As noted in previous e-Manifest updates, EPA on March 5, 2026, published the following proposed rule: Paper Manifest Sunset Rule; Modification of the Hazardous Waste Manifest Regulations (91 FR 10862). This will force the use of total electronic and hybrid manifests and effectively sunset or terminate the use of Paper Manifests, also for state-regulated wastes that require the use of a Uniform Hazardous Waste manifest. Comments on this proposed rule are due by May 4, 2026.
Once the actual rule is published (sometime later this year we suspect), it will take two years for the rule to come into effect. Consequently, paper manifests will likely be obsolete by September of 2028. This will affect all Hazardous Waste Generators (Large Quantity and Small Quantity), Hazardous Waste Transporters and Hazardous Waste TSDFs. Additionally, all entities using e-Manifest must be registered for an account in the RCRAInfo e-Manifest system. The registration requirement is already in effect. Hybrid manifests will still be allowed, which means the generator can sign on paper, but an electronic manifest must be started at the time of shipment and the first transporter, and all other handlers of the waste must sign electronically in e-Manifest. Note that paper manifests can still be used in the event of an emergency in the unlikely event that the e-Manifest system fails. This does not affect the DOT shipping paper requirement for Hazardous Materials. As a reminder, all Regulated Hazardous Wastes are also Regulated Hazardous Materials under DOT. A paper copy of the manifest can be printed out from the e-Manifest system to fulfill this requirement.
The full notification can be found here: https://www.federalregister.gov/documents/2026/03/05/2026-04366/paper-manifest-sunset-rule-modification-of-the-hazardous-waste-manifest-regulations
WTS will continue to monitor this situation and advise accordingly. For our generator clients, WTS will still be partnering with you to provide you with Compliant Hazardous Waste Manifests. If you would like to get ahead of the curve and implement Electronic Manifest prior to the required date, please contact your WTS representative and we will partner with you throughout the process.
As always, if you have any questions on this matter, please do not hesitate to contact your WTS representative.
