Waste_Content Page_Hazardous waste manifest requirements

Hazardous waste manifest requirements

As of Jan. 22, 2025, all small and large quantity generators are required to register for e-Manifest through RCRAInfo. For more information, refer to the RCRAInfo e-Manifest user registration webpage.

The uniform hazardous waste manifest is the form required for all generators who transport, or offer for transport, hazardous waste for off-site treatment, recycling, storage or disposal. The manifest can be fully electronic or completed on a paper form. The data from both electronic and paper forms is stored in the federal e-Manifest system. Detailed information on the manifest system and its requirements can be found in:

What Shipments Require A Manifest

Uniform hazardous waste manifests are required when shipping the following wastes:

  • regulated hazardous waste (state and federal);
  • Toxic Substances Control Act-regulated polychlorinated biphenyls (PCBs);
  • exported or imported hazardous waste;
  • waste shipments transported as hazardous that are tested at arrival, regardless of outcome; or
  • waste generated from a generator's episodic event.

The Federal e-Manifest System

The U.S. Environmental Protection Agency (EPA) established a national system, called "e-Manifest," to track hazardous waste shipments electronically and to ultimately establish a paper-free process for tracking these shipments. The e-Manifest system is housed within the RCRAInfo electronic database and can produce forms, reports and procedures to track hazardous waste from the time it leaves the generator (facility where it was produced) until it reaches the offsite waste management facility that will store, treat or dispose of the hazardous waste. The system allows the waste generator to verify that the waste has been properly delivered and maintains these records to meet state and federal recordkeeping requirements.

Generator e-Manifest Requirements

Register To Use e-Manifest

All small and large quantity generators are required to obtain and maintain a RCRAInfo Industry Application account to access final manifests or make required corrections. To satisfy this requirement, a facility must have at least one registered RCRAInfo user who has the permission level of site manager or e-Manifest Certifier. For more information on creating an account and obtaining or changing permissions, visit the Wisconsin Hazardous Waste Annual Report webpage.

  • The DNR recommends that facilities register two site managers per facility. This will avoid a lag in access to the system should personnel change over time.
  • Site managers may assign user roles to additional company personnel based on whether they will need to review, create and/or sign manifests electronically.

Very small quantity generator facilities may choose to register a RCRAInfo user. To do this, the facility must have or obtain an EPA ID number. For more information, view the Notification of Hazardous Waste Activities webpage.

A facility can meet the manifest recordkeeping requirements of s. NR 662.040, Wis. Adm. Code, by maintaining active registered users who can access final manifests during information requests or inspections.

Manifest Corrections

Many e-Manifest errors are a result of paper manifest data being entered incorrectly into the e-Manifest system, often due to illegible paper manifests. The DNR encourages the adoption of fully electronic manifests to reduce the burden of correction requests and improve the quality of information in the federal system.

Generators are responsible for ensuring the accuracy of the data on a manifest and the data submitted to e-Manifest.

  • Waste handlers are required to make corrections to manifests within 30 days of regulators requesting corrections.
  • If a generator discovers an error, they may either make the correction or request that the transporter or receiving facility make the correction, depending on the type of error.

The party responsible for making a correction in e-Manifest depends on which field of the manifest must be revised. For a comprehensive explanation of how to make corrections and which party is responsible, view the Requirement to Correct Errors in Manifest Data Submitted to EPA webpage.

Exception Reports

As of Dec. 1, 2025, a generator must submit an exception report in the e-Manifest module of RCRAInfo. Submitting an exception report to e-Manifest satisfies the requirement to notify the DNR; an additional copy of the report does not need to be mailed or emailed.

  • The designated facility must submit a signed or electronically certified final copy of the manifest to the e-Manifest system within 30 days of the date the waste was received.
  • If a small quantity generator or large quantity generator has not received a signed/certified copy of the manifest from the designated facility within 60 days of the date the waste was accepted by the first transporter, they must file an exception report.
  • When the designated facility rejects a shipment of non-empty containers and forwards them to an alternate facility for management, the generator must submit an exception report (within 60 days of the date the waste was accepted by the first transporter of the new manifest).

To submit an exception report, the facility must have an RCRAInfo account user with the permission level of e-Manifest certifier or site manager. Navigate to the e-Manifest module and click on "Other Actions," then select "Create/Manage Reports."

Transporter e-Manifest Requirements

Transporters are encouraged to obtain an RCRAInfo Industry Application account to be able to initiate, electronically sign and correct manifests in the e-Manifest system.

The manifest creation options listed below are utilized based on the transporter, generator and disposal facility preferences and electronic capabilities.

Paper: the generator, transporter(s) and receiving facility sign a paper manifest.

Hybrid: a paper manifest that is signed by the generator and then is signed electronically by all transporters and the receiving facility.

Electronic: a fully electronic manifest signed electronically by the generator, transporter(s) and receiving facility.

TSD/Receiving Facility e-Manifest Requirements

Submitting Final Manifest To e-Manifest System

Once the manifest is received by the licensed or permitted treatment, storage or disposal facility (receiving facility), the facility has 30 days to submit the completed manifest to the e-Manifest system.

  • There is a processing fee for each manifest submitted by a receiving facility, which varies depending on how it was submitted; a fully electronic manifest is the least expensive manifest to upload.
  • This approach to fees was intended by the EPA to support the transition to a fully electronic manifest system, to ultimately reduce costs incurred by all parties.

For all manifest fees and payment information, review the e-Manifest user fees and payment information.

Providing Final Copy To Generator

Because small quantity and large quantity generators are required to have a registered user of e-Manifest, the receiving facility is no longer required to mail the final manifest to these customers because they can retrieve the final manifest in RCRAInfo. However, this does not prohibit receiving facilities from also sending a final copy of the manifest to the generator.

Very small quantity generators and PCB generators that are required or who elect to manifest their waste do not need to have a registered e-Manifest system account user, though they may choose to register. If there is no registered e-Manifest user, the receiving facility must mail the final copy to the generator.

Manifests From VSQGs

The following waste shipment scenarios require the very small quantity generator (VSQG) manifests to be submitted to the e-Manifest system when:

  • The origin state or destination state requires the use of a manifest.
  • A manifest is elected to be used by the very small quantity generator, transporter or receiving facility.
  • The waste is from the generator's episodic event (requires manifest).
  • The waste volume results in a change in generator category to small quantity generator or large quantity generator status.
  • The waste contains TSCA-regulated PCBs.
  • The generator or receiving facility is required to use a manifest due to enforcement agreements.

If a Wisconsin very small quantity generator chooses to use a manifest or elects to work with a transporter or receiving facility that chooses to use manifest, then that VSQG must obtain an EPA ID number.

The receiving facility must submit the final manifest to the e-Manifest system. If the very small quantity generator does not have a registered e-Manifest user, the receiving facility must mail or email a final copy of the manifest to the generator.

Manifest Corrections

The receiving facility accepting manifested wastes is responsible for making corrections to e-Manifest data when errors are identified or when the facility is requested to make changes by the state or EPA. For a comprehensive explanation of how to make corrections and which party is responsible, review the requirement to correct errors in manifest data submitted to the EPA.

Discrepancy Reporting

A discrepancy report is submitted when a hazardous waste receiving facility, or a treatment, storage and disposal facility, determines any of the following:

  • A significant difference is noted between the type or quantity of waste received and the information listed on the manifest.
  • A waste shipment rejection occurs for either a full or partial shipment of hazardous waste.
  • There are container residues that exceed the quantity limits for RCRA-empty containers.

Upon discovering a waste discrepancy, the facility must attempt to reconcile the discrepancy with the waste generator or transporter. If the discrepancy is not resolved within 20 days after receiving the waste, the facility is required to immediately submit a discrepancy report.

  • As of Dec. 1, 2025, a TSDF/receiving facility must submit discrepancy reports in the e-Manifest module of RCRAInfo. The report should include a copy of the manifest in question and the attempts to reconcile the discrepancy.
  • Discrepancy reporting is a federal requirement found in 40 CFR 264.72 and 40 CFR 265.72. Submitting a discrepancy report to e-Manifest satisfies the requirement to notify DNR; an additional copy of the report does not need to be mailed or emailed.

To submit a discrepancy report, the facility must have an RCRAInfo user account with the permission level of e-Manifest certifier or site manager. Navigate to the e-Manifest module and click on "Other Actions," then select "Create/Manage Reports." In the drop-down list "View" in the upper right-hand corner, select "Discrepancy Report."

Unmanifested Waste Reporting

If a receiving facility accepts waste from off-site, such as from a large quantity generator or small quantity generator, without a required manifest, an unmanifested waste report must be prepared in accordance with the federal regulations found in 40 CFR 264.76 and 40 CFR 265.76.

The unmanifested waste report must be submitted by the facility into the e-Manifest module of RCRAInfo within 15 days of receiving the waste. The report must include the following information:

  • The EPA identification number, name and address of the TSDF/receiving facility.
  • The date the TSDF/receiving facility received the waste.
  • The EPA identification number, name and address of the generator and the transporter.
  • A description and the quantity of each unmanifested hazardous waste the facility received.
  • The method of treatment, storage or disposal for each hazardous waste.
  • The certification signed by the owner or operator of the TSDF or an authorized representative.
  • A brief explanation of why the waste was unmanifested.

Submitting an unmanifested waste report into e-Manifest satisfies the requirement to notify DNR; an additional copy of the report does not need to be mailed or emailed.

To submit an unmanifested waste report, the facility must have an RCRAInfo user account with the permission level of e-Manifest certifier or site manager. Navigate to the e-Manifest module and click on "Other Actions" and then select "Create/Manage Reports." In the drop-down list "View" in the upper right-hand corner, select "Unmanifested Waste Report."

Exporter e-Manifest Requirements

As of Dec. 1, 2025, exporters of hazardous waste to facilities outside of the United States must upload the uniform hazardous waste manifest into the e-Manifest system.

The exporter is the entity responsible for submitting the manifest and paying the requisite fee. If you are a Wisconsin exporter with an Authorization of Consent letter from EPA but are unable to upload an export manifest, please contact your regional licensing, reporting and compliance specialist.

Additional Resources

For RCRAInfo user access and permissions, contact your regional licensing, reporting and compliance specialist.

e-Manifest Helpdesk for Industry Users
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Call toll-free: 833-501-6826 or direct: 970-494-5508
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