Environmental compliance never really sits still. RCRA is a perfect example.

Some recent changes have already taken effect. Others are coming down the pipeline in 2026 and beyond. And a few of the proposals on the EPA’s agenda — PFAS, lithium batteries, full e-Manifest adoption — could reshape how facilities manage hazardous waste for years to come.

Are you an environmental manager juggling deadlines across multiple facilities? Here’s what you need to know.

The e-Manifest Changes Are Already in Effect

If you haven’t fully transitioned your team to e-Manifest workflows, now is the time. Several key updates took effect in early 2025, with more following in December.

Corrections happen electronically — and on a clock. As of January 22, 2025, manifest reviews and corrections are handled through e-Manifest. When the EPA or a state agency identifies an issue, your facility has 30 days to resolve it. The good news: generators can also self-identify and correct errors before regulators do.

Exception and discrepancy reporting timelines shifted. LQGs now have 45 days for initial inquiries and 60 days for formal exception reports. Facilities also have 20 days — up from 15 — to investigate and respond to discrepancy reports. That extra time matters, but only if your team knows how to use it.

Paper manifests are gone. Destination facilities no longer send paper manifest copies to LQGs and SQGs. e-Manifest is now the system of record. If your team hasn’t set up system access and user registration, this needs to happen immediately.

All three report types now go through e-Manifest. As of December 1, 2025, exception reports, discrepancy reports, and unmanifested waste reports must all be submitted electronically. That covers communication with both state agencies and the EPA.

One important note on exception reports: since TSDFs no longer send signed paper copies back to generators, e-Manifest is your primary way to confirm waste reached its destination. If a signed manifest doesn’t appear within the required window, that can trigger a report. But if you have a signed copy and it just hasn’t been entered into the system yet, that’s a data issue — not a missing shipment. Work with your vendor to get it added.

What’s Coming in 2026 (and Why You Should Start Preparing Now)

Full Transition to Electronic Manifests

The EPA has signaled its intent to phase out paper manifests entirely. A Federal Register announcement is expected sometime in 2026.

Most generators already require electronic records. But this move would eliminate the paper option for everyone. The industry broadly supports the shift, but questions remain around implementation. This is especially a concern for facilities with limited connectivity or during system outages.

Here’s the thing: only a small percentage of the roughly two million manifests received each year are currently submitted electronically. The EPA wants, and needs, broader adoption. The time to get comfortable with e-Manifest is now, not when a mandate forces your hand.

What to do:

• Get your team trained and comfortable in e-Manifest today.
• Run test submissions during non-critical shipments to identify gaps.
• Build a backup procedure for system downtime.

Lithium-Ion Batteries as Universal Waste

The EPA is working on a proposed rule to create a new, tailored universal waste category specifically for lithium batteries. Solar panels are also proposed for inclusion.

The proposed rule is expected in February 2026, with a final rule targeted for August 2027. Lithium-ion batteries can already be managed as universal waste under existing federal rules — but the EPA is proposing tighter, more specific standards to reduce fire risks from improperly handled batteries at end of life.

Under the universal waste framework, you don’t need manifests for shipping. But you do need to send waste to permitted recyclers or disposal sites. If finalized, the new rule would set clearer standards for handling, storage, and labeling.

Worth noting: some states aren’t waiting. Hawaii already manages lithium-ion batteries as universal waste for businesses. California has added solar panel modules to its program. If you operate in those states, follow your existing state rules — they may differ from the eventual federal requirements.

What to do:

• If you generate lithium batteries, the EPA recommends managing them as universal waste now, even before the rule finalizes.
• Start planning for potentially stricter requirements.
• Monitor state rules in every state where you operate.

PFAS as RCRA Hazardous Constituents

In February 2024, the EPA proposed adding nine PFAS compounds to the list of hazardous constituents under RCRA. The final rule is expected in April 2026.

This listing applies specifically to the RCRA Corrective Action Program — meaning it primarily affects RCRA-permitted treatment, storage, and disposal facilities. Where necessary, those facilities would need to investigate and clean up releases of the listed PFAS compounds.

This is not the same as listing PFAS as hazardous waste. The full “cradle to grave” management requirements wouldn’t apply — yet. But the EPA has indicated this could be a stepping stone toward a future hazardous waste listing. That would mean significantly broader requirements for generators, transporters, and disposal facilities alike.

The nine proposed PFAS: PFOA, PFOS, PFBS, GenX (HFPO-DA), PFNA, PFHxS, PFDA, PFHxA, and PFBA.

What to do:

• If your facility uses or generates PFAS-containing materials, start tracking where they’re used and how they’re managed.
• Watch for the EPA’s final rule this spring.
• Stay ahead of future PFAS rulemaking — the regulatory direction is clear.

Don’t Wait for a Mandate

The pattern across all of these changes is the same: the EPA is moving toward tighter tracking, electronic systems, and expanded accountability for hazardous materials. Facilities that build the right processes now, before rulemakings finalize, will be in a much stronger position than those scrambling to catch up.

That means training your team, auditing your current workflows, and making sure your compliance processes can flex as new rules take effect.

Want the full picture? Our 2026 RCRA Guide walks through all of this — plus the foundational rules, generator categories, waste classification, and more.