The Final Countdown: EPA’s Third Rule and the Future of E-Manifest

Are you ready for the final level-up in hazardous waste tracking? As of January 22, 2025, the Environmental Protection Agency’s (EPA) new rule, aka the “Third Rule,” will officially launch, completing the e-Manifest system’s epic journey toward a fully digital future. This final rule isn’t just another regulatory update; it’s a game-changer set to make hazardous waste tracking smoother, smarter, and more sustainable. If your company handles, exports, or tracks hazardous waste, here’s what you need to know to stay ahead of the curve.

What’s the Third Rule All About? In a nutshell, the Third Rule updates e-Manifest regulations under the Resource Conservation and Recovery Act (RCRA) to enhance the tracking of hazardous waste shipments across the United States. Since its debut in 2018, e-Manifest has been helping waste generators and handlers keep tabs on shipments electronically. The Third Rule takes things up a notch, tightening up processes for export manifests, integrating reports, and aligning polychlorinated biphenyls (PCBs) requirements. For anyone shipping waste outside the U.S., this is a big deal.

So, let’s break down the biggest updates and why you should be excited.

  1. Export Manifests? Now in e-Manifest, No Paper Required! If you’re shipping hazardous waste internationally, here’s a major upgrade: all export manifests now go straight to e-Manifest, and the exporter pays the user fee directly—no paper trail required. That’s right, paper-based processes for exports are out, and electronic tracking is in. This means that around 22,000 additional export manifests will flow into the e-Manifest every year. Exporting companies can skip the hassle of mailing manifests and say goodbye to lagging data; everything’s digital, accurate, and real-time.
  2. More Data for International Shipments = Better Tracking. The EPA has added extra data fields for international shipments, making the e-Manifest system even more robust. This helps to ensure every detail about your hazardous waste is recorded accurately, keeping you compliant and giving regulators a complete picture of where the waste is going and what’s in it. Think of it as a smart tracking upgrade for your hazardous cargo.
  3. Movement Document Makeover. The new rule tightens up the connection between e-Manifest data and the Waste Import Export Tracking System (WIETS), making international shipments easier to track in RCRAInfo. It’s like adding a GPS to your waste manifest—linking data from start to finish to keep it all in one view. With this integration, tracking cross-border movements is about to get a whole lot smoother.
  4. One-Stop Manifest Reporting. If Exception Reports, Discrepancy Reports, and Unmanifested Waste Reports have cluttered your desk, here’s good news. The Third Rule rolls these all into e-Manifest, streamlining your process by consolidating them into a single platform. Fewer systems mean more clarity. e-Manifest will be your go-to for all things hazardous waste tracking.
  5. Mandatory e-Manifest Access for Generators. As of January 2025, small and large quantity generators must register in e-Manifest to receive final signed copies. That’s right—paper copies are no longer an option! With this mandatory registration, generators get fast, direct access to digital manifests, making recordkeeping easier and more secure. Plus, you’ll always have the latest version of your documents right at your fingertips.
  6. PCB Manifesting Goes Digital. Handling PCBs? The Third Rule syncs up Toxic Substances Control Act (TSCA) requirements with RCRA’s hazardous waste tracking in e-Manifest, unifying all your tracking needs under one roof. So, now PCB manifests work like any other hazardous waste manifest, streamlining the process and reducing compliance headaches.
  7. And Finally, Some Techy Tune-Ups. With a round of miscellaneous corrections, the Third Rule also cleans up the system: obsolete requirements are gone, typos are corrected, and new definitions are in place. It’s like a digital deep clean to keep e-Manifest accurate, current, and user-friendly.

Why Should You Care?

Not only does the Third Rule simplify the regulatory landscape, but it also cuts down on paperwork, improves data transparency, and ultimately makes compliance easier. This isn’t just an administrative upgrade; it’s a boost to sustainability, accountability, and efficiency. Here’s how:

  • Increased Visibility: With e-Manifest covering every export manifest and bringing movement documents into the fold, it’s now easier than ever to track where hazardous waste is going, making it simpler to comply with regulations.
  • Smooth Operations: By integrating reporting, simplifying PCB tracking, and reducing the need for physical paper, the new rule frees up time for waste handlers to focus on what matters most—safe and sustainable waste management.
  • Better for the Environment: The Third Rule ensures all data is centralized and accessible, which helps EPA enforce regulations more effectively and protects the environment by making hazardous waste handling more transparent.

Ready for January 22, 2025?

With the Third Rule, e-Manifest is set to transform hazardous waste tracking once again. Make sure your team is ready by familiarizing everyone with the expanded data fields for exports, registering for e-Manifest, and updating any systems to handle new reporting requirements. This way, you’ll hit the ground running when the new rule kicks in, keeping your company compliant and moving forward with confidence.

The Third Rule isn’t just about regulation—it’s a step toward a more connected, transparent, and efficient hazardous waste industry. Are you ready to lead the charge?

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