Deadline Ahead: How the Third e-Manifest Rule Will Impact Generators

The EPA’s third e-Manifest rule is here, and it’s more than just another regulatory tweak. As of January 22, 2025, generators need to navigate new site manager requirements, prepare for additional reports to move into the e-Manifest portal, and anticipate the long-term shift toward fully electronic manifests.

If your team is asking “what does this really mean for us?”, this article breaks it down.

Want the full walk-through? Watch the on-demand webinar with Encamp experts Adam Estes and Kevin Vinson.

What the Third Rule Changes

EPA’s e-Manifest program has been expanding for years, but this third rule brings the most practical impact for generators so far. Key updates include:

• Establishing the Site Manager role in RCRAInfo / e-Manifest (separate from Site Contact).
• Introducing new discrepancy, exception, and unmanifested waste reports directly into the portal, with a December 1 target for launch.
• Rolling out a manifest corrections workflow with a 30-day fix window.
• Laying the groundwork for future regulatory modules in e-Manifest, including TSCA import / export tracking and WIETS.
  

In short: more activity is shifting into the e-Manifest portal, and oversight will only increase.

Site Manager vs. Site Contact

One of the most confusing changes is the requirement for a Site Manager — a role that did not exist in regulations before e-Manifest.

• Site Contact: The person regulators call about spills, incidents, or compliance questions regarding the site.
• Site Manager: A permissions role within RCRAInfo. They assign users, control access levels, and approve submittals.
  

EPA requires at least one Site Manager per EPA ID number for large quantity generators (LQGs) and small quantity generators (SQGs). But having just one creates risk. If that person leaves the company, access can be lost.

Best practice: assign at least two Site Managers for redundancy.

And while very small quantity generators (VSQGs) are not federally required to designate a Site Manager, doing so can make episodic events and state-specific requirements much easier to manage.

Federal Rule, Fifty States

Here’s where things get tricky: e-Manifest is a federal program, but enforcement is handled by the states. That means requirements can look different depending on where you operate. The following are a few, though by no means exhaustive, examples:

• California doesn’t recognize VSQGs and issues its own state IDs, which still require Site Managers.
• Vermont, New Hampshire, and Washington require EPA IDs even for VSQGs.
• Minnesota can require EPA IDs and Site Managers depending on county-level rules.
  

Takeaway: Don’t assume federal rules are the final word. Create a state-by-state compliance playbook to avoid surprises.

New Reporting Deadlines

EPA is moving more reporting requirements into the e-Manifest system. Generators should prepare for three new workflows:

• Discrepancy Reports: Triggered when waste received differs from the manifest (10%+ quantity difference, wrong waste type, or residues). The resolution window will extend to 20 days. While this isn’t a report that the generator files (it’s a TSDF responsibility), it will likely flag the Site Manager. So, it’s good to be aware of it.
• Exception Reports: If a generator doesn’t receive the final manifest from a TSDF, large quantity generators must act at 45 days and file at 60 days. This process will move from paper/email to an in-portal button.
• Unmanifested Waste Reports: If a TSDF receives hazardous waste without a manifest, they’ll need to recreate the record in e-Manifest within 15 days. This will likely flag the Site Manager, so generators be aware.
  

What this means for you: update your SOPs now so your team knows who clicks what, and when.

Manifest Corrections Go Digital

Since January 22, 2025, EPA has been flagging mismatches between paper manifests and e-Manifest entries. Generators have 30 days to make corrections.

The three most common errors?

1. Waste codes — missing, mismatched, or entered incorrectly.
2. EPA ID numbers — transposed or wrong facility IDs.
3. DOT shipping names — often the most complex field.
   

While the correction process in e-Manifest is relatively simple, the administrative burden of frequent errors adds up quickly. Regular internal reviews can catch mistakes before EPA does.

Looking Ahead: The Push to Fully Electronic

EPA has already mandated fully electronic manifests for its own cleanup sites. That’s a clear signal: the ultimate goal is a fully digital system.

Moving away from hybrid paper/electronic manifests will improve data accuracy and oversight — but it will also demand more from generators in terms of systems, processes, and training. Now is the time to start preparing.

The Bottom Line

The third e-Manifest rule signals a future where hazardous waste tracking is centralized, digital, and closely monitored. For generators, it means new responsibilities, tighter deadlines, and fewer margins for error.

Want to see real workflows, examples, and compliance tips? Watch the on-demand webinar. Encamp’s experts walk through the rule in detail, highlight state-specific wrinkles, and share practical strategies to stay ahead of the changes.