⚠️ Next Biennial Report Due: March 1, 2028

e-Manifest applies to any facility shipping hazardous waste off-site using a manifest, including:

Generator categories:

• Large Quantity Generators (LQGs) — producing 1,000 kg or more of hazardous waste per month
• Small Quantity Generators (SQGs) — producing 100–1,000 kg per month
• Very Small Quantity Generators (VSQGs) — when a manifest is required by state or federal rules

Transporters:

• DOT-licensed hazmat carriers transporting manifested waste
• Required to sign manifests electronically or submit paper copies to EPA Manifest Processing Center

Treatment, Storage, and Disposal Facilities (TSDFs):

• All facilities receiving manifested hazardous waste shipments
• Required to complete and submit manifests electronically within 30 days of receipt

Any facility shipping hazardous waste off-site using a manifest must comply with e-Manifest requirements, regardless of generator category.

Critical Deadline:

As of January 22, 2025, all LQGs and SQGs must be registered for e-Manifest. Facilities that are not registered cannot legally initiate hazardous waste shipments. If your facility has changed generator status — moved from VSQG to SQG, or SQG to LQG — registration requirements apply immediately upon reclassification. Do not wait for your next scheduled shipment to confirm your registration status.

Step 1: Generator Initiates Manifest

The generating facility logs into EPA's e-Manifest portal through CDX and creates a new manifest by entering waste type, quantity, EPA waste codes, and destination TSDF information. The manifest is saved in the system and held for transporter signature at pickup.



Errors at this stage — incorrect waste codes, wrong quantities, or missing TSDF information — require electronic corrections after the fact. There is no paper correction pathway as of January 22, 2025.

Step 2: Transporter Signs Electronically

When waste is picked up, the transporter logs into e-Manifest and signs the manifest electronically. A printed copy accompanies the shipment to satisfy DOT requirements during transport. The transporter's signature creates a timestamped record in the national database.

Step 3: Receiving Facility Completes the Manifest

When the shipment arrives at the TSDF, the facility logs in, receives the shipment, and electronically signs and submits the manifest to EPA. TSDFs have 30 days from receipt to complete this step. Manifests not completed within 30 days appear as "unmatched" in the system — creating reconciliation problems for generators, particularly ahead of biennial reporting deadlines.

Step 4: Data Stored in National System

All manifest data flows into EPA's central database upon TSDF completion. Generators can access completed manifests through the RCRAInfo portal at rcrainfo.epa.gov. Certificates of Disposal are issued separately by receiving TSDFs when applicable and are required for complete biennial report reconciliation.



Unmatched manifests do not automatically resolve. Generators are responsible for following up with TSDFs to close open records — a task that becomes significantly harder when left until the months before a March 1 filing deadline.

For Generators:

• Real-time tracking of waste shipments from pickup through final disposal
• Immediate access to completed manifests once TSDFs submit
• Direct integration with biennial reporting, reducing manual data entry and calculation errors
• Processing fees of $4 per electronic manifest versus $20 or more for paper submission
• Faster identification and correction of manifest errors before they become compliance problems
• Centralized records accessible for EPA inspections without manual file retrieval

For Transporters and TSDFs:

• Streamlined manifest completion and electronic submission
• Reduced paperwork, physical filing, and postal submission requirements
• Improved coordination with generators and regulators through shared system access

For Regulators:

• Centralized data for compliance monitoring and enforcement
• Improved accuracy in waste tracking and shipment history
• Faster detection of manifest fraud, illegal dumping, or missing shipment records

Industry-Wide Impact:

EPA estimates e-Manifest saves the waste management industry approximately $75–90 million annually in administrative costs. For individual facilities, the more immediate impact is inspection readiness — electronic records are immediately accessible, consistently formatted, and directly tied to biennial reporting data.

Facilities still relying on paper manifests are not just paying more per shipment. They are creating documentation gaps that become audit liabilities.

Registration Steps:

Step 1: Create a CDX Account

Go to cdx.epa.gov and create an account. You will need a valid email address and basic facility information. Each person who will sign manifests electronically needs their own CDX account — shared credentials are not permitted.



Step 2: Register for RCRAInfo Access

Within CDX, register for the RCRAInfo program. This connects your facility's EPA ID number to the e-Manifest system. If your facility does not have an EPA ID number, you must obtain one through your state environmental agency before completing this step.

Step 3: Obtain Signatory Authorization

To electronically sign manifests, each user must complete the Electronic Signature Agreement (ESA) process within CDX. This involves identity verification and agreement to EPA's electronic signature terms. Without signatory authorization, users can view manifests but cannot initiate or sign them.

Step 4: Authorize Third-Party Access (If Applicable)

EPA allows generators to authorize third parties — such as U.S. Waste Industries — to create and sign manifests on their behalf. This reduces administrative workload for facilities managing multiple waste streams or frequent shipments.

Important Registration Considerations:

• Generator status changes trigger immediate registration requirements — do not wait for your next shipment
• Facilities that have never shipped hazardous waste but anticipate doing so should register before the need arises
• Multi-site operations require separate registration for each facility with a distinct EPA ID number
• Transporters and TSDFs must complete their own independent registration and signatory authorization
  

U.S. Waste Industries can guide facilities through CDX registration, RCRAInfo access setup, and signatory authorization — reducing the administrative burden on EHS staff managing multiple compliance priorities simultaneously.

EPA charges manifest processing fees to fund system operation:

Fully electronic manifest

Processing Fee: $4

Paper manifest (manual data entry)

Processing Fee: $20+

Hybrid manifest (scanned/uploaded)

Processing Fee: $10–15

TSDFs are billed monthly by EPA based on number of manifests processed. Some TSDFs pass portion of these fees to generators as part of disposal costs.

Processing fees for paper manifests are significantly higher than for fully electronic manifests. Facilities transitioning from paper to electronic manifests reduce processing fees by up to 80%.

Paper Manifest Limitations:

Facilities can still use paper manifests, but they must follow updated submission procedures:

• Top copy must be mailed or uploaded to EPA Manifest Processing Center
• EPA manually enters data into e-Manifest
• Processing fees significantly higher than electronic submission
• As of January 22, 2025, paper manifest corrections are no longer accepted by EPA; all corrections must be submitted electronically through the e-Manifest system.

Facilities using paper manifests experience longer processing times and delayed access to completed manifests.

Large Quantity Generators are required to file a Biennial Hazardous Waste Report with EPA by March 1 of each even-numbered year. The report covers hazardous waste generated and managed during the previous calendar year. The next federal deadline is March 1, 2028, covering calendar year 2027 waste generation data.

Facilities that treat biennial reporting as a February task consistently run into problems. The data required to file accurately — manifests, Certificates of Disposal, waste characterization records — accumulates throughout the year. Gaps discovered in February are significantly harder to resolve than gaps caught quarterly.

Who Must File

• Large Quantity Generators (LQGs) are required to file the federal Biennial Report
• Small Quantity Generators (SQGs) are not required to file federally, but some state programs impose their own reporting requirements — verify with your state environmental agency
• Very Small Quantity Generators (VSQGs) are generally exempt from biennial reporting requirements

How e-Manifest Supports Biennial Reporting

e-Manifest integrates directly with EPA's RCRAInfo system and stores all manifest data electronically, reducing manual data entry and providing a pre-populated starting point for report preparation.

What e-Manifest simplifies:

• Centralized storage of all hazardous waste shipment records
• Direct access to manifest history through RCRAInfo
• Faster identification of missing or incomplete shipment records

What e-Manifest does not do automatically:

• Reconcile manifests with Certificates of Disposal
• Flag or resolve unmatched manifests on your behalf
• Substitute for state-specific reporting requirements

The Reconciliation Problem Most Facilities Ignore

Before filing, LQGs must reconcile e-Manifest data with Certificates of Disposal from receiving TSDFs — confirming every shipment has a documented final disposition. This means matching completed manifests to CODs, identifying unmatched manifests where TSDFs haven't submitted within 30 days, and following up to close open records.

Unmatched manifests are the most common source of biennial reporting gaps — and they're significantly easier to resolve when caught quarterly rather than in January.

Recommended Practice: Reconcile e-Manifest records against Certificates of Disposal quarterly. Facilities that wait until January discover problems that may take weeks to resolve, pushing preparation past the March 1 deadline.

Since e-Manifest launched in 2018, U.S. Waste Industries has worked with industrial facilities to manage hazardous waste shipments, maintain accurate manifest records, and prepare for biennial reporting requirements. Our role in the e-Manifest process is practical and direct — we reduce the administrative burden on EHS staff while ensuring shipment documentation meets EPA requirements.

Our e-Manifest support includes:

• Manifest creation and submission — we draft and submit electronic manifests on behalf of clients, reducing administrative workload and ensuring waste codes, quantities, and TSDF information are entered accurately
• Registration guidance — we provide support for CDX account setup, RCRAInfo registration, and signatory authorization
• Manifest reconciliation — we help facilities reconcile e-Manifest records against Certificates of Disposal on a quarterly basis — not in February when it's too late to resolve gaps cleanly
• TSDF coordination — we follow up directly with receiving facilities to close unmatched manifests before they create biennial reporting problems
• Transition support — we help facilities still using paper or hybrid submission methods move to fully electronic manifests, reducing per-manifest processing costs
  

e-Manifest Expertise Since 2018 We've supported facilities through every phase of e-Manifest — from initial registration and paper-to-electronic transition to manifest reconciliation and biennial report preparation. Our team knows EPA's CDX portal and RCRAInfo system, and we manage the documentation process so your EHS staff isn't buried in administrative follow-up.

Direct Access. Proactive Support. Family-owned with 25 years managing hazardous waste compliance. Real people answer the phone Monday through Friday, 7 AM to 5 PM, with direct access to your project manager. We reconcile manifest records quarterly — not in February when gaps are hardest to fix.

Inspection-Ready Documentation Every hazardous waste shipment we manage includes EPA e-Manifest submission, Certificates of Disposal from receiving TSDFs, waste profiles and characterization documentation, and biennial reporting support for LQGs. Your records are audit-ready before an inspector ever requests them.