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The EPA continues to modernize hazardous waste tracking with the latest final Third Rule of the e-Manifest system. These changes, published on July 26, 2024, aim to streamline reporting, improve compliance and integrate hazardous waste export manifests into the electronic system.
With the final phase in effect as of January 22, 2025, businesses handling hazardous waste need to understand the key updates and their impact.
What is the final Third Rule?
The final Third Rule modifies the RCRA hazardous waste manifest system by refining reporting processes and reducing administrative burdens. The rule includes:
- Integration of hazardous waste export manifests into e-Manifest, shifting responsibility for submission to exporters
- Expanded international shipment data requirements to enhance tracking of transboundary hazardous waste movements
- New registration requirements for generators, ensuring Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) register for e-Manifest access
- Elimination of paper manifest mailings from receiving facilities to the EPA, further digitizing the process
- Mandatory corrections of manifest errors, ensuring real-time accuracy and compliance
Who is affected?
The updates impact hazardous waste generators, transporters and receiving facilities. Organizations that handle hazardous waste must ensure they are compliant with the new requirements to avoid penalties and streamline their waste tracking processes.
Key compliance deadlines
January 22, 2025
- LQGs and SQGs must register for e-Manifest access
- Mandatory corrections of manifest errors required within 30 days of an EPA or state request
- Exception and discrepancy reporting deadlines extended after shipment receipt
- The new four-part manifest will be available for use. The EPA has stated that the existing inventory of five-part manifests may still be used until December 1, 2025.
December 1, 2025
- Exception, discrepancy and unmanifested waste reports must be submitted through e-Manifest instead of to regulators directly.
- Export manifests must be submitted digitally by exporters.
- All five-part manifests must be replaced with four-part version for both domestic and international shipments.
Why does this matter?
Ensuring compliance with the final Third Rule is crucial for businesses handling hazardous waste. The updates simplify tracking, enhance data accuracy and help organizations avoid costly enforcement actions. By registering for e-Manifest and adopting these digital tools, companies can improve efficiency while ensuring environmental responsibility.
Stay compliant — Get ready for 2025
With deadlines approaching, businesses should take action now to register for e-Manifest, review their hazardous waste tracking processes and prepare for the transition to digital reporting.
Republic Services offers over 70 years of environmental solutions expertise to help customers navigate new regulations and ensure compliance.
For more information, visit republicservices.com.
