February 11, 2026

December 1, 2025 Deadline for e-Manifest Rule Compliance

On July 26, 2024, EPA issued the third e-manifest rule [89 FR 60692], and as of December 1, 2025, the following provisions are in effect:

• Requirement for exporters to submit export manifests via the e-manifest system and pay user fees; and
• Requirement to submit exception, discrepancy, and unmanifested waste reports via the e-manifest system.

Exporters

Domestic exporters must submit export manifests via the e-manifest system and pay the requisite user fees. [§262.83(c)(4)] Companies submitting data system-to-system should use the latest e-manifest JSON schema and export manifest examples to assist with integrating their system.

Each exporting site needs at least one registered user in RCRAInfo with site management permission to submit export manifests and pay fees. Site managers receive their invoice electronically on the first day of the month following manifest submission. The invoice summarizes the prior month’s manifest activity and identifies all manifests sent to EPA. Acceptable electronic payment methods include commercial credit card, commercial debit card, and automated clearing house (ACH) debit. Checks or any other forms of payment sent directly to the EPA are not accepted.

Manifest reports

Exception reports

Exception reporting requirements [§262.42] are triggered in two instances:

1. When a large or small quantity generator (LQG or SQG) has not received a copy of the manifest with the signature of the owner or operator of the designated facility within 60 days of the date the initial transporter accepted the waste, and
2. When a shipment is rejected and forwarded to an alternate facility using a new manifest, but the LQG or SQG has not received a copy of the manifest with the signature of the owner or operator of the alternate facility within 60 days of the date the initial transporter of the new manifest accepted the waste.

These generators must submit all exception reports through the e-manifest system. Users must be registered and have at least the certifier role in the e-manifest module for their site. A very small quantity generator operating under the episodic generation provisions must submit an exception report if necessary, but is not required to do so via the e-manifest system (because such generators are not required to have an e-manifest account).

Discrepancy reports

Manifest discrepancies include significant differences between the quantity or type of hazardous waste designated on the manifest and the quantity and type of hazardous waste a facility actually receives. [§§264.72 and 265.72] Significant differences in quantity are: for bulk waste, variations greater than 10% in weight; for batch waste, any variation in piece count, such as a discrepancy of one drum in a truckload. Significant differences in type are obvious differences that can be discovered by inspection or waste analysis, such as waste solvent substituted for waste acid, or toxic constituents not reported on the manifest or shipping paper.

Upon discovering a significant difference in quantity or type, the owner or operator must attempt to reconcile the discrepancy with the waste generator or transporter. If the discrepancy is not resolved within 20 days after receiving the waste, the owner or operator must immediately submit a discrepancy report via the e-manifest system, describing the discrepancy and attempts to reconcile it, along with a copy of the manifest at issue. Users must be registered and have at least the certifier role in the e-manifest module for their site.

Unmanifested waste reports

If a facility accepts for treatment, storage, or disposal any hazardous waste from off-site without an accompanying manifest and the waste is not excluded from manifest requirements, the facility must submit an unmanifested waste report via the e-manifest system within 15 days after receiving the waste. [§§264.76 and 265.76] Users must be registered and have at least the certifier role in the e-manifest module for their site.

 

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Considerable care has been exercised in preparing this document; however, McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with the publication of this information. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which this information may conflict. McCoy and Associates, Inc. does not undertake any duty to ensure the continued accuracy of this information.

This document addresses issues of a general nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with the environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.