EPA Announces Fees Associated with New e-Manifest System



EPA is establishing a national system for tracking hazardous waste shipments electronically. This "e-Manifest" system will provide a long awaited modernization of the nation's hazardous waste tracking process. EPA anticipates launching the e-Manifest system in June 2018.

On January 3, 2018, rules associated with setting and revising fees to recover the full cost of the e-Manifest system were published in the Federal Register. EPA intends to recover costs associated with the development, operation, maintenance, and upgrades for the e-Manifest system. The regulation outlines who must pay the user fees, what transactions trigger fees, the fee formula, fee payment options, EPA's fee revision process, and implications for companies that fail to pay. The fees will vary depending on whether companies submit manifests electronically or via paper copies.

The final rule provides that only receiving facilities will have payment obligations and excludes generators, transporters and entities other than receiving facilities designated on manifest. Additionally, the rule defines the "billable event" as the submission of the final manifest copy signed by these receiving facilities. The final rule outlines instructions for facilities that wish to continue to use paper manifests providing that the preferred means of submission to the system by receiving facilities is a data file along with an image file of each manifest. Instructions for other scenarios including the process for manifest data correction, hazardous waste exports, return shipments of rejected hazardous waste, handling regulated facilities lacking EPA Identification Numbers, out of state shipments of non-RCRA wastes, as well as others are also outlined.

The rule provides the following table which outlines the initial fee structure for the various types of submittals on a per manifest basis. These fees are based on assumptions and should be viewed as rough approximations of the final fees. EPA will publish a final two-year schedule of user fees on the e-Manifest website when more information about the e-Manifest budget and contracts awards becomes available.

Year 1 Marginal Cost Manifest Fees by Manifest Type

Manifest Submission Type

Year 1 Fee

Paper Manifest TypesMailed Paper$20
Image Uploads$13
Data File Uploads$7
Electronic Manifests (includes hybrids)Electronic$4

If you have any questions about this new rule, or the e-Manifest system, please contact your local office at (800) 229-6655.