_A contractor that prepares manifests for its generator clients is a broker in EPA e-Manifest. What a broker can and cannot do, and the flow._ # You already prepare the manifest. EPA has a name for that. A contractor running a collection event or a lab pack prepares the manifest and arranges the shipment for the municipality or lab that generates the waste. In EPA e-Manifest that is a broker — a handler type with its own EPA ID. The client signs as generator; the contractor prepares, and signs as transporter. - **Generator** (Your client) — Signs for the waste — Box 15 — in ink on a hybrid printout or electronically through its own RCRAInfo user. Holds its own key; Mercovi never does. - **Transporter and broker** (You) — Prepares the manifest under the broker ID and signs for the haul — Box 17 — with the transporter key. - **Designated facility** (The TSDF) — Receives and certifies — Box 20 — with its own key. Pays the e-Manifest fee. ## The broker flow. ### You prepare under the broker ID. With a Site Manager key on the broker site, the contractor saves the manifest naming the client as generator, its own trucks as transporter and the designated facility. It is Pending and visible on the client's own EPA dashboard before anyone signs. _Screen: a manifest record — parties with EPA IDs, lines with codes and approvals, signatures, and the EPA e-Manifest status on the record._ ### The client signs as generator. Electronically through EPA's sign link if its site can e-sign, or in ink on the printed EPA form for a hybrid manifest. The paper is the client's record. A broker cannot sign for the generator. _Screen: the client portal — every manifest from every event, searchable, with its tracking number._ ### You sign as transporter. With the transporter key, as the load leaves. The signatures sit on the record in order: generator, transporter, facility. _Screen: a manifest record — parties with EPA IDs, lines with codes and approvals, signatures, and the EPA e-Manifest status on the record._ ### The facility receives and certifies. Checked in against the manifest at the dock, signed as the designated facility, certified. The signed manifest and its tracking number come back to the record. _Screen: an outbound shipment — containers aboard, the manifest with the facility as offeror and its e-Manifest status on the record, and the certificate of disposal landed on every source generator's record._ ## What a broker can and cannot do. ### A broker can - **Hold its own EPA ID.** Filed on Form 8700-12 with site type Broker, in most states through myRCRAid, then registered in e-Manifest like any site. - **Prepare, update and correct any manifest naming it.** With a Site Manager key on the broker site; no permission on the generator's site is needed to prepare. - **Make the manifest visible to everyone on it.** A saved manifest is Pending on the generator's, the transporters' and the facility's dashboards. - **Be the named Item 14 party.** Under the proposed Paper Manifest Sunset Rule the generator names the broker in Item 14 as the party that prepared or arranged the shipment — proposed, not final. ### A broker cannot - **Sign for the generator.** EPA: brokers cannot sign manifests on behalf of their generator clients. The generator signs for itself. - **Create image-only manifests.** - **Pay or be billed the fee.** The e-Manifest fee stays with the receiving facility. - **Hold the client's credential.** Generator signing from inside the contractor's software is possible only if the client adds the contractor's signer to its own RCRAInfo site — a per-client choice with the client's written agreement. ## The two credentials. A contractor-as-broker holds keys for its broker site and its transporter site, and nothing for the generator. ### Broker site key Prepares, updates and corrects every manifest the contractor arranges, across all its clients. ### Transporter site key Signs for the haul. Covers the contractor's own registered transporter site. ### Generator key Held by the client, never by Mercovi. The client signs in ink or through its own user. > Mercovi coordinates a chain of credentials. It never holds one for you. Mercovi's manifest record names the generator, each transporter in order, the designated facility and the broker, with EPA IDs, and carries the manifest's status, submission method and tracking number. The client sees its manifests in the portal. ## Asked about brokers. ### Is a hazardous waste contractor a broker? In [EPA e-Manifest](/e-manifest), yes, when it prepares the manifest and arranges the shipment for a generator client. It registers a Broker site with its own EPA ID and appears on the manifest as the broker handler, alongside its transporter role. ### Can a broker sign the manifest for its client? No. The generator signs — electronically through its own RCRAInfo user, or in ink on a hybrid manifest. The broker prepares; the transporter and the facility sign their own boxes with their own credentials. The one exception is a client that chooses, in writing, to add the contractor's signer to its own RCRAInfo site. ### Who pays the e-Manifest fee on a brokered manifest? The receiving facility, as on every manifest. A broker is neither charged nor billed, and neither is the generator or the transporter, so preparing your clients' [manifests](/platform/manifests) under your own broker ID adds no EPA fee to the shipment. The fee is set by EPA's schedule and depends on the submission type — see [how e-Manifest works](/e-manifest). ## See it run a job end to end. Tell us what you run — events, plant pickups, lab packs, a floor — and we'll show you the screens that matter to you. [Book a demo](/demo)