April 15, 2026

Paper Manifest Sunset Rule Proposed

On March 5, 2026, EPA proposed its paper manifest sunset rule, setting the stage for an all-electronic future. [91 FR 10862] The rule would require waste handlers to use the e-manifest system, accessible via RCRAInfo, to track all shipments of hazardous waste, effective two years after publication of the final rule. Consequently, only electronic and hybrid manifests could be submitted to the e-manifest system, and the image and data-plus-image submittal options would no longer be available. Hybrid manifests will be limited to those initiated electronically but printed for the generator to sign a paper copy and for the initial transporter. Subsequent handlers complete the hybrid manifest electronically.

In addition to hazardous waste generators, transporters, and TSDFs, affected entities include VSQGs using the episodic hazardous waste provisions, Subpart P healthcare facilities and reverse distributors, importers and exporters, PCB waste handlers, and waste brokers. Brokers who assist in preparing or arranging hazardous waste shipments would need to be referenced in field 14 of the manifest by a standardized statement:

“[Broker company name], EPA ID [EPA identification number], prepared and/or arranged the shipment on behalf of the generator.”

Any entity can enter that required statement, but the generator remains responsible for ensuring the broker’s name and ID number are accurately included in the statement.

EPA is also proposing revisions to definitions across the manifest regulations to clarify that a manifest is only the electronic version of EPA Form 8700-22 (the uniform hazardous waste manifest) and 8700-22A (the manifest’s continuation sheet). Other definitions related to users, manifest submissions, and handwritten signatures would be amended or removed. To comply with DOT hazardous material transportation requirements, generators would continue to print a copy of the manifest from the e-manifest system and provide it to the transporter. To account for instances when the e-manifest system may be unavailable, EPA envisions allowing users to print a standalone manifest from an EPA website on a separate network and follow paper-based manifest procedures. If this happens, the generator must retain a copy of the printed manifest for three years after the waste is shipped. A printed copy would also need to be retained by generators for three years after the shipment if a hybrid manifest is used.

Comments on the proposal may be submitted through May 4, 2026 via Docket ID No. EPA-HQ-OLEM-2025-3456.

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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.