Sunsetting Paper Manifests – Is It Finally Happening?

The Hazardous Waste Electronic Manifest Establishment Act (e-Manifest Act) was signed into law over 13 years ago in October 2012.  However, the United States Environmental Protection Agency (U.S. EPA) reports that over 99.5% of the over two million manifests received annually do not fully utilize the electronic manifest system. The Hazardous Waste e-Manifest System Advisory Board met in September 2025 with the goal of laying a path towards the complete sunsetting of paper manifests. A white paper detailing the plan, background, and obstacles can be found here.

December 2025 Requirements

Beginning on December 1, 2025, all generators (except for Very Small Quantity Generators (VSQGs) or PCB generators) must submit all Exception Reports through e-Manifest. Similarly, all receiving facilities must submit all Discrepancy Reports through e-Manifest; paper copies can no longer be mailed to the U.S. EPA Regional Administrator after December 1, 2025. Users completing these reports must be registered and have at least the Certifier role within e-Manifest for their site. Export manifests must be submitted by domestic exporters via e-Manifest beginning on December 1, 2025, as well.

Barriers to e-Manifest

U.S. EPA recognizes that there are a range of barriers that still exist and will need to be addressed before paper manifests are fully phased out. These include:

• Legacy Workflows
• S. DOT Shipping Paper
• Access to Manifest Tracking Numbers
• Variability of Pickup Volumes
• Office and Field Hours
• Legacy Industry Systems
• Cell Service and Internet Access

U.S. EPA is proposing system updates that will address access to manifest tracking numbers, variability of pickup volumes, office and field hours, and internet service access. These changes are intended to further address the legacy workflow of manifest preparation and signatures to ease the burden on generators, transporters, and receiving facilities. They are also engaging the U.S. DOT to ensure the transition from paper manifests still maintains allowances to meet U.S. DOT’s requirements.

System Updates

One of the most challenging barriers to the current e-Manifest system is the signatures required to transfer custody of waste between the generator and transporter. To address this, U.S. EPA is proposing a signature method that will allow for short message system (SMS) signatures. In short, a user would be able to text a manifest tracking number to e-Manifest to begin a message exchange that will end with the user texting their full name as a signature. This would make access more convenient and not as dependent on internet access.

Another barrier is the current process to update shipment details which requires the updates be made by a registered user in the RCRAInfo Industry Application and be associated with the site. U.S. EPA is proposing to use a combination of SMS editing and Quick Response (QR) codes that will allow a user to be make updates without needing to be granted access to a site within e-Manifest. The updates will be automatically pushed through the system and into the manifest itself. The intent is to make the process nearly as convenient as just updating a paper form on a clipboard.

Expected Regulatory Changes and Timeline

While there have already been three rulemakings to implement the use of e-Manifests, none have fully sunset the use of paper manifests. A new proposed rule will need to be published that will include a date by which paper manifests can no longer be used. U.S. EPA currently anticipates publishing the rule to the Federal Register for public comment in early 2026 and a final rule is expected to be issued in 2027. U.S. EPA is still weighing their options as to how soon compliance will be required and if there will be a staggered approach or not.

The new rule will likely require many additional waste handlers to register with e-Manifest. These include:

• Episodic VSQGs operating under 40 CFR part 262, subpart L
• Handlers of pharmaceutical wastes subject to 40 CFR part 266, subpart P
• RCRA transporters
• PCB generators and transporters subject to the manifest under 40 CFR 761, subpart K

In addition to the new rule, several existing regulations (40 CFR Parts 260, 262-267, 271, and 761) need to be updated to remove language pertaining to the use of paper manifests. These current Resource Conservation and Recovery Act (RCRA) and Toxic Substances Control Act (TSCA) regulations may also be updated to remove paper recordkeeping requirements as all necessary records would be accessible through e-Manifest

After over 40 years of tracking hazardous waste shipments with paper manifests, a full phaseout is imminent. Overhauling such an extensive recordkeeping system has come with many obstacles, and there are surely more to come. ALL4 is following these changes and is available to assist your company with the e-Manifest system. Please reach out to Meredith Pedraza at mpedraza@all4inc.com or your ALL4 project manager with questions.