EPA Goes Digital: Bye-Bye Paper Waste Manifests
Published Date: 3/5/2026
Proposed Rule
Summary
The EPA wants to stop using paper forms for tracking hazardous waste and switch to electronic ones, saving about $28.5 million a year and making waste tracking safer and clearer. This change affects waste transporters, certain waste generators, and facilities handling hazardous waste pharmaceuticals. Comments on the plan are open until May 4, 2026, so now’s the time to weigh in!
Analyzed Economic Effects
6 provisions identified: 4 benefits, 2 costs, 0 mixed.
Paper Manifests End in 24 Months
EPA proposes to stop accepting paper hazardous waste manifests for shipments started on or after the paper manifest sunset date, which would be 24 months after the publication of the Agency's final rule. After that date, only fully electronic or hybrid electronic manifests will be valid and EPA will no longer accept paper, image-only, or data-plus-image submissions for shipments initiated on or after the sunset.
Estimated $26.4–$28.5M Annual Savings
EPA estimates phasing out paper manifests would unlock about $26.4 million to $28.5 million in annual savings across all entities that use manifests, using discount rates of 7% and 3%. The savings come from reduced printing, recordkeeping, and reporting burdens and are presented as annual figures in the economic analysis.
Mandatory e-Manifest Registration Required
The proposal would require specified waste handlers to register with EPA's e-Manifest system so they can use electronic manifests and perform related tasks. Affected groups called out include hazardous waste transporters, certain VSQGs managing episodic events, healthcare facilities and reverse distributors handling hazardous waste pharmaceuticals, and PCB waste handlers.
Electronic Reporting, Data Correction, Record Retention
The proposal extends electronic submission requirements and mandatory manifest data corrections and e-Manifest record retention to additional groups, including VSQGs managing episodic events, healthcare facilities and reverse distributors handling hazardous waste pharmaceuticals, and PCB waste generators and transporters. These changes would align exception, discrepancy, and unmanifested waste reporting with the e-Manifest system.
Some PCB Generators Must Get TSCA EPA IDs
Under the proposal, PCB waste generators that are currently exempt from TSCA notification would be required to notify EPA using EPA Form 7710-53 and obtain a TSCA-issued EPA ID so they can register with e-Manifest. EPA estimates numbers of PCB generators without either RCRA or TSCA IDs in the docket discussion.
Hybrid Manifests & New Signature Options
EPA's proposal preserves hybrid manifests (printed, signed hard-copy starting from an electronic form) and notes existing Remote Signer flexibility; EPA is also considering an alternative electronic signature method (including signing via SMS) to allow transporters to sign without a registered account. These options are intended to reduce barriers to electronic manifest adoption for field personnel.
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Key Dates
Department and Agencies
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