Paper Manifest Sunset Transition Register

PROBLEM: On March 5, 2026 the EPA published the proposed Paper Manifest Sunset Rule in the Federal Register, proposing a date — 24 months after publication of the final rule — after which paper manifests would no longer be accepted for hazardous-waste shipments. Despite the e-Manifest system launching in 2018, electronic manifests account for less than 1 percent of all manifests submitted. The e-Manifest Third Rule (finalized June 2024) already requires all large and small quantity generators to be registered in EPA's RCRAInfo portal (since January 22, 2025) and requires electronic exception, discrepancy and unmanifested-waste reports (since December 1, 2025). A two-year transition that moves 99 percent of manifests from paper to electronic has no shared register tracking who is ready and who is not.

SOLUTION: An IBM Cloud Ideas compliance improvement that maintains a paper-manifest sunset transition register: each generator, transporter and receiving facility is logged with its RCRAInfo registration status, its electronic-manifest readiness, its outstanding data-correction obligations, and its exception/discrepancy reporting status, with unregistered or paper-only parties flagged before the sunset date arrives.

EVIDENCE BASIS: DOCUMENTED — EPA proposed Paper Manifest Sunset Rule, published in the Federal Register March 5, 2026: sunset 24 months after the final rule; projected $26.4–28.5 million annual savings; comment period through May 4, 2026. DOCUMENTED — e-Manifest Third Rule (June 2024): LQG/SQG registration required from January 22, 2025; electronic exception/discrepancy/unmanifested-waste reports required from December 1, 2025. REPORTED — electronic manifests under 1 percent of all manifests submitted (Holland & Knight analysis of the proposal, JD Supra).