EPA Announces New Electronic Manifest User Fees

On June 30, EPA announced the upcoming User Fees for fiscal years 2022 and 2023 (October 1, 2021 through September 30, 2023) for the e-Manifest system. EPA encourages the hazardous waste industry to adopt fully electronic manifesting as soon as possible so that industry members can take maximum advantage of the benefits and cost savings of electronic manifesting. However, EPA acknowledges that it will take time for industry to fully transition to electronic manifests.

The table below lists the user fees for fiscal years 2022 and 2023 (October 1, 2021, through September 30, 2023) for the e-Manifest system.

These user fees are set based on the manifest usage and processing costs for each manifest type. As of June 30, 2021, EPA no longer accepts mailed paper manifest. Instead receiving facilities must submit paper manifests as either a scanned image upload or data plus image upload.

EPA charges user fees to receiving facilities for each manifest submitted. The amount of the user fee is based on how the receiving facilities submit the manifest to EPA (e.g., electronic or paper). EPA does not charge generators, transporters, or brokers for user fees, but receiving facilities do charge customers for user fees.

For example, 75 percent of all e-Manifest program costs are borne by processing paper manifests. The best way to reduce user fees in the future will be to accelerate use of electronic manifests. EPA is undertaking several efforts to do this, such as reducing the burden for user registration and electronic signatures for generators and transporters.

More information on the E-manifest system is available on the EPA website at https://www.epa.gov/e-manifest.  If you have any questions or would like additional information, please contact Jeff Hannapel with NASF at jhannapel@thepolicygroup.com.

This update is courtesy of the National Association for Surface Finishing (NASF). For more information or to become a member, visit nasf.org.