EPA’s New e-Manifest Reporting Requirements: What Generators Need to Know

EPA recently issued a reminder regarding its e-Manifest Third Final Rule, published July 26, 2024. The rule finalizes a major shift: several manifest-related reports must be submitted electronically through the e-Manifest system starting December 1, 2025.

Below is a quick breakdown:

1. Exception Reports — Biggest Change for Generators

Beginning December 1, 2025, Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) must submit Exception Reports electronically via e-Manifest.This requirement does not apply to Very Small Quantity Generators (VSQGs) or PCB generators. 40 CFR § 262.42

Submission triggers:

• LQGs & SQGs: Submit an Exception Report if you have not received a signed manifest from the receiving facility within 60 days of the waste being accepted by the initial transporter.

• Rejected Shipments: If waste is redirected to an alternate facility on a new manifest and you do not receive a signed copy from the alternate facility within 60 days, an Exception Report is required.

  
  

2. Discrepancy Reports — No Change for Generators

Discrepancy Reports are still a receiving facility obligation, but reporting must occur in e-Manifest starting December 1, 2025.

What counts as a discrepancy? (40 CFR § 265.72)

• Quantity:

  • Bulk: >10% deviation in weight

  • Batch: Any variance in item count (e.g., one drum missing)

• Type:

  • Obvious differences in waste description vs. what is received (e.g., solvent received instead of acid)

    
    

If the discrepancy cannot be resolved with the generator or transporter within 20 days, the facility must file a Discrepancy Report electronically.

3. Unmanifested Waste Reports — Facilities Only

No new obligations for generators. Facilities that accept waste without a manifest must submit an Unmanifested Waste Report electronically within 15 days of receipt, unless the waste is exempt from manifest rules.

Compliance & Preparation

For SQGs and LQGs, timely submission of Exception Reports is now a core compliance requirement. Failure to meet these deadlines risks enforcement actions and violations under RCRA.

Next steps:

·      Ensure your generator site is registered in RCRAInfo

·      Confirm user permissions for e-Manifest

·      Train responsible personnel ahead of the December 2025 transition

EPA provides registration guidance:

• RCRAInfo Sign-In page

• “User Registration” instructional video

Bottom line: EPA is moving generator reporting into the digital age. If you are an LQG or SQG, build internal processes now so your Exception Reports flow through e-Manifest on day one.