How to Fill Out EPA Form 8700-22 (w/Examples) + FAQs

You fill out EPA Form 8700-22 by entering your generator ID, transporter info, designated facility info, waste descriptions, container counts, weights, and hazardous waste codes, then signing the certification before the waste leaves your site. The form, called the Uniform Hazardous Waste Manifest, is the federal cradle-to-grave tracking document required under the Resource Conservation and Recovery Act (RCRA) for nearly every shipment of hazardous waste in the United States.

Mistakes on this form trigger civil penalties up to $93,058 per day per violation under EPA’s 2026 inflation-adjusted schedule, and willful violations can lead to criminal prosecution under RCRA Section 3008(d). The EPA’s e-Manifest System processed over 7.5 million manifests in fiscal year 2025, and roughly 38% are still submitted on paper, where error rates run three times higher than electronic submissions.

Here is what you will learn in this guide:

• 📋 How to complete every single box on Form 8700-22, line by line, with no guesswork
• ⚖️ The exact federal rules under 40 CFR 262 Subpart B and what each one means for your shipment
• 🧪 Three real-world filer examples covering SQGs, LQGs, and VSQGs in different industries
• 🚫 The most common mistakes generators, transporters, and TSDFs make and how to avoid each
• 💻 How the e-Manifest system works, the 2026 user fees, and when paper is still allowed

What EPA Form 8700-22 Actually Is

EPA Form 8700-22 is the Uniform Hazardous Waste Manifest, a federally standardized shipping document that tracks hazardous waste from the point of generation through transportation to its final treatment, storage, or disposal facility. The form was created under the authority of RCRA Subtitle C and is mandated by 40 CFR 262.20 for all generators of hazardous waste who ship that waste off-site for management.

The manifest is the single most important paperwork link in the cradle-to-grave system, and it serves several purposes at once. It identifies the parties involved, describes the waste in DOT hazmat terms, lists the EPA hazardous waste codes, and creates a chain of custody with signatures at every transfer point. Without a properly completed manifest, the shipment is illegal, and any party that knowingly transports unmanifested waste can face up to two years in prison under 42 U.S.C. § 6928(d)(5).

The form comes in two flavors: the paper version, which uses a six-copy carbonless set, and the electronic version submitted through the EPA e-Manifest portal. Both versions ask for the same information, but the electronic version validates entries in real time and reduces the most common data-entry errors. Paper manifests must still be ordered from an EPA-registered printer, because the form uses a unique pre-printed Manifest Tracking Number that no one is allowed to duplicate.

Who Must Use the Form

Three categories of hazardous waste generators must use Form 8700-22 when shipping waste off-site, and each category has its own rules. Large Quantity Generators (LQGs) produce 1,000 kilograms or more of hazardous waste per month, Small Quantity Generators (SQGs) produce between 100 and 1,000 kilograms per month, and Very Small Quantity Generators (VSQGs) produce less than 100 kilograms per month under the federal Generator Improvements Rule.

VSQGs are usually exempt from the manifest requirement when shipping to a state-approved facility, but the moment a VSQG ships to a permitted TSDF, most receivers will still require a manifest as a matter of policy. The consequence of skipping the manifest when one is required is steep, because EPA treats it as an unmanifested shipment violation, which is a separate count of liability from any underlying waste-handling violation.

A common misconception is that universal waste, used oil, and scrap metal need a manifest. They generally do not, because they are managed under the Universal Waste Rule at 40 CFR 273 or the Used Oil rules at 40 CFR 279, which have their own tracking systems.

Paper vs. e-Manifest

The Hazardous Waste Electronic Manifest Establishment Act of 2012 authorized EPA to create the e-Manifest system, which went live on June 30, 2018, and has been the preferred method ever since. As of the EPA’s Third Rule on e-Manifest finalized in 2024 and effective in stages through 2026, more transactions must occur electronically, and the user fees are set by waste type and submission method.

The 2026 fee schedule charges $25 for a fully electronic manifest, $10 for a hybrid manifest, $15 for a scanned image upload, and $20 for a mailed paper manifest, all paid by the receiving facility under the e-Manifest fee structure. The consequence of choosing paper when electronic is feasible is higher cost passed through by your TSDF and a much higher chance of data errors that come back as discrepancy reports.

A real-world example is MetalCoat Inc., a mid-sized plating shop in Ohio, which switched from paper to fully electronic manifests in 2025 and cut its quarterly discrepancy reports from 14 down to 2. The savings on TSDF fees alone covered the cost of the CROMERR electronic signature setup within four months.

Box-by-Box Walkthrough of Form 8700-22

Form 8700-22 has 20 numbered items on the first page and a continuation sheet called Form 8700-22A for shipments with more than four waste streams. Every item must be completed accurately, because any blank or wrong field can render the manifest invalid and trigger an EPA Notice of Violation.

Item 1: Generator ID Number

Item 1 requires the generator’s 12-character EPA ID number, which is assigned to the physical site where the waste was generated, not to the company. The ID is obtained by filing EPA Form 8700-12, the Site Identification Form, with your state environmental agency.

The consequence of entering a wrong or expired ID is a rejected manifest at the TSDF gate and an automatic violation, because 40 CFR 262.12 prohibits any generator from offering hazardous waste for transport without a valid ID. A common misconception is that a corporate parent ID covers all subsidiaries, but EPA assigns IDs by location, so each plant, lab, or warehouse needs its own.

For example, Dr. Lopez’s Dental Group in Houston has three offices, and each office must apply for its own EPA ID before shipping spent dental amalgam, even though all three operate under the same tax ID.

Item 2: Manifest Tracking Number

Item 2 is the unique 12-character Manifest Tracking Number, ending in the suffix “JJK” or a similar EPA-assigned code identifying the registered printer. You do not write this number yourself, because every paper form is pre-printed by an EPA-registered manifest printer.

Duplicating, photocopying, or making up a tracking number is a federal violation, and EPA has prosecuted printers and brokers for selling counterfeit forms. The number is the spine of the entire tracking system, because every signature, discrepancy report, and exception report ties back to it.

Item 3: Page Number

Item 3 simply states which page this is and how many total pages exist, written as “1 of 1” or “1 of 3” if continuation sheets are used. The consequence of mismatched page numbers is a discrepancy report from the TSDF, which can pause processing for up to 45 days under 40 CFR 264.72.

Item 4: Emergency Response Phone

Item 4 must list a 24-hour emergency response phone number that is monitored by a live person able to provide hazmat information about the load. This is a DOT requirement under 49 CFR 172.604, and the number must work during the entire transport.

A common mistake is listing the office switchboard, which is unstaffed at night, and that mistake alone has produced fines of $500 to $5,000 per shipment in DOT enforcement actions. Most generators contract with a service like CHEMTREC for this purpose, paying an annual fee that gives them a registered 24-hour line.

Item 5: Generator Name and Mailing Address

Item 5 is the generator’s legal company name and the site mailing address, which may differ from the physical site address listed on the EPA ID record. The site of generation, if different, goes in the space provided.

The consequence of mismatched names between the manifest and the EPA ID database is a RCRAInfo flag and a likely audit, because EPA cross-references every manifest against generator records nightly.

Items 6 and 7: Transporters

Item 6 is the first transporter’s name and EPA ID, and Item 7 is the second transporter if the load is being passed off mid-route. Each transporter must hold a valid EPA ID for transporters and a DOT registration.

Listing a transporter who does not hold a valid EPA ID makes the entire shipment illegal, because 40 CFR 263.11 requires every transporter to be registered before they touch hazardous waste.

Item 8: Designated Facility

Item 8 is the name, site address, and EPA ID of the designated TSDF that will receive and manage the waste. The facility must hold a RCRA permit or interim status for the waste codes you are shipping.

A common misconception is that any licensed waste hauler can receive your waste, but only a permitted TSDF can legally accept manifested hazardous waste. Sending waste to an unpermitted facility is a felony under 42 U.S.C. § 6928(d).

For example, GreenLab Pharmaceuticals once shipped a load of P-listed acute hazardous waste to a transfer station that was only permitted as a 10-day transfer point, and the resulting enforcement action cost the company $217,000 in penalties plus cleanup costs.

Item 9: U.S. DOT Description

Item 9 has two parts: 9a is a checkbox for HM (hazardous material) status, and 9b is the proper shipping name, hazard class, UN/NA identification number, and packing group. This is the single most error-prone field on the entire form.

The proper shipping name must come straight from the Hazardous Materials Table at 49 CFR 172.101, and it must include any required technical names in parentheses for n.o.s. (not otherwise specified) entries. For example, “Waste flammable liquid, n.o.s. (xylene, methanol), 3, UN1993, II” is correct, while “Waste paint thinner” is wrong and will be rejected.

The consequence of a wrong shipping description is a hold at the TSDF, a DOT Hazmat Enforcement investigation, and possible fines of up to $89,678 per violation under the 2026 PHMSA penalty schedule.

Item 10: Containers

Item 10 lists the number of containers and the container type code, such as DM for metal drums, DF for fiberboard drums, TP for portable tanks, or CY for cylinders. The full code list appears in the Form 8700-22 instructions.

Mismatching containers between the manifest and the actual load is the number-one trigger for a discrepancy report, and the TSDF must report any quantity or type discrepancy to EPA within 15 days under 40 CFR 264.72.

Item 11: Total Quantity

Item 11 is the total weight or volume in the units listed in Item 12, such as 4,400 pounds or 55 gallons. The number must reflect the actual load, not a rounded estimate.

A common misconception is that small over-or-under reporting is harmless, but the EPA Biennial Report is built directly from manifest data, and a pattern of misreporting can re-classify a generator from SQG to LQG, which carries far stricter requirements.

Item 12: Unit of Measure

Item 12 uses one-letter codes: P for pounds, T for tons, K for kilograms, M for metric tons, G for gallons, L for liters, Y for cubic yards, and N for cubic meters. Use the unit your TSDF uses on the invoice to avoid reconciliation problems.

Item 13: Waste Codes

Item 13 lists up to six federal and state hazardous waste codes per line, and continuation sheets are used if more codes apply. Federal codes come from 40 CFR Part 261 Subparts C and D, covering F, K, P, U, and D codes.

The consequence of missing a waste code is severe, because the TSDF will manage the waste only for the codes listed, and any unlisted code that later turns up in a sample triggers a Land Disposal Restriction (LDR) violation. Each LDR violation carries fines up to $93,058 per day under the 2026 schedule.

A common mistake is leaving off state-only codes, such as California’s non-RCRA hazardous waste codes from Title 22 CCR, which are required when shipping to or through California. Missing them voids the manifest under California Health and Safety Code § 25160.

Item 14: Special Handling Instructions

Item 14 contains any special handling instructions, profile numbers, or TSDF-required notes, such as “PCB content less than 50 ppm” or “Reactive sulfide-bearing waste, do not mix with acids.” This is also where the LDR notification is referenced when required.

The consequence of leaving out an LDR notification is that the TSDF cannot land-dispose the waste, and the load will sit until paperwork is corrected. Storage past 90 days at an LQG site without a permit is itself a violation under 40 CFR 262.17.

Item 15: Generator Certification

Item 15 contains the generator’s certification statement, which must be signed by hand on paper or by CROMERR-compliant electronic signature on e-Manifest. The signer must be authorized in writing by the generator and must personally verify the load.

Signing a manifest you have not personally verified is a federal felony under 18 U.S.C. § 1001 for false statements, and EPA has won multiple criminal convictions for “rubber stamp” signatures in the past five years.

Items 16, 17, 18, 19, and 20

Item 16 is the international shipments section, used only when waste crosses U.S. borders, and it triggers 40 CFR 262 Subpart H requirements. Item 17 is the transporter acknowledgement signature and date, signed when the transporter takes possession of the load.

Item 18 is the discrepancy indication space at the TSDF, where any difference in type, quantity, or condition is noted. Item 19 is the alternate facility designation, used if the primary facility cannot accept the load and rejects it under 40 CFR 264.72(f). Item 20 is the designated facility’s signature acknowledging receipt, which closes the cradle-to-grave loop.

The consequence of any missing signature is that the manifest never closes, and after 35 days the generator must investigate, then file an Exception Report within 45 days under 40 CFR 262.42.

Three Real-World Filer Examples

Below are three named-person scenarios drawn from common industry profiles, each showing how the form is filled out under different generator categories. These examples reflect typical facts; the names are illustrative.

Example 1: Maria Chen, VSQG Dental Office

Maria Chen runs a small dental practice in Vilnius-sister-city Sacramento, California, generating roughly 8 kg per month of spent dental amalgam containing mercury. As a VSQG under federal rules, she is normally exempt from manifesting under 40 CFR 262.14, but California’s stricter Department of Toxic Substances Control rules require a manifest for every shipment.

Maria lists waste code D009 for mercury in Item 13, uses container code DF for one fiberboard drum holding 25 lbs in Items 10 and 11, and writes “Waste mercury, 8, UN3077, III” in Item 9b. Her dental amalgam recycler in Item 8 is a permitted facility, and Maria signs Item 15 herself because she is the practice owner.

Example 2: James Patel, SQG Auto Body Shop

James Patel operates an auto body shop in Dallas, Texas, generating about 400 kg per month of spent solvents and paint waste, putting him squarely in the SQG tier. He ships four 55-gallon drums of mixed solvents quarterly under 40 CFR 262.16 SQG rules.

In Item 9b he writes “Waste flammable liquid, n.o.s. (xylene, toluene, methyl ethyl ketone), 3, UN1993, II,” in Item 10 he writes “4 DM,” in Item 11 he writes “1760,” and in Item 12 he writes “P” for pounds. His Item 13 codes are F003, F005, D001, and D035, picked from 40 CFR 261.31. He uses the Texas Commission on Environmental Quality state waste codes in Item 14 because Texas is an authorized state.

Example 3: Dr. Aisha Williams, LQG University Lab Pack

Dr. Aisha Williams manages environmental health and safety at a research university in Boston, Massachusetts, where the campus generates 2,500 kg per month of hazardous waste across hundreds of labs. The university files manifests almost weekly using the e-Manifest system.

Aisha’s lab pack shipments use Item 9b text “Waste chemicals, n.o.s., 9, UN3077 or UN3082, III” depending on phase, and she lists every applicable P-code, U-code, and D-code in Item 13, often using continuation sheet 8700-22A for shipments with more than four waste streams. She maintains LDR notifications under 40 CFR 268.7 and stores copies for at least three years as required by 40 CFR 262.40.

Three Common Shipment Scenarios and Outcomes

Filing Action	Regulatory Outcome
Generator signs Item 15 without verifying drum contents	False certification under 18 U.S.C. § 1001, criminal exposure up to 5 years
TSDF receives 4 drums but manifest shows 5	Discrepancy report filed within 15 days per 40 CFR 264.72, shipment held
Generator fails to receive signed copy back within 35 days	Mandatory Exception Report to EPA within 45 days under 40 CFR 262.42

Box-Filling Choice	Direct Consequence
Listing only federal codes when shipping into California	Manifest void under Cal. H&SC § 25160, state penalties added
Using “Waste paint” instead of proper UN shipping name	DOT violation under 49 CFR 172.101, fines up to $89,678
Using a transporter without an EPA ID	Illegal shipment under 40 CFR 263.11, generator and transporter both liable

Submission Method	2026 e-Manifest Fee
Fully electronic via RCRAInfo	$25 per manifest
Hybrid (electronic generator, paper transporter)	$10 per manifest
Scanned image upload by TSDF	$15 per manifest

Mistakes to Avoid

Below are the most common errors seen in EPA enforcement files and TSDF discrepancy reports, with the negative outcome that follows each.

• Using a photocopied manifest form. The Manifest Tracking Number must be unique, and a photocopy is treated as a forged federal document.
• Listing the wrong EPA ID for the generator site. This causes immediate rejection at the TSDF and a 40 CFR 262.12 violation that can stand alone in an enforcement action.
• Skipping state-specific waste codes. States like California, New York, and Washington require state codes in addition to federal codes, and missing them voids the manifest in those jurisdictions.
• Using a non-24-hour emergency phone number. This is a 49 CFR 172.604 violation and exposes the generator to DOT fines up to $89,678 per shipment.
• Forgetting the LDR notification. Without it, the TSDF cannot land-dispose, and the waste can sit in storage long enough to violate the 90-day or 180-day accumulation limits.
• Letting an unauthorized employee sign Item 15. EPA has prosecuted “rubber stamp” signatures, and the certifying employee must have written authority and personal knowledge of the load.
• Mismatched container counts between manifest and load. This produces an automatic discrepancy report that delays processing and triggers EPA scrutiny.
• Failing to keep manifest copies for three years. 40 CFR 262.40 requires retention, and missing records during inspection counts as a separate violation per shipment.
• Ignoring the 35-day exception window. If the signed copy does not return, the generator must investigate and file an Exception Report by day 45.
• Mixing waste streams without re-profiling. Adding a new chemical to a previously profiled drum without updating the profile leads to a wrong shipping description and discrepancy at the TSDF.

Do’s and Don’ts of Manifest Filing

The do’s and don’ts below come directly from EPA guidance and Office of Enforcement and Compliance Assurance audit findings. Each is followed by a brief reason.

• Do use the e-Manifest system whenever possible, because validation catches most errors before submission.
• Do verify every container against the manifest before signing Item 15, because the certification is a sworn federal statement.
• Do keep manifest copies for at least three years, because 40 CFR 262.40 makes retention mandatory.
• Do train every authorized signer annually under 40 CFR 262.17(a)(7), because untrained signers create personal criminal exposure.
• Do use a CHEMTREC-style 24-hour emergency line, because DOT requires live human response.
• Don’t photocopy or scan a paper manifest to reuse, because the tracking number must be unique.
• Don’t leave Item 14 blank when LDR notice is required, because the TSDF cannot land-dispose without it.
• Don’t let the transporter modify Item 15 after the generator signs, because any change voids the certification.
• Don’t ship to a facility without confirming its current RCRA permit status, because permits expire and operations get suspended.
• Don’t forget to update Item 1 if the generator changes its EPA ID after a site reorganization, because the wrong ID equals an unmanifested shipment.

Pros and Cons of e-Manifest vs. Paper

The shift to electronic manifests has tradeoffs that every generator should weigh against their volume, IT capability, and risk tolerance.

• Pro: real-time validation in the e-Manifest portal blocks most data errors before submission.
• Pro: lower user fees for fully electronic submissions under the 2026 fee schedule.
• Pro: instant access to copies, reducing the need for filing cabinets and three-year retention infrastructure.
• Pro: faster TSDF processing because the receiver does not re-key data.
• Pro: integration with RCRAInfo lets generators run analytics on their waste streams.
• Con: CROMERR setup cost for electronic signatures can run $1,000-$3,000 per facility.
• Con: some transporters still lack e-Manifest capability, forcing hybrid manifests at higher per-shipment cost.
• Con: system outages at the EPA portal occasionally force a paper backup procedure.
• Con: training time for staff to learn the RCRAInfo industry user interface.
• Con: paper is still required for certain export shipments under 40 CFR 262 Subpart H.

State Nuances Beyond the Federal Baseline

Forty-eight states are authorized to administer the RCRA program, and each can be more stringent than EPA but not less. The federal manifest form itself is the same nationwide because of 40 CFR 262.21, but state waste codes, reporting cycles, and signature rules vary.

California DTSC requires non-RCRA hazardous waste codes for materials EPA does not list, such as certain treated wood and contaminated soil. Texas TCEQ assigns industrial solid waste codes that must appear in Item 14. New York DEC requires its own quarterly summary in addition to federal biennial reporting. New Jersey DEP enforces its Worker and Community Right to Know Act in tandem with manifest data.

The consequence of treating a state-authorized program like the federal program is double, because both EPA and the state can pursue parallel enforcement, and a single shipment error can produce both federal and state penalty counts.

Recap of Key Court Rulings and Enforcement Actions

Several federal cases shape how EPA Form 8700-22 must be filled out today, and each one matters for compliance staff. In United States v. Hayes International Corp., 786 F.2d 1499 (11th Cir. 1986), the court held that knowingly transporting hazardous waste to an unpermitted facility is a strict-liability felony when the manifest is missing or false.

In United States v. Dean, 969 F.2d 187 (6th Cir. 1992), the court ruled that a generator’s certifying signature on Item 15 imposes personal criminal liability when the signer knows the manifest is inaccurate. EPA’s 2024 settlement with Clean Harbors included millions in penalties partly because of recurring manifest discrepancy patterns, showing that even sophisticated TSDFs are not immune to enforcement.

The Sackett v. EPA line of cases, while focused on the Clean Water Act, signaled that courts are watching agency interpretation of regulatory authority closely, which makes precise manifest paperwork even more important when defending an enforcement action.

How to Submit, Correct, and Retain the Manifest

Once the manifest is signed, the generator keeps the appropriate copy and gives the rest to the transporter, who delivers them with the load. The TSDF signs Item 20 on receipt, returns a signed copy to the generator within 35 days, and uploads the data to e-Manifest within 30 days under 40 CFR 264.71.

Corrections after submission are made through the Manifest Correction process inside RCRAInfo, where the original signer or an authorized substitute can submit a corrected version with a CROMERR signature. The consequence of failing to correct a known error is that the original incorrect manifest stands as the record, and EPA can use it in enforcement.

Retention rules require generators to keep manifests and exception reports for at least three years, and 40 CFR 262.40(d) extends the period automatically during any unresolved enforcement action. A common misconception is that e-Manifest storage by EPA replaces the generator’s duty to retain copies, but the regulation is clear that the generator must keep its own records.

FAQs

Is EPA Form 8700-22 required for every hazardous waste shipment?

Yes. Every off-site shipment of RCRA hazardous waste from an SQG or LQG requires Form 8700-22 under 40 CFR 262.20, with limited exemptions for VSQGs and certain reverse distribution.

Can I download a blank Form 8700-22 and print my own?

No. Paper manifests must come from an EPA-registered printer because each form has a unique pre-printed Manifest Tracking Number, and printing your own is treated as forgery.

Do VSQGs ever need to file Form 8700-22?

Yes. VSQGs must use the manifest when shipping to a permitted RCRA TSDF and when state law requires it, even if federal rules would otherwise exempt the shipment under 40 CFR 262.14.

Is the e-Manifest fee paid by the generator?

No. The fee is billed to the designated facility, although TSDFs typically pass the cost through to generators on the disposal invoice.

Can I sign Item 15 with a digital signature?

Yes. Electronic signatures are valid when made through a CROMERR-compliant system inside e-Manifest, but typed names or generic e-signature tools are not valid.

Do I need to file an Exception Report if the signed copy is late?

Yes. If the generator does not receive a signed manifest within 35 days, an Exception Report must be filed with EPA within 45 days under 40 CFR 262.42.

Is the manifest required for universal waste shipments?

No. Universal waste under 40 CFR 273 is tracked through bills of lading or shipping papers, not the Uniform Hazardous Waste Manifest.

Can a broker sign the manifest on behalf of the generator?

No. Only an authorized employee of the generator with personal knowledge of the load may sign Item 15 under 40 CFR 262.20, although brokers can prepare the form for review.

Do I include state waste codes in Item 13?

Yes. State-authorized programs require their own waste codes when the shipment originates in, passes through, or is delivered to that state, and missing them voids the manifest under state law.

Is retention of manifest copies required after e-Manifest submission?

Yes. Generators must keep their own copies for three years under 40 CFR 262.40, and the period extends automatically during any open enforcement matter.

Can I correct a manifest after the TSDF signs Item 20?

Yes. Corrections are made through the Manifest Correction module in RCRAInfo with a CROMERR signature, and any party to the manifest may initiate the correction.

Is Form 8700-22A required for every shipment?

No. The continuation sheet is only needed when the load has more than four waste streams or more than two transporters, as described in the Form 8700-22 instructions.