EPA recently proposed a rule that would end paper and hybrid hazardous waste manifests — for good. If you’re still running pickups on paper (and most facilities are), this is worth your attention now, not later.

Here’s what the proposal says, what it means for your operations, and what to do in the meantime.

What EPA Is Proposing

On March 5, 2026, EPA released a proposed rule to sunset the use of paper and hybrid hazardous waste manifests in favor of e-Manifests — the electronic system that’s been available since 2018.

The proposed deadline: 24 months after the final rule is published. If EPA finalizes this rule in 2026, that puts the cutoff somewhere around 2027 or 2028.

After that date, paper-only and image-only submissions to the e-Manifest system would no longer be valid for tracking hazardous waste shipments under federal or state law.

The comment period closes May 4, 2026.

The Key Provisions — Plain and Simple

1. Paper manifests are out. No more submitting paper or image-only documents to the e-Manifest system for shipments initiated after the sunset date. Hybrid or fully electronic manifests only.
2. More facility types have to register. The proposed rule would extend mandatory e-Manifest registration to groups not previously required to register — including hazardous waste transporters, very small quantity generators (VSQGs) managing episodic events, healthcare facilities, reverse distributors, and PCB waste generators and transporters.
3. Exception and discrepancy reporting goes fully electronic. EPA eliminated paper-based discrepancy reporting as of December 1, 2025. This rule would extend those same requirements to more handler categories (see number 2 above for those handlers).
4. Recordkeeping moves to e-Manifest. Facilities would satisfy record retention requirements through their e-Manifest accounts rather than maintaining on-site paper copies. (Hybrid manifest generator copies remain an exception.) In practice, this is a simplification — but it requires your system access and registration to be in place before the deadline hits.
5. PCB waste generators face a new EPA ID requirement. Generators of PCB waste who are currently exempt from notification would need to obtain a TSCA-issued EPA ID. If you manage PCB waste, flag this now.

Here’s the Part That’s Easy to Overlook

The e-Manifest system has been available since 2018. Despite nearly a decade of availability, electronic manifests account for less than 1% of all submissions today.

That’s not a criticism — it’s context. Paper manifests are deeply embedded in how facilities operate, especially at the generator-to-transporter handoff. That’s the moment of physical custody transfer, and it’s where paper dependency is hardest to untangle.

EPA knows this. That’s part of why this rule exists. The agency isn’t nudging the industry toward e-Manifesting anymore — it’s drawing a line.

What This Means for Your Operations

For most facilities, the impact will be felt in a few concrete areas:

Workflow changes at the point of pickup. The generator-to-transporter handoff is the hardest part to transition. You’ll need a plan for how that process works without a paper manifest in hand. Make sure you know the distinction between a fully electronic and a hybrid manifest approach and update processes accordingly.

New registration requirements for more facility types. If your organization includes transporters, VSQGs with episodic events, or healthcare/pharma reverse distributors, those entities will need to be registered in e-Manifest — a step that takes time to coordinate across sites and personnel.

Hybrid manifests as a near-term bridge. Hybrid manifests — where the generator signs a printed copy but the rest is completed electronically — remain available under the proposal. For facilities with complex field operations, this is likely the most realistic near-term path. It’s not a permanent solution, but it buys time to transition without going cold-turkey on paper.

System access has to be in place before you need it. Registration, user permissions, and system familiarity aren’t things you want to sort out under deadline pressure. Starting now — even before the final rule — puts you ahead.

Should You Comment?

The comment period closes May 4, 2026. Whether or not you submit formal comments, it’s worth understanding what’s at stake and what others in the industry are raising.

A few things worth considering if you’re weighing whether to comment:

The e-Manifest Advisory Board recommended a phased approach. If your operations would benefit from a longer or more structured transition timeline, saying so on the record matters. EPA does consider comment volume and specificity when shaping final rules.

Operational complexity is a legitimate comment. If the 24-month window creates genuine hardship — particularly for multi-site operations, facilities with specialized waste streams, or organizations that depend on transporter coordination — document that clearly and specifically.

A blanket objection is less useful than a targeted one. Comments that explain why a provision is unworkable, with operational examples, carry more weight than general opposition to electronic systems.

If you’re not sure where to start, reaching out to your industry association or legal counsel for a read on how others in your sector are responding is a reasonable first step.

What to Do Now

You have time — but not unlimited time. Here’s how to use it well:

• Assess your current manifest volume and process. Understand which facilities are generating manifests, how many, and what the handoff process looks like at each one.
• Check your e-Manifest registration status. If you’re not registered — or if some of your facility types aren’t — start the process now.
• Identify which facility types fall under the new registration requirements. Transporters, VSQGs with episodic events, healthcare/reverse distributors, and PCB waste generators should all be on your radar. For VSQGs, it can be very tempting to think this doesn’t affect you, but keep in mind: Some states require VSQGs to get EPA ID numbers and the episodic generation rules require having an EPA ID number so it may be worth it to get an EPA ID number now rather than need one later…
• Evaluate whether hybrid manifests make sense as a bridge. For complex operations, this may be the most practical near-term path. Also consider if hybrid manifests are your preferred approach, if so, it may be worth commenting to EPA in case they later want to try and eliminate the hybrid option.
• Monitor the rule’s progress. This is still a proposal. The timeline could shift, especially given the Advisory Board’s recommendation for a phased approach. But waiting to act until it’s finalized is a risk.

Have questions about how this proposed rule could affect your compliance program? We’re here to help.