users with existing CDX accounts are able to access RCRAInfo. It is important to note that CDX uses Login.gov to authenticate users. CDX accounts simply need to login via the RCRAInfo Industry Application to gain access to the application. Unregistered users can create their CDX and Login.gov accounts through the RCRAInfo Industry Application. All users need to request permissions for their specific site(s) once they gain access.

11. Can generators add the management method code at the initiation of the manifest?

The management method code is optional up until the point the manifest is finalized and submitted to EPA. This means a user may enter a management method code on the manifest at any point, but the receiving facility must enter/ensure the code is entered after signing for receipt of the waste and before the manifest is electronically signed and placed on the receiving facility's invoice.

12. Are state hazardous waste codes included in e-Manifest?

Yes. Up-to-date state waste codes are available in the system along with all federal waste codes.

13. Why can I not find my state-issued ID Number in e-Manifest?

If you cannot find your state-issued ID, visit State Contacts and contact the appropriate state person and they will assist. State-issued IDs are not automatically uploaded to RCRAInfo, which is why you are unable to find it when searched.

14. Can I create a manifest template for repeat shipments?

Yes, users can simply use the copy manifest icon on the e-Manifest dashboard.

15. What role does e-Manifest play in supporting emergency response?

A Site Manager or state administrator can choose to grant emergency responders view access to their site or state information, respectively. However, transporters must continue to carry a shipping paper on the transport vehicle for the use of responders, in accordance with current DOT requirements.

16. How does e-Manifest handle multiple waste codes for a single waste line (e.g., lab packs)?

A company may include as many waste codes as they need on each waste line for electronic manifests.

17. Are there “flex fields” for tracking additional information that isn’t required by EPA?

Yes, in the e-Manifest system we refer to this as “reference information” which are optional and available at the individual manifest and waste line level.

18. Does e-Manifest allow use of decimals in the quantity field?

No, the system does not allow for decimals.

19. Will e-Manifest allow for printing of hazardous waste labels?

No.

20. I can’t find my manifest. What is going on?

There may be a couple of things potentially going on:

If you (or your receiving facility) submitted the paper manifest via scanned image upload, it’s possible your manifest has not yet been entered into the e-Manifest system by the EPA Paper Processing Center.
It’s possible that a manifest is not appearing for you if your EPA ID number from the paper manifest was not entered correctly. For example, if the receiving facility mistyped your EPA ID number from the paper manifest or used a generic “VSQG” or “CESQG” rather than entering your EPA ID.

To prevent this type of error, we encourage receiving facilities to use the “Search for Generator” button in e-Manifest. This button will then populate name/addresses/phone/email automatically on the manifest.

If your receiving facility uploaded a data plus image manifest or used an electronic manifest and you still can't find the manifest, please contact your receiving facility to confirm the EPA ID number they entered for you.

If you receive an email from a state agency or EPA asking you to correct manifest data, you are required to make the correction within 30 days.

21. How long do remote signers have to execute an electronic signature?

Remote signers have until the earlier of either (1) 24 hours from the time that their field personnel received the waste from the preceding waste handler (i.e., generator or transporter) or (2) before transferring the waste to another handler (i.e., another transporter or receiving facility), to execute an electronic signature to the hazardous waste manifest.

Example 1. A truck driver contacts their dispatcher that they received waste at 11:00 AM on a Tuesday. The remote signer has until 11:00 AM on Wednesday to execute the electronic signature.

Example 2. A truck driver contacts their dispatcher that they received waste at 11:00 AM on a Tuesday and will drop it with another waste hauler at 5:00 PM that same day. The remote signer has until before the transfer of custody occurs (in this case, 5:00 PM Tuesday) to execute the electronic signature.

User Registration

1. Does each person need to register for e-Manifest? Or can there be one company account shared by multiple users?

While RCRAInfo accounts must be associated with an individual, the Remote Signer Policy (pdf)(376 KB) stipulates that a Remote Signer user with sufficient permissions can execute electronic signatures for manifests where a field personnel with first-hand knowledge of the hazardous waste shipment has authorized them to do so.

2. What is the current user registration process for e-Manifest?

Please refer to our "How to Register for e-Manifest" page for further information.

3. I’m registered on the RCRAInfo test site, Preprod, do I need to re-register in RCRAInfo to participate in e-Manifest?

Yes. Users testing e-Manifest who have registered in RCRAInfo pre-production must also register in the RCRAInfo production. Because these are two separate applications, you must register for each separately.

4. What are the permission levels for e-Manifest?

There are three permission levels in the e-Manifest module: Viewer, Preparer, and Certifier. These permissions are hierarchical so each permission can perform the functionality of the levels before it as well as the specific functionality for that given permission (i.e., a Preparer can do everything that a Viewer can do, and a Certifier can do everything that a Preparer and Viewer can do). Additionally, the RCRAInfo system offers a Site Manager Permission level which applies to all modules in the system, including the e-Manifest module.

Functionality for e-Manifest	Viewer	Preparer	Certifier	Site Manager
View manifests	X	X	X	X
Create manifests, edit Draft manifests, and complete non-CROMERR compliant signatures.	N/A	X	X	X
Complete CROMERR compliant signatures, correct manifest data electronically, and submit manifests.	N/A	N/A	X	X
Approve users and grant permissions (i.e. Viewer, Preparer, Certifier, and Site Manager) to other company contacts at a site. View billing invoices for a site as well as submit payments.	N/A	N/A	N/A	X

5. What is a Viewer?

As a Viewer, you can view manifest images and data for specified sites, but cannot create, edit, or sign manifests.

6. What is a Preparer?

As a Preparer, you can perform the same functionality of a Viewer and also create and edit manifests for sites for which you are assigned this role. Preparers can use the “Quick Sign” feature to complete non-CROMERR compliant signatures.

7. What is a Certifier?

As a Certifier, you can perform the same functionalities of a Viewer and Preparer and can also complete CROMERR compliant electronic signatures and submit manifest information to EPA for sites for which you are assigned this role. As a Certifier, you are required to obtain an Electronic Signature Agreement.

8. What is a Site Manager?

As a Site Manager, you can perform the same functionalities as a Viewer, Preparer, and Certifier for e-Manifest. Unlike the lower permission levels, Site Manager applies to all modules. In other words, a user granted Site Manager permission for a site would automatically have Certifier permissions for all modules. In addition, you can approve and grant permissions to other contacts in your organization to sites for which you have Site Manager permission. As a Site Manager, you are also required to obtain an Electronic Signature Agreement and have the option of managing Electronic Signature Agreements for others in your organization. You may also be responsible for managing your company’s Application Programming Interface ID and key. If a receiving company, you have access to view and pay user fees through EPA’s RCRAInfo system.

9. What is a Remote Signer?

A Remote Signer is a registered RCRAInfo user with sufficient permissions to sign electronic manifests. In order to act as the Remote Signer, the individual would need at least Preparer level permission in the e-Manifest module for the site’s EPA ID they are signing for. Certifier or Site Manager level access would also allow an individual to act as a Remote Signer. (Note that Remote Signer is not a separate permission level.)

A Remote Signer can also be the individual that holds the application programming interface (API) ID and keys that is used by their company’s software to communicate with e-Manifest. Currently, to obtain an EPA ID and key and use the RCRAInfo API, the Remote Signer needs Site Manager level access to the site that will be signing.

10. Who qualifies for a Site Manager?

EPA has not set formal criteria for the Site Manager designation, so organizations have flexibility in their decisions. However, some suggestions for Site Manager include:

At least one Site Manager who is responsible for managing personnel.
At least one Site Manager who is responsible for a company’s information technology systems (e.g., someone who can help manage the company’s Application Programming Interface (API) key and electronic signature agreements).
At least one Site Manager who has the ability to pay invoices on behalf of the company if the site is a TSDF (e.g., someone who can pay user fees).

11. What if EPA receives a request for a lower-level permission and there is no Site Manager assigned/approved yet?

EPA strongly encourages sites to assign a Site Manager and will prioritize Site Manager permissions. In the absence of a Site Manager, EPA will approve user requests for lower permission levels until a Site Manager has been assigned. Following that approval, the Site Manager will then approve users within their organization.

12. Am I required to complete an Electronic Signature Agreement (ESA)

If you register as a Certifier or Site Manager and have not previously completed an electronic signature agreement, you will be required to complete an ESA as part of the registration process. Following Regulator approval of your first site permissions, you will be presented with an electronic signature agreement the first time you log in. At that time, you must complete the ESA. ESAs can be conducted electronically or via a handwritten signature.

13. Does a Site Manager need an ESA for each site?

No. A user only needs to complete an ESA once.

14. I couldn’t successfully complete or get approval for the online ESA, what do I need to do?

If you do not gain approval for your ESA online, you must prepare and submit a paper electronic signature agreement and provide it to your Site Manager. If your site does not have a Site Manager (or you are the initial Site Manager for your site), then you will have to provide the paper ESA to EPA or your state. The address for where to mail your ESA will appear on the bottom of the paper ESA. Log into your RCRAInfo Industry account and navigate to your profile and select the “My e-Signature Agreements” section. There will be an option to re-download the ESA so you can print, sign, and then mail it in or provide it to your Site Manager.

15. I couldn’t find or add my site in RCRAInfo, what do I need to do?

To add a site, you must click the "Select Existing Site" button on the My Sites page to add an existing site location. If the site does not exist in the system, you must click the "Request New Site ID" button to obtain a Site ID using the Site Identification Form (EPA Form 8700-12) and follow the instructions regarding the site addition process.

16. In which states can I electronically request an EPA ID?

You can request an EPA ID in states that have opted into the myRCRAid module, which is the equivalent of filing the Site Notification form (EPA Form 8700-12). You can view up-to-date information on which states have opted into myRCRAid and the other modules in RCRAInfo.

Regulatory users can find this information in their settings under “State Participation”. Industry users can find the same information from the homepage under “Documentation”.

17. How is my company’s information added to e-Manifest?

A site’s information is added to e-Manifest via EPA’s Site Identification form (EPA Form 8700-12). If your site has not yet submitted a Site Identification Form/does not have an EPA ID, you can submit a Site Identification form to obtain an EPA ID and add your site to EPA’s RCRAInfo and e-Manifest systems. Additionally, if a generator does not have an EPA ID, generator information can always be manually added to the manifest (by a transporter or receiving facility, for example) which can then be copied for subsequent manifests.

18. If I create an e-Manifest account, can I share my login credentials?

No, accounts must be unique to individuals.

Invoices/Payments

1. Who should I contact if I have questions about my invoice?

If you have any issues with your invoice, contact [email protected] to reach EPA financial staff that can address your issues. In your email, please provide your name and the facility where you work, the EPA ID number of your facility, your contact information, the invoice date in question, the manifest tracking number(s), and the nature of the invoice issue. EPA staff intend to resolve your concerns within ten business days of receipt.

2. What happens if I pay my invoice late?

You are required to pay your invoice in the calendar month that it was received, or you will begin to accrue late fees. These fees include a monthly handling charge and a penalty on the principal of the bill for each month your bill remains unpaid. If your bill is unpaid 120 days after receiving it, it will be forwarded to the U.S. Treasury Department for collections and further action. Additionally, non-payment of your bill could subject your facility to enforcement action.

3. Who has the ability to view and pay invoices?

Site Managers receive a copy of their invoice electronically on the first day of the month after their manifests were submitted to EPA. This invoice summarizes the manifest activity for the facility in the prior month and also identify all manifests that were sent to EPA.

The electronic payment methods that are accepted in this system include a commercial credit card, a commercial debit card, and Automated Clearinghouse (ACH) debit. Checks or any other forms of payment sent directly to the EPA will not be accepted.

4. Who is responsible for paying an invoice if your company ownership has changed?

If you are a receiving facility whose ownership has changed, but still have an active invoice that needs to be paid, you must work with the new ownership to identify who must pay the invoice. EPA requests that the new ownership identify who must pay this invoice to prevent the accrual of late charges. Regardless of any ownership changes, outstanding manifest invoices must be paid.

If the invoice is to be paid by an active Site Manager registered in e-Manifest, please send an email to [email protected] and indicate which facility is responsible for paying this invoice.

5. How do I dispute a charge on my invoice?

If you believe there is an error with your invoice, you can request a review by EPA financial staff by emailing [email protected]. EPA staff will research your claim and expect to inform you of their decision via email within ten business days of receipt.

If you are unsatisfied with this initial decision, you have ten business days of receiving that decision to appeal. The appeal will go to the Director of EPA’s Office of Resource Conservation and Recovery for a final decision. You can initiate an appeal by contacting [email protected].

EPA will inform you of this appeal decision via email within ten business days of receipt.

6. Do I need to pay if I am disputing an invoice?

While in dispute, you are not required to pay your invoice; however, late fees will continue to accrue.

If EPA staff resolve the dispute in your favor, late charges will be waived. Otherwise, you will be required to pay any applicable late fees. You can avoid late fees by paying the disputed invoice up front; EPA will reimburse the invoice if the dispute is resolved in your favor.

Refunds from invoice adjustments are made via the same method of payment used to pay the invoice. If you have not paid your invoice and are due an adjustment, you will receive an updated invoice.

EPA cannot issue a credit for use on any future invoices.

7. If I work for a federal agency that receives regulated waste accompanied by a required manifest, how do I pay my invoice?

If you work for a federal non-military facility, the Site Managers registered with your facility will receive an invoice in e-Manifest. To make a payment, you can initiate a transfer between agencies, which can be done through the Intra-Governmental Payment and Collection (IPAC) system. To complete the transfer, you will need to obtain the EPA’s Agency Location Code (ALC).

If you work for a federal military facility, you can submit an SF-1034 to your local finance office to make a payment, which will forward to the Defense Finance and Accounting Services (DFAS). Funds will be disbursed to the EPA by DFAS through the IPAC system. To complete this transfer, you will need to obtain the EPA’s Data Universal Numbering System (DUNS) and the Commercial and Governmental Entity (CAGE) number. as well as the ALC.

To obtain these specific codes, please contact [email protected].

8. Do I need a W-9 form to make a payment?

A W-9 form is a tax form developed by the IRS that allows users to certify they are making payments to authorized companies/organizations. Although the EPA does not require a W-9 form to make a payment, some companies require this tax ID number in order to authorize payments to the EPA. Your accounting staff should be able to determine if you need this information.

To request a completed W-9 form, please contact [email protected].

PCBs

1. Do record retention policies differ for RCRA and PCB wastes tracked with the RCRA manifest?

No. Record requirements for both RCRA hazardous waste and Regulated PCB waste manifests are the same; both must be kept for three years under EPA’s federal regulations.

2. Does waste containing Toxic Substances Control Act (TSCA)-regulated Polychlorinated Biphenyls (PCBs) need to be manifested for disposal?

Yes. Unless specifically exempted from the requirements in 40 CFR part 761 subpart K. The PCB regulations require generators to prepare a manifest on EPA Form 8700-22, and, if necessary, a continuation sheet prior to transporting regulated PCB waste. Regulated PCB waste(s) means those PCBs and PCB Items that are subject to the disposal requirements of 40 CFR part 761 subpart D. Refer to 40 CFR section 761.207 for more information.

3. Is a manifest necessary for PCB waste that is not regulated under federal TSCA regulations, but which is regulated by the state?

Yes. Waste containing PCBs that is not regulated for disposal under TSCA federal regulation (e.g., transformers containing < 50 ppm PCBs) may still be regulated by state waste programs. If the PCB-containing waste is regulated by the state where the waste is generated or the state where the waste is received, use EPA Form 8700-22. For convenience, refer to the table below for state-specific waste codes pertaining to PCBs, which are also available in the e-Manifest system. This list may not be complete; contact the state regulator for more information.

Waste Code	Description
California
261	PCB and other material containing PCBs
Illinois
IL04	PCB1 Solids (Capacitors, Transformer Carcasses)
IL05	PCB2 Liquids (Transformer and Capacitor Oils, etc.)
Maine
M002	PCB Content of 50 ppm of higher
MRM002	Universal Waste PCB
Maryland
M001	Polychlorinated biphenyls (greater than 500 ppm)
MT01	Polychlorinated biphenyls (50 to 500 ppm)
MX01	Mixtures of soil, water, or debris containing PCBs with concentrations greater than 50 ppm or any residue resulting from the cleanup of a spill of any commercial chemical product or manufacturing product having the generic name listed in COMAR 26.13.02.19E and G
Massachusetts
MA02	PCB Wastes
Michigan
<026L	PCB Waste
Minnesota
MN03	PCB Waste
Nevada
PCBX	Generic PCB Waste
New York
B001	PCB Oil (concentrated) from transformers, capacitors, etc.
B002	Petroleum oil or other liquid containing 50 ppm or greater of PCBs, but less than 500 ppm PCBs. This includes oil from other electrical equipment whose PCB concentration is unknown, except for circuit breakers, reclosers and cable.
B003	Petroleum oil or other liquid containing 500 ppm or greater of PCBs.
B004	PCB articles containing 50 ppm or greater of PCBs, but less than 500 ppm PCBs, excluding small capacitors. This includes oil-filled electrical equipment whose PCB concentration is unknown, except for circuit breakers, reclosers and cable.
B005	PCB articles, other than transformers, that contain 500 ppm or greater of PCBs, excluding small capacitors.
B006	PCB transformers. "PCB transformers" means any transformer that contains 500 ppm PCB or greater.
B007	Other PCB wastes including contaminated soil, solids, sludges, clothing, rags and dredge material.
Oregon
ORX002	Polychlorinated biphenyls (PCBs)
Pennsylvania
502	PCB containing waste
Rhode Island
R007	PCB Waste
Vermont
VT01	Waste containing PCBs in concentrations equal or greater than 20 parts per million
Washington
WPCB	Washington State Dangerous PCB Waste containing polychlorinated biphenyls at concentrations of 2 parts per million or greater from specific sources: discarded transformers, capacitors or bushings containing PCBs (except when drained of all free flowing liquid) and the following wastes generated from salvaging, rebuilding, or discarding of transformers, capacitors or bushings containing PCBs at concentrations of 2 parts per million or greater: cooling and insulating fluids and cores, including core papers.

4. If a waste contains non-TSCA regulated PCBs, does this need to be stated on the manifest?

Yes. If the waste contains PCBs but is not TSCA-regulated waste, it needs to be clearly stated on the manifest, e.g. “Non-TSCA PCB waste.” Using the phrase “Non-DOT Regulated Polychlorinated Biphenyls” is not sufficient to communicate that a waste is not TSCA-regulated. Also refer to FAQ #16 under Receiving Facilities.

5. What information about PCB waste is required to be included on the manifest?

Generators who transport or offer for transport TSCA-regulated PCB waste must include all of the required information on either the manifest (Form 8700-22) or the manifest continuation sheet (Form 8700-22A or other PCB manifest continuation sheet).

The following information is required under 40 CFR section 761.207(a) for each PCB waste category at the specified frequency.

	Required Frequency	Identity/type of PCB waste	Date of removal from service	Weight in kilograms	Unique identifying number
Bulk PCB waste	Per load	X	X	X
PCB Article Container	Per container	X	X	X	X
PCB Container	Per container	X	X	X	X
PCB Article not in a PCB Container or PCB Article Container	Per article		X	X	X

6. Is a Unique Identifier required for every container listed on the manifest?

Yes. A unique identifier is required for each PCB container shipped on a manifest. Refer to the table above for the required frequency and information for each waste type. These requirements can be found at 40 CFR section 761.207(a):

“…The generator shall specify: …For each PCB Article Container or PCB Container, the unique identifying number, type of PCB waste (e.g., soil, debris, small capacitors), earliest date of removal from service for disposal and weight in kilograms of the PCB waste contained. (Item 14—Special Handling Instructions box)”

The generator can choose to assign the manifest tracking number as the unique identifier for a single PCB article or container. For manifests shipping multiple PCB articles and/or containers, the generator can choose to assign Unique Identifiers that include the manifest tracking number, if each item has a unique identifier (e.g., 1234567MTN-01, 1234567MTN-02, 1234567MTN-03).

7. What PCB manifest information is required to be submitted to EPA’s e-Manifest system? If a continuation sheet is used, must it be submitted to EPA’s e-Manifest system?

Facilities receiving PCB waste that is required under either federal or state law to be shipped on a manifest must submit the manifest Form 8700-22, and all required manifest information to EPA’s e-Manifest system. If a continuation sheet is used with the manifest, it must be submitted to EPA’s e-Manifest system. Generators may use Form 8700-22A or other PCB manifest continuation sheet in accordance with Note 1 to 40 CFR section 761.207(a):

“EPA Form 8700– 22A is not required as the PCB manifest continuation sheet. In practice, form 8700–22A does not have adequate space to list required PCB-specific information for several PCB articles. However, if form 8700–22A fits the needs of the user community, the form is permissible.”

8. If a manifest lists waste containing “< 50 ppm PCBs” or “trace PCBs,” is it considered a TSCA-regulated PCB waste that requires submittal of all of the supporting information?

Yes. EPA considers all wastes described as containing PCBs on a manifest to be TSCA-regulated PCB waste and will therefore need the required supporting information. EPA must make this assumption as waste containing < 50 ppm PCBs is often TSCA-regulated, for example, if it is < 50 ppm as a result of dilution. Refer to 40 CFR section 761.60(g) for an example.

If the PCB-containing waste is not required to be manifested under either federal or state law (and thus use of the manifest is voluntary), receiving facilities do not need to submit the manifest to EPA. (Note that any manifest submitted to the EPA, voluntary or otherwise, will incur a user fee.)

In the event that a manifest is not required by the PCB regulations but must be submitted to EPA to fulfill other state or federal regulatory requirements (because, for example, it also includes hazardous waste that must be manifested), the manifest should explicitly say, with respect to the PCB-containing waste, “Non-TSCA PCBs.” This clarification will avoid the receiving facility having to submit any other information about the PCB waste, such as information required under 40 CFR section 761.207.

9. Is it necessary to manifest waste that may or may not be TSCA regulated? I am sending it to the TSDF where they will determine the concentration and regulatory status for me.

Yes. If the regulatory status of the waste has not been determined, you must comply with all of the requirements in 40 CFR part 761 subpart D, including use of a hazardous waste manifest, until such time as the regulatory status is determined. For example, an untested transformer that is shipped as waste without a manifest would be a violation of 40 CFR part 761 subpart K if that transformer was found to contain > 50 ppm PCBs. Since the manifest is required at the time the waste was shipped off-site, the receiving facility is required to submit the manifest to e-Manifest.

Post-delivery, if the waste is determined to be non-TSCA regulated, the receiving facility should follow the necessary steps to resolve the discrepancy, as required by 40 CFR section 761.215. The receiving facility should include the relevant information and a comment in Item 18 of the paper manifest prior to entering the data into the e-Manifest system or correct the relevant waste line information through the e-Manifest corrections process after submitting.

10. Do I need to apply for a RCRA-issued EPA ID or a TSCA-issued EPA ID?

Apply for a RCRA-issued EPA ID if:

Your PCB handler facility also manages RCRA hazardous waste.
Your PCB handler facility does not handle RCRA hazardous waste, but you want to register and use the e-Manifest system to track your PCB manifests.

(Refer to FAQ# 11 below for how to apply for a RCRA-issued EPA ID.)

Apply for a TSCA-issued EPA ID if:

You’re a PCB handler that does not handle RCRA hazardous waste, and you have no intentions to use the e-Manifest system to track your PCB manifests. You can apply for a TSCA-issued EPA ID by submitting a Notification of PCB Activity Form. (Note that TSCA-issued EPA IDs cannot be used to create, track, or modify manifests in the e-Manifest system.)

Note: If you are unsure which EPA ID your facility has, reach out to EPA via email to [email protected].

11. How do I register for the e-Manifest system if I don’t have a RCRA-issued EPA ID?

You need a RCRA-issued EPA ID to register and use e-Manifest. For special instructions on how to apply for a RCRA-issued EPA ID please contact the ORCR PCB team at [email protected].

12. If I have both a TSCA-issued and a RCRA-issued EPA ID, can I use my RCRA-issued EPA ID for non-manifesting PCB purposes?

No. Your RCRA-issued EPA ID will not be the same as your TSCA-issued EPA ID; you should continue to use the TSCA-issued ID for all PCB correspondence (e.g., submission of Form 7710-53, PCB Annual Reports), and only use the RCRA-issued ID for manifest purposes.

Note: This scenario is specific only for non-RCRA regulated facilities that requested a RCRA-issued ID for PCB manifesting purposes.

13. Why should I register for e-Manifest and what are the benefits of having a RCRA-issued EPA ID vs a TSCA-issued EPA ID?

Registering in the e-Manifest system allows users for more flexibility in using the electronic system instead of submitting paper manifests.

EPA ID issuance type	Use paper manifests	Use e-Manifest to store and correct all manifests (paper included)	Use electronic manifests
RCRA	X	X	X
TSCA	X

If a facility does not handle RCRA waste in addition to TSCA waste and is interested in using the e-Manifest system, then facilities shall obtain a RCRA-issued EPA ID by following FAQ #11, and then register to the e-Manifest system to be able to access electronic manifests.
If a facility does not handle RCRA waste in addition to TSCA waste and is not interested in using the e-Manifest system, facilities can continue to use their TSCA-issued EPA ID number or the generic identification number “40 CFR PART 761” on hybrid or paper manifests to meet manifesting requirements at 40 CFR section 761.205(c)(1). However, these generators will not be able to access and retrieve these manifests in e-Manifest and thus cannot use the system for recordkeeping or post-receipt correction purposes.