Authored by Angie Martin, PE, CHMM

EPA’s e-Manifest processing facility received over 1.5 million manifests from the launch of the system on June 30, 2018 through April 30, 2019. On an annualized basis, this number falls 880,000 manifests short of the projected number of manifests initially used to calculate EPA’s e-Manifest fees. The regulations require EPA to recalculate fees which are effective October 1, 2019 and every 2 years thereafter. EPA has increased fees for different types of manifest submissions from 60% to 115%. These fees are charged directly to the destination facilities. As such, Heritage is adjusting our e-Manifest fee to $25 per manifest, effective with shipments originating on October 1.

As noted below, EPA’s analysis indicated that a very low percentage of manifests have been submitted using fully electronic options (<0.3%).  This is due to a wide variety of factors (user registration, continuing software changes, technical restrictions, logistical challenges, etc.) and was the primary topic of the recent Advisory Board meeting.  EPA also has a backlog of approximately 100,000 paper manifests to process and about 270,000 data plus image manifests to process. 

At this time, Heritage submits manifests to EPA using the same two most widely used options indicated below (scanned image and data plus image). 

Manifest Submission Type Submitted (6/30/18 – 4/30/19) %
Mailed paper manifest 103,348 6.8%
Scanned image upload 272,627 18%
Data plus image 1,140,003 75%
Fully electronic 4,005 <0.3%

Source: EPA, “Hazardous Waste e-Manifest Advisory Board June 2019 Meeting Background Whitepaper.”


Heritage is committed to safely and compliantly transporting, managing, and disposing of our customers’ waste.  We will continue to follow the EPA’s progress on e-Manifest programming and implementation and to update our customers on the progress.  EPA will recalculate fees in 2021, effective October 2021.