EPA’s Latest Hybrid Manifest Guidance: Are You Ready for What’s Ahead?

Still relying on paper manifests to stay compliant? You’re not alone—but the EPA is making it clear: hybrid manifests are the bridge to a fully electronic future, and 2025 is the year things start moving fast. With new requirements now in effect, lower fees for hybrid submissions, and stricter expectations around generator registration, the clock is ticking for waste generators, transporters, and TSDFs to adapt. Fortunately, the latest EPA guidance offers a clear roadmap—and with the right tools in place, compliance doesn’t have to be complicated.

What Is a Hybrid Manifest—and Why the 2025 Update Matters

A hybrid manifest starts the same way a traditional paper manifest does—by capturing signatures on a physical form. But instead of mailing that form to the EPA, the data is submitted electronically via RCRAInfo. This hybrid approach bridges the gap between legacy workflows and modern digital compliance, offering a more accessible path toward full e-Manifest adoption.

In May 2025, the EPA released updated guidance reinforcing its support for hybrid manifests as a preferred alternative to paper-only submissions. Among the highlights:

• Hybrid manifests now qualify for lower EPA submission fees—just $6 per manifest compared to $10–$20 for paper.
• All large and small quantity generators are now required to register with RCRAInfo in order to view final copies and make post-receipt corrections.
• Remote signing is permitted, and new tools make it easier to print, manage, and track hybrid manifests across facilities.

These changes signal a clear shift in EPA expectations—favoring digital efficiency, real-time access, and better data accuracy across the hazardous waste lifecycle.

Lower Fees, Fewer Headaches: Why Going Hybrid Pays Off

For years, the EPA’s e-Manifest system has offered multiple submission methods—but they weren’t all created equal when it comes to cost. As of 2025, the savings are more compelling than ever. Hybrid manifests now carry a $6 submission fee, compared to $10 for scanned images and $20 for mailed paper forms. That’s a 70% reduction for those willing to digitize just one part of the process.

But the benefits of hybrid go beyond fees:

• Faster processing: Hybrid manifests appear in RCRAInfo within hours—not weeks.
• Improved accuracy: Digitally submitted data reduces transcription errors from scanned paper.
• Real-time visibility: Both generators and TSDFs can track manifest status without waiting on physical mail.
• Audit readiness: Electronic records simplify compliance audits and reporting.

For organizations still managing stacks of paper or relying on faxed copies, hybrid manifests offer a practical middle ground—with meaningful savings and less friction. And with Wastebits, submitting hybrid manifests is fully integrated into your existing workflow—no extra tools or manual uploads required.

New Requirements in Effect: What Generators and TSDFs Must Do Now

The EPA isn’t just encouraging electronic adoption—it’s making parts of it mandatory. As of January 22, 2025, all Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) must register in RCRAInfo to access finalized manifest copies and perform post-receipt corrections. Without this access, generators risk falling out of compliance if data errors go unaddressed.

Here’s what’s required now:

• RCRAInfo Registration: Each site must have registered personnel assigned appropriate roles (e.g., Site Manager, Certifier).
• Manifest Corrections: Only registered users can initiate and approve post-receipt corrections to hybrid or electronic manifests.
• Visibility Obligations: Generators must be able to access the signed copy submitted by the receiving facility—this is only possible via RCRAInfo.

For TSDFs and transporters, it’s just as critical:

• Timely submission to EPA is expected—hybrid forms must be entered into RCRAInfo promptly.
• Remote signer policies must be respected, especially when using electronic tools to capture signatures from off-site personnel.
• Interstate shipments must account for state-specific e-Manifest adoption status, which Wastebits tracks and enforces automatically.

These aren’t just best practices—they’re baseline requirements. Wastebits ensures that every user role, signature, and submission is handled with full EPA alignment, reducing the burden on your team and keeping your operation inspection-ready.

Coming December 2025: New Hybrid Requirements for Exports and Exception Reporting

The hybrid manifest rules don’t stop at domestic shipments. Starting December 1, 2025, the EPA will implement new requirements under its Third Final Rule that expand e-Manifest and hybrid applicability to export shipments and additional reporting obligations. This marks a major shift in how regulated waste crossing U.S. borders—or handled under special conditions—must be documented and submitted.

Here’s what’s changing:

• Export manifests will be subject to the same electronic submission and signature expectations as domestic shipments.
• Exception reports, discrepancy reports, and unmanifested waste reports must now be filed through RCRAInfo, replacing older paper-based processes.
• Hybrid manifests will play a key role in this transition, serving as a compliant option for facilities that need time to fully digitize but still want to meet new reporting requirements.

These changes are designed to bring greater transparency and traceability to the entire hazardous waste lifecycle—even when materials cross international lines or deviate from standard routes.

For facilities that export waste or frequently handle discrepancies, now is the time to prepare. Wastebits’ platform is already built to support these upcoming requirements, including the ability to track hybrid exports, generate electronic exception reports, and integrate seamlessly with RCRAInfo’s new tools.

Update: New EPA User Fees and Payment Requirements for 2025–2027

The EPA has released updated user-fee guidance for the e-Manifest program, and several details meaningfully shift the cost landscape for facilities processing manifests. These changes apply to manifests submitted beginning October 1, 2025, and they further reinforce why hybrid and fully electronic submissions are the most cost-effective path going forward.

Receiving facilities will now see the following fee structure for fiscal years 2026 and 2027:

• Scanned image uploads: $25.00 per manifest
• Data + image uploads: $7.00 per manifest
• Fully electronic or hybrid electronic manifests: $5.00 per manifest

For context, the FY 2024–2025 fees are $22, $10, and $6 respectively. The downward shift in the hybrid/electronic fee makes the electronic path not only the most compliant and reliable, but now the lowest-cost option as well. Facilities relying heavily on paper or scanned workflows may see costs rise unless they modernize their process.

Only receiving facilities are billed for e-Manifest fees, and the EPA continues to issue monthly invoices to the Site Manager listed in RCRAInfo. Payments must be made electronically—via ACH or commercial credit/debit card—and routed through the e-Manifest Payment Portal. If an invoice is not paid within the month it’s issued, penalties begin accruing, and debts unpaid for 120 days may be referred to Treasury for collection.

For receiving facilities, this is a good moment to verify internal billing workflows, confirm that Site Manager permissions are up to date, and evaluate whether current manifest submission methods are aligned with the lowest-cost option. For generators and transporters, the updated fee schedule strengthens the business case for shifting vendors toward hybrid or fully electronic processes—reducing cost exposure while improving turnaround times and data quality.

How Wastebits Helps You Stay Ahead of EPA Expectations

The EPA’s message is clear: the future of manifesting is digital—and hybrid workflows are the gateway. But navigating the evolving requirements, system updates, and state-by-state adoption can feel overwhelming without the right partner.

That’s where Wastebits comes in.

Our hybrid manifest solution is purpose-built for compliance, efficiency, and ease of use. Whether you’re just beginning to move away from paper or you’re managing complex, multi-site operations, we help you:

• Submit hybrid manifests directly to the EPA without extra steps or manual data entry.
• Assign and manage RCRAInfo roles for your team, ensuring proper access and approvals.
• Capture signatures remotely—in the field, at the facility, or from authorized off-site personnel.
• Track manifest status in real time, including discrepancies and post-receipt corrections.
• Stay compliant with upcoming changes for export and exception reporting—before they become a problem.

As the EPA continues modernizing the nation’s hazardous waste tracking system, Wastebits is right there with them—ensuring our customers aren’t just compliant, but confident.

Ready to Simplify Hybrid Manifests?

If you’re looking for a smarter way to manage manifests, reduce costs, and stay ahead of EPA requirements, Wastebits is here to help. Our hybrid manifest solution takes the guesswork out of compliance—so you can focus on your operations, not the paperwork.

Request a demo to see how Wastebits can streamline your hazardous waste tracking and make hybrid manifests work for you.