Yes. EPA recently decided to grant extra time for receiving facilities to submit paper manifests during the initial months after system launch (scheduled for June 30, 2018). Under EPA’s regulations, receiving facilities must submit paper manifests to EPA within 30 days of receipt. However, EPA will allow receiving facilities to submit paper manifests they receive between June 30, 2018, and September 1, 2018, by September 30, 2018. This effectively provides receiving facilities up to 60 additional days, over the existing 30 days provided in the regulations, to submit paper manifests to EPA.

This does not change the requirement for receiving facilities to send manifests initiated on and after June 30, 2018, to EPA and for EPA to then charge a user fee for each manifest it receives. Rather, it simply extends the deadline for when paper manifests would be due to EPA. There are three ways for receiving facilities to submit a paper manifest: (1) through the U.S. mail; (2) upload of a scanned image of the manifest; and (3) sending a data file plus a scanned image of the manifest. Once the paper manifest is received by EPA, EPA will charge a user fee for each manifest based on how the manifest was submitted and the corresponding costs to EPA to process the data. EPA charges the highest user fee for paper manifests mailed to the Agency, a lower fee for uploads of scanned images, and a lower fee still for manifests submitted as data files plus scanned images.

(Receiving facilities, of course, can use electronic manifests/hybrid manifests, but as these manifests are signed electronically in EPA’s e-Manifest system and are submitted to the Agency instantaneously, the extra time to submit paper manifests is not applicable for these manifests. EPA charges the lowest user fee for electronic manifests.)

EPA believes that this additional time will allow receiving facilities to complete any steps necessary to modify their software systems and integrate them with e-Manifest so that they are in a better position to take advantage of the lower user fees for paper manifests submitted as “data plus image” uploads. Thus, this flexibility reduces costs to industry as well as reduces processing burden for EPA and sets up an important framework for entities to expedite their transition to fully electronic manifesting.

EPA encourages receiving facilities to submit paper manifests as soon as possible, rather than waiting until September 30, 2018. This will help both the receiving facility and EPA best manage, process, and bill for any manifests accumulated during this period.

Beginning on September 1, 2018, receiving facilities must submit all paper manifests to EPA within 30 days of receipt by the receiving facility, as required by the regulations.