Why the EPA’s New e-Manifest Strategy Could Reshape Hazardous Waste Tracking

Big changes are coming to the EPA’s e-Manifest system. Here’s why they matter—and how to stay compliant without stress.

Six years after launching its nationwide e-Manifest system, the EPA has a problem: fewer than 1% of hazardous waste manifests are fully electronic. Now, the agency is gearing up for a sweeping strategy shift—and it could upend how your company handles compliance.

From rising user fees to a possible end of paper manifests, the upcoming changes are more than technical—they’re transformational. At Wastebits, we’ve been processing e-Manifests for years, working with the largest names in waste to ensure compliance…but we still see this unfortunate scenario: many businesses don’t realize what’s coming until it’s too late.

In this post (as we do with our customers and partners), we’ll unpack the real drivers behind the EPA’s new direction, expose what’s buried in the latest advisory board recommendations, and show how Wastebits is already helping companies stay one step ahead. If hazardous waste manifests are part of your operation, you’ll want to read on. These changes won’t wait for you to catch up 😬.

A System in Transition: What’s Prompting the Change

When the EPA launched the e-Manifest system in 2018, the vision was clear: eliminate paper, streamline compliance, and create a centralized digital trail for hazardous waste. But reality hasn’t kept pace. Despite the availability of electronic options, fully digital manifests have barely cracked the 0.5% mark—even after six years of rollout.

This slow adoption has frustrated regulators and stakeholders alike, and now, the EPA is signaling it’s ready to accelerate the shift. In recent advisory board meetings, the agency outlined its priorities for Fiscal Years 2026 and 2027, including:

• Coordinating closely with the Department of Transportation
• Rolling out improvements tied to the “Third Rule”
• Expanding end-user support and help desk services
• Enhancing data quality
• Laying the groundwork to sunset paper-based options.

But it’s not just the EPA pushing for progress. The Advisory Board urged the agency to move faster—and more transparently—especially when it comes to involving industry partners and state agencies in its conversations with DOT. Without regulatory alignment and better outreach, they warned, digital adoption could stall even further.

There’s a growing sense that the e-Manifest program is at a crossroads. The next two years may define whether this system becomes the industry standard—or remains an underutilized government platform.

Fee Hikes and Format Penalties: The New Cost Landscape

If you’re still submitting image uploads or relying on hybrid manifests, you might want to double-check your budget. The EPA’s newly proposed fee structure for FY 2026/2027 sends a clear message: paper is no longer the preferred path.

Here’s how the fees are changing:

• Image Upload: $25
• Data + Image Upload: $7
• Fully Electronic: $5*

EPA Fee Tier	2018-2019	2020-2021	2022-2023	2024-2025	2026-2027
Mailed in Paper Manifest	$15	$25	N/A	N/A	N/A
Scanned Image Upload	$10	$20	$20	$22	$25
Data + Image Upload	$6.50	$14	$13	$10	$7
Electronic Manifest (Fully Electronic & Hybrid)	$5	$8	$8	$6	$5*

The most dramatic increase is for image-only uploads—a move designed to discourage the continued use of scanned paper copies. Meanwhile, data plus image submissions will see a discount, intended to help companies bridge the gap toward fully electronic adoption.

At $5, the cost difference may not be enough to justify the operational overhaul required to go fully digital.

But the Advisory Board wasn’t convinced this pricing shift goes far enough. They pushed for a more aggressive reduction in electronic manifest fees—proposing $1 or $2 per submission—to truly incentivize adoption. Their rationale? At $5, the cost difference may not be enough to justify the operational overhaul required to go fully digital.

At Wastebits, we’ve helped process over 1 million hazardous waste manifests, and we’ve seen firsthand how fee structures influence behavior. Many companies stick with outdated workflows simply because change feels risky—or confusing. But with paper options now the most expensive and sunset dates looming, the cost of doing nothing is about to rise.

The good news? Transitioning doesn’t have to be overwhelming. For teams used to three-ring binders and PDF uploads, a guided digital rollout can unlock efficiency gains and long-term savings. We’ve seen it happen again and again.

The Sunset of Paper: Will the EPA Finally Pull the Plug?

For years, paper manifest options have lingered in a sort of regulatory limbo—not quite phased out, but steadily deprioritized. That limbo may be coming to an end.

The EPA has officially signaled that it’s working on a proposed rule to sunset both image-only and data-plus-image manifest submissions, potentially phasing them out in stages. While no hard date has been finalized yet, the message is clear: a fully digital future is no longer a distant goal—it’s the destination.

This shift has huge implications for generators, transporters, and TSDFs still relying on manual processes. Once scanned paper images are retired, legacy workflows will no longer meet compliance requirements. The agency’s long-term plan includes not only regulatory change but a cultural shift—backed by help desk expansion, user outreach, and system redesigns.

At Wastebits, we’ve already helped numerous companies prepare for this reality. Whether it’s building hybrid workflows that ease the transition or offering full API integrations with RCRAInfo, we know that successful adoption starts with practical, user-friendly tools. And because we’ve supported organizations of every size, we understand how to tailor solutions that fit existing operations—rather than forcing you to rebuild from scratch.

The takeaway? The time to start preparing is now. Because when the paper options disappear, compliance will depend on how well you’ve embraced the tools of tomorrow.

Operational Impacts: What Generators, TSDFs, and Transporters Should Expect

The EPA’s push for digital adoption isn’t just about technology—it’s about accountability. And for many in the hazardous waste chain, that means major operational changes are on the horizon.

One of the biggest shifts comes from the Third Rule, which requires all Large and Small Quantity Generators to register in RCRAInfo and introduces a 30-day correction window for manifest errors. That means tighter deadlines, more system logins, and increased scrutiny around data accuracy.

In response, the EPA is expanding its support infrastructure. A retooled help desk will offer:

• Technical support for generators, TSDFs, and brokers
• Webinars tailored to transporters and receiving facilities
• Guidance for navigating registration and correction workflows
• System-to-system API support for more seamless integrations.

This expansion reflects what Wastebits has long recognized: regulatory compliance only works when it’s user-friendly. That’s why our platform already offers integrated signature capture, flexible access for all roles in the manifest lifecycle, and guided workflows that reduce data-entry errors before they occur.

With over 1 million manifests processed through our system, we’ve seen the nuances that trip up even the most well-organized teams—especially during transitions like this. For example:

• Facilities scrambling to meet the 30-day correction window
• Generators confused by multiple RCRAInfo logins
• Transporters unsure when digital copies are legally valid during transit

Wastebits provides not just a system, but a safety net—a way to stay compliant without second-guessing every signature or submission.

Wastebits as a Guide Through the Shift

While the EPA fine-tunes policies and projections, businesses on the ground are left to figure out the “how.” That’s where Wastebits comes in.

Wastebits isn’t scrambling to keep up with these changes—we’re ahead of them. Our platform was built for flexibility, evolving alongside regulatory shifts and offering multiple ways for users to stay compliant, even during industry-wide transitions.

Whether your team is still printing and filing or already experimenting with hybrid workflows, we meet you where you are. Our tools support:

• Fully electronic manifests with integrated digital signatures
• Hybrid processing for companies phasing out paper gradually
• Automated alerts to help meet new correction timelines
• Custom dashboards and reporting to stay audit-ready
• API integrations for enterprise-level systems

And it’s not just about software. Our team actively supports onboarding, training, and ongoing optimization—especially as new rules, like the Third Rule, go into effect. We’re already helping clients anticipate the operational shifts these changes will bring, so they don’t have to scramble when enforcement begins.

The EPA may be setting the destination, but Wastebits is the GPS helping companies get there without detours, delays, or compliance risks.

Conclusion: Change Is Coming—Will You Be Ready?

The EPA isn’t just adjusting fees or issuing new guidance—it’s steering the entire hazardous waste industry toward a digital future. From the proposed sunset of paper-based workflows to the new compliance demands of the Third Rule, the next two years will bring some of the most significant changes to manifesting in over a decade.

The question isn’t if your business will be impacted. It’s how prepared you’ll be when it happens.

With over a million manifests already under our belt, Wastebits has the tools, experience, and integration expertise to help you navigate this transition with confidence. Whether you’re a generator, transporter, or TSDF, we’re ready to support your shift toward full electronic adoption—without disrupting your operations.

Don’t wait until the rules are final and the deadlines are looming.
Book a demo today and see how Wastebits can simplify compliance, improve data accuracy, and future-proof your manifest process.