_What EPA e-Manifest is, who signs what, hybrid versus fully electronic, the manifest lifecycle, what a broker may do, and where Mercovi sits in the chain._ # How EPA e-Manifest works, and where Mercovi sits in it. Every hazardous waste manifest is on its way to living in EPA's system. Here is who does what on it, which kind of manifest you are actually filing, and what Mercovi records. ### What e-Manifest is It is the part of EPA's RCRAInfo that holds the Uniform Hazardous Waste Manifest electronically. Form 8700-22, created, signed, tracked and corrected in RCRAInfo, where each manifest receives its manifest tracking number. Every manifest required for a shipment eventually exists there: federal RCRA waste, state-regulated waste where a state requires a manifest, VSQG waste where a state requires it, PCB waste, imports and exports. Access is a browser at rcrainfo.epa.gov, or the API. > Source: [EPA — Frequent questions about e-Manifest](https://www.epa.gov/e-manifest/frequent-questions-about-e-manifest). ## Who is who on the manifest. The generator signs for the waste, the transporter signs for the haul, the facility signs on receipt, and a broker prepares it for someone else. Each party acts only through its own credential; nobody holds everyone's. ### Generator - **Role on the manifest** The client — the municipality, lab or plant that generates the waste. - **Signs as** Box 15: in ink on a hybrid printout, or electronically through its own RCRAInfo user. - **Holds the key for** Its own generator site. Mercovi never holds it unless the client explicitly adds the contractor's signer. ### Transporter and broker - **Role on the manifest** The contractor: hauls the load and, as broker, prepares the manifest for the client. - **Signs as** Box 17 as transporter. A broker never signs for the generator. - **Holds the key for** Its transporter site and its broker site. ### Designated facility - **Role on the manifest** The TSDF, recycler or transfer facility that receives the waste. - **Signs as** Box 20 on receipt; final certification in RCRAInfo. - **Holds the key for** Its TSDF site. Pays the e-Manifest fee. ## Hybrid or fully electronic. Most HHW clients sign on paper; the rest of the manifest is still electronic. ### Fully electronic The generator's site is registered with a certifier holding an Electronic Signature Agreement; generator, transporter and facility all sign electronically. ### Hybrid The generator may be unregistered and signs the printed copy in ink; the generator keeps that paper as its record. Transporter and facility sign electronically. This is the default for HHW. ### Data and image A paper form whose data the facility keys in and whose scan it uploads. ### Image only A scan only. Brokers cannot create it. ## The manifest's life. Saved, scheduled, on the road, waiting at the facility, signed. EPA owns the status; Mercovi mirrors it. Draft (no MTN yet, editable) → Pending (saved, incomplete) → Scheduled (complete, awaiting shipment) → In transit (generator and transporter signed) → Ready for signature (at the facility) → Signed (facility certified) → Corrected (post-signature versions) _Screen: a manifest record — parties with EPA IDs, lines with codes and approvals, signatures, and the EPA e-Manifest status on the record._ ## Where it sits in a Mercovi job. The manifest starts as the site's template, becomes the job's manifest, and carries its EPA e-Manifest status, submission method and tracking number on the record. ### Prepare The site's manifest template becomes the job's manifest. Its document type is computed from the waste codes: a RCRA code makes it a Uniform Hazardous Waste Manifest; a non-hazardous document never touches EPA. _Screen: a manifest record — parties with EPA IDs, lines with codes and approvals, signatures, and the EPA e-Manifest status on the record._ ### Job day The crew's counts become the lines. Hybrid for HHW: the generator signs the printed form; fully electronic when the client's generator site can e-sign. ### Hand-off The transporter signs for the load as it leaves; the manifest goes in transit. ### At the facility Checked in against the manifest at the dock — what the paper says against what came off the truck — then signed on receipt. _Screen: check-in at the dock — manifested versus received counts, scale weights, locations, and a discrepancy recorded at the dock._ ### After The signed manifest and its tracking number sit on the job; the post-op's disposal lines come from the manifest lines; the certificate of disposal lands on every source generator's 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._ ### The portal The client sees its manifests with their tracking numbers in its own login. ## The broker flow. A contractor that prepares the manifest for its client is a broker in e-Manifest. You prepare (under the broker ID; Pending on the client's dashboard) → Client signs (as generator — ink or its own user) → You sign (as transporter) → Facility certifies (signed; tracking number on the record) [Read the broker module](/broker) ## Remote signing, and the fee. ### Remote signing A registered signer at the same company may execute the electronic signature for the crew member who has first-hand knowledge of the shipment; both names appear on the manifest. EPA's Remote Signer policy covers the generator's, transporter's and facility's receipt signatures; the facility's final certification still needs its own signature in RCRAInfo. The policy sets a deadline for executing the signature after the waste is received or before hand-off. > Source: [EPA — Remote Signer memorandum](https://rcrapublic.epa.gov/files/14956.pdf). ### The fee The receiving facility pays it; nobody else is billed. No fee for post-receipt corrections. > Source: [EPA — e-Manifest user fees](https://www.epa.gov/e-manifest/e-manifest-user-fees-and-payment-information). ## The timeline. Paper is on its way out. ### e-Manifest launches (June 2018) EPA's electronic manifest system goes live for every manifested shipment. > Source: [EPA — e-Manifest](https://www.epa.gov/e-manifest). ### The Third Rule (effective January 2025) Large and small quantity generators must register. Exception, discrepancy and export reports move into e-Manifest. > Source: [Federal Register, 2024-07-26](https://www.federalregister.gov/documents/2024/07/26/2024-14694/integrating-e-manifest-with-hazardous-waste-exports-and-other-manifest-related-reports-pcb-manifest). ### Paper Manifest Sunset Rule (proposed March 2026) Paper manifests would end a set period after a final rule; hybrid manifests continue; the image-based types are eliminated; transporter registration becomes mandatory; the broker is named in Item 14. Nothing is final yet. > Source: [Federal Register, 2026-03-05](https://www.federalregister.gov/documents/2026/03/05/2026-04366/paper-manifest-sunset-rule-modification-of-the-hazardous-waste-manifest-regulations). ## Asked about e-Manifest. ### What is EPA e-Manifest? The module of EPA's RCRAInfo that holds the [Uniform Hazardous Waste Manifest](/glossary#uniform-hazardous-waste-manifest) electronically, where a manifest is created, signed, tracked and corrected and receives its [manifest tracking number](/glossary#mtn). Every manifest required for a shipment eventually exists there, whether it was signed fully electronically or as a hybrid with the generator's signature in ink. ### What is a hybrid manifest? An electronic manifest on which the generator signs the printed copy in ink while the transporter and facility sign electronically. The generator need not be registered in RCRAInfo, which is why it is the default for [HHW programs](/hhw): a county or a school district signs the paper at the site, and the rest of the chain is electronic. ### Can a broker sign a manifest for a generator? No. A broker prepares and arranges the shipment under its own EPA ID; the generator signs for itself, in ink on a hybrid manifest or through its own RCRAInfo user. EPA states that brokers cannot sign on behalf of their generator clients. Mercovi coordinates the chain of credentials and never holds the client's — see [the broker module](/broker). ### Who pays the e-Manifest fee? The receiving facility, per manifest. Brokers, transporters and generators are not billed, and there is no fee for a correction made after receipt. A contractor preparing its clients' manifests as a broker therefore adds no EPA fee to the chain; the amount depends on the submission type and is set by EPA's fee schedule. ### When does paper end? EPA proposed the Paper Manifest Sunset Rule in March 2026; paper would end a set period after a final rule, and hybrid manifests would continue. Nothing is final yet. Until it is, a generator may still sign in ink on a hybrid manifest, which is why the [compliance page](/compliance#emanifest) describes the hybrid path as the default rather than the exception. Questions about any of the above are the best demo we can give you. [Book one](/demo).