EPA Proposed Rule

Paper Manifest Sunset

On March 3, 2026, the U.S. Environmental Protection Agency (EPA) published a proposed rule seeking to amend the hazardous waste manifest regulations to establish a sunset date for use of paper manifests. The EPA believes switching from paper manifests to electronic manifest could save an estimated 28.5 million dollars annually while also providing better tracking and transparency for regulators and the public. While the EPA’s main goal with its proposed rule seeks to decrease the burden of manifest users, it also seeks to:

• Add new registration requirements with the EPA’s e-Manifest system for RCRA hazardous waste transporters, certain PCB waste generators, and PCB waste transporters.
• Update exception reporting requirements for certain very small quantity generators (VSQGs).
• Update exception reporting requirements for very small quantity generators (VSQGs) managing hazardous waste from episodic events, as well as for healthcare facilities and reverse distributors handling hazardous waste pharmaceuticals.
• Add four technical corrections to the import and export requirements

To view this proposed rule in its entirety you can click HERE!

If you would like to make a comment on this new proposed rule, all comments must be received on or before May 4, 2026. For those seeking comment on the information collection provisions, it is best to have those comments submitted on or before April 6, 2026, to best ensure consideration by the Office of Management and Budget (OMB).

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