The EPA has rolled out an important update to hazardous waste reporting that will affect how storage and transfer facilities track waste. Understanding these changes now will help ensure smooth compliance as the 2027 deadline approaches.
What’s Changing
Starting January 1, 2027, the EPA will retire Management Method Code H141 (Storage and Transfer) from both e-Manifest and the Biennial Hazardous Waste Report. In its place, storage and transfer facilities will use new “S” codes that provide much greater specificity about how waste will ultimately be managed after storage (these codes are already live, so you don’t have to wait until 2027 to start using).
This update addresses a long-standing issue from previous reporting cycles. H141 functioned as a catch-all code that didn’t tell regulators or generators what would actually happen to waste once it left the storage facility. The new codes eliminate this ambiguity and create a clearer line of sight into final waste management activities.
The New “S” Codes
The EPA has introduced 24 new codes, each beginning with “S” and corresponding to a specific final management method. For example:
- S010 for waste stored and transferred for metals recovery.
- S040 for waste stored and transferred for incineration.
- S132 for waste stored and transferred for landfill disposal.
- S070 for waste stored and transferred for chemical treatment.
These codes mirror existing management method codes but specifically indicate that storage and transfer will occur before final treatment or disposal.
What You Need to Know
The codes are available now. While H141 remains valid until January 1, 2027, the new S codes are already active in RCRAInfo for e-Manifest and the 2025 Biennial Report. The EPA recommends that storage and transfer facilities begin using them now, rather than waiting for the deadline.
How it works in practice. When a storage facility receives waste for later metals recovery, the TSDF will use S010 on the manifest. The final receiving facility that performs the metals recovery will continue using H010.
What this means for generators. TSDFs are responsible for entering these codes, but generators should understand the change and verify that their storage and transfer facilities use the appropriate S codes instead of H141. This improved tracking provides better visibility into how your waste is ultimately managed.
Some states don’t accept H141. Several states do not currently accept H141 as a valid Management Method Code in reporting — it may be acceptable on the manifest, but you still need to track down the final management method for the subsequent waste report. The S codes help alleviate this burden; if you operate in these states, talk with your vendors about adopting the S codes now, and then repeat this process for your other states. For a full breakdown, see Encamp’s State Waste Reporting pages.
Prepare for manifest corrections. Work with vendors to begin the transition away from H141 now. Encamp anticipates a spike in manifest correction requests after January 1, 2027 when H141 is no longer allowed (this can affect your December shipments that occurred prior to the January 1, 2027 deadline because they didn’t reach eManifest before the 1st). Transitioning now will help reduce that workload.
For more information. The EPA announced this update in its January 2025 Waste Management Newsletter. Questions about the new codes can be directed to the e-Manifest Users Call or the EPA RCRAInfo Team.
How Encamp Can Help
Navigating regulatory changes like these new management method codes can be complex, especially when you manage compliance across multiple facilities or state jurisdictions. Encamp’s environmental compliance platform can analyze your current manifest data to identify how many of your shipments still use H141, giving you visibility into which storage and transfer facilities in your waste stream will need to transition to the new S codes.
This baseline understanding helps you proactively communicate with your TSDFs and plan for the 2027 deadline. As the transition progresses, Encamp will build automated validation to alert you when facilities should be using S codes instead of H141, ensuring that your waste tracking stays compliant.
Whether you’re preparing for the 2025 Biennial Report cycle or monitoring the industry-wide move away from H141, Encamp provides the tools and expertise to keep your hazardous waste management accurate, compliant, and efficient.
