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The Cost Impacts of e-Manifests

 

On December 20, 2017 the EPA signed the e-Manifest User Fees final rule. The rule authorizes the EPA to collect fees from users of the hazardous waste manifest to recover the full cost of developing and operating the e-manifest system. 

Electronic hazardous wastes manifests (e-manifests) will be accepted by EPA beginning on June 30, 2018. According to the rule, hazardous waste treatment, storage, and disposal facilities (TSDFs) and other facilities that receive manifested wastes will be charged fees for their manifest activity each month. Hazardous waste generators can expect these fees to be passed along by TSDFs as part of their service agreement.

While paper manifests will still be allowed after this date, switching to e-manifests offers significant financial incentive. For a paper manifest, the receiving facility will also be required to submit a data image file, at an estimated $40 per manifest fee. This is compared to an estimated $4 fee for submission of an e-manifest. Hybrid manifests, which allow generators to sign and retain a paper copy while the transporter and subsequent handlers only access the electronic version of the manifest, would also have the estimated $4 fee.

To encourage the transition to a fully electronic system, the EPA has plans to further increase fees for paper manifest if electronic manifest use does not reach 75% in four years. After three years of e-manifest operations, the Agency plans a full phaseout of paper manifests.

States with authorized hazardous waste programs will have to revise their programs to adopt or reference the e-manifest fee system. Currently the fees only apply to domestic hazardous waste manifests. The EPA says it will address electronic export manifests in a separate notice at a future date.

A copy of the pre-publication final rule can be found here.

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