Hazardous Waste Exception Reports Now Require Electronic Submission — Here’s What Changed
One of our consultants discovered this change while updating our HMBP template earlier this year: starting December 1, 2025, the EPA no longer accepts mailed paper exception reports. Large quantity generators and small quantity generators alike must now submit exception reports through the RCRAInfo e-Manifest system.
If you’ve never had to file an exception report, you might not think this affects you. But exception reports are triggered by something that happens to almost every generator eventually — a late manifest. Here’s what you need to know.
What Triggers an Exception Report?
When you ship hazardous waste to a TSDF (treatment, storage, and disposal facility), the TSDF is required to return a signed copy of the manifest confirming receipt. For LQGs, if that signed manifest doesn’t come back within 45 days of the shipment date, the generator must:
- Contact the transporter and/or the TSDF to determine the status of the waste
- Document those follow-up efforts in writing (email works well)
If the signed manifest still hasn’t been received within 60 days of the original shipment, the generator must file an exception report. It is important to note that this 60-day timeframe applies to both LQGs and SQGs.
Two things generators often get wrong:
- The 45-day clock starts from the date the waste was shipped, not the date the manifest was created
- Even if the signed manifest arrives on day 46, you are still required to file the exception report. The 45-day trigger is absolute.
We recommend beginning follow-up efforts at 30 to 35 days — well before the regulatory deadline — so you have time to track down the issue before the clock runs out.
What Changed in December 2025
The federal regulation at 40 CFR 262.42(a)(3) now requires that exception reports be submitted through the EPA e-Manifest system in RCRAInfo. Paper submissions mailed to the DTSC PO Box are no longer accepted.
This applies to both large quantity generators (262.42(a)(3)) and small quantity generators (262.42(b)(2)).
California regulation still references the old mailing address in some places, but the federal rule — which California has adopted — now mandates electronic submission. The DTSC’s current guidance aligns with this change.
Practical Steps for Generators
- Confirm yourRCRAInfoaccess. If your facility has been relying on a consultant or third party to manage RCRAInfo, make sure the login credentials are current and the right people have access. If you have had account issues in the past — we’ve seen facilities get locked out because of login.gov changes — sort that out now, not when you’re on a 60-day clock.
- Set up a manifest tracking system.Track every shipment date and flag any manifest thathas not been returned signed within 30 days. This gives you a buffer before the regulatory timeline kicks in. A simple spreadsheet works. A calendar reminder works. Whatever system you’ll actually use consistently.
- Document your follow-up in writing.If you reach the point where you need to contact the transporter or TSDF, do it by email. Phone calls are fine for gettinganswers, but follow up with a written summary. That documentation becomes part of the exception report if you have to file one.
- Don’t assume the TSDF will handle it.The responsibility for filing anexception report rests with the generator — not the hauler, not the TSDF. Even if the delay is entirely on the TSDF’s end, the regulatory obligation is yours.
Update Your HMBP
Your contingency plan and emergency response procedures — part of your Hazardous Materials Business Plan — should reference the exception reporting requirement. As you update your HMBP this year, confirm that the exception report section reflects the new RCRAInfo submission process rather than the old mailing instructions.
How CDMS Can Help
CDMS manages hazardous waste compliance for facilities across California, including manifest tracking, exception report preparation, and RCRAInfo submissions. We can set up a tracking system for your facility and handle the process if an exception report is triggered.
Need Help Setting Up Manifest Tracking?
If you don’t have a system for tracking manifest return dates, let’s get one in place before the next shipment goes out.
Request Your Free Assessment or reach out to service@cdms.com.
CDMS provides comprehensive environmental compliance management to manufacturing and industrial facilities across California. Our hazardous waste management services include manifest tracking, exception reporting, biennial reporting, and RCRAInfo submittals.
