Frequent Questions about the Manifest Registry

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Can I submit multiple form samples to the EPA Registry for approval?

Yes. There is nothing in the regulations to prevent a registrant from submitting multiple sets of samples to the Registry under section 262.21(d) in title 40 of the Code of Federal Regulations (CFR). EPA expects that registrants will be forward-looking when they apply to the Registry. For example, some registrants might want to get approved for two paper types so they have flexibility to use one paper type or the other in the event that one paper type is discontinued by the manufacturer or goes up in price. If a registrant would like to get approved for two paper types, it must submit form samples for each type of paper, to get approval for both paper types.

Must I submit a continuation sheet sample to the Manifest Registry under 40 CFR section 262.21(d)?

The regulations, found in 40 CFR section 262.21(d)(3), state that you do not need to submit samples of a continuation sheet if you intend to print the continuation sheet using the same paper type, paper weight of each copy, ink color of the instructions, and binding method as your manifest form samples. However, we have found errors in continuation sheet samples provided by applicants. For that reason, we believe it is advisable that you provide samples of the continuation sheet when you provide samples of the manifest.

How much information must be provided in the initial application and how must it be organized?

Each registrant should use its discretion to determine the appropriate amount of information to submit. If its printing arrangement is straightforward, its application may be relatively simple. EPA encourages all registrants to review the guidances posted on our Web site for preparing the initial application and form samples. These documents will give you an idea of our expectations regarding your application materials.

You will note that there is no application form. Registrants are free to organize their applications as they want. Of course, it makes sense to organize them as clearly as possible. This will help to prevent questions from EPA on the application. In general, the application should be organized so EPA can easily determine whether all of the requirements of 40 CFR section 262.21(b) have been met.

What situations might exempt me from having to submit form samples under 40 CFR section 262.21(d) or (h)(3)?

40 CFR section 262.21(j) provides that EPA may, at its discretion, exempt a registrant from the requirement to submit a form sample under 40 CFR section 262.21(d) or (h)(3). A registrant may request an exemption from EPA by indicating why an exemption is warranted. We envision several reasons why a registrant might request an exemption.

For example, it would not be unusual for two or more registrants to rely on the same commercial printer to print their forms under the Registry. If a commercial printer prints the manifest on behalf of an approved registrant and then, subsequently, a second registrant applies to use that same printer, we do not believe it is necessary for the second registrant to submit new form samples under 40 CFR section 262.21(d), so long as the same printer will be printing the manifest using the same paper type, paper weight, ink color of the instructions and binding method of the form samples approved for the first registrant. After the printer's forms get approved the first time, the second registrant could submit the printer's original form samples for evaluation under the Registry. Once approved under 40 CFR section 262.21(e), the second registrant must use that printer to print its forms according to the specifications at 40 CFR section 262.21(f), as well as the paper weight, paper type, ink color of the instructions, and binding method of the printer's originally approved form samples. It also must pre-print a unique manifest tracking number on each manifest using its approved suffix.

Another common situation would be where a registrant gets approved to print a manifest using a certain paper type, paper weight, ink color of the instructions, and binding method, and subsequently wants to change one or more of these specifications. Under 40 CFR section 262.21(h)(3), the registrant must submit three form samples and get EPA approval. We believe the 40 CFR section 262.21(h)(3) requirement is important for evaluating whether a registrant's revised manifest meets the specifications at 40 CFR section 262.21(f). However, there might be some exceptions to this.

For example, we do not believe we need to evaluate a revised form sample if we are aware that the revised specifications have already been approved for another registrant. As we evaluate and approve form samples under 40 CFR sections 262.21(e) and (h)(3), we may post approved form specifications (e.g., paper type, paper weight) on our Web site. If an approved registrant would like to change one or more of its form's specifications to another approved specification on our Web site, the registrant may notify EPA that it intends to do so, in lieu of submitting revised form samples. EPA could then relieve the registrant of the requirement to submit revised form samples.

Can I typeset the form after I am approved to print the manifest?

Typesetting the form subsequent to approval under 40 CFR section 262.21(e) is strongly discouraged. As provided by 40 CFR section 262.21(i), if, subsequent to its approval under 40 CFR section 262.21(e), a registrant typesets its manifest and continuation sheet instead of using the electronic file of the form samples approved by EPA, it must submit a sample of the manifest and continuation sheet to the Registry for approval. EPA recognizes that most registrants that get approved will print one or more batches of forms for use or sale. After the print jobs are done, the printer will destroy or recycle the printing plate and move on to the next print job. When it wishes to print more manifests, the printer will need to create a new printing plate.

We are not requiring the registrant to resubmit a sample of its approved manifests each time it develops a new printing plate. After it is approved under 40 CFR section 262.21(e), we fully expect it to save the electronic file of its approved samples in its computer system to recreate its printing plate when needed.

Can my organization request two or more suffixes in our initial application?

For several reasons, registrants may not request more than one suffix in their initial application. We understand that some registrants intend to sell the manifest and may want to print suffixes desired by their customers (e.g., a customer's abbreviated company name). We want to emphasize, however, that this is not the purpose of the suffix. The primary purpose of the unique suffix is to enable each registrant to print manifest tracking numbers (MTNs) that are unique to its organization. Another purpose is for EPA to identify the source of a manifest.

In addition, registrants may not request multiple suffixes because this would reduce the availability of suffixes for other registrants.

Finally, we believe that one suffix will provide a registrant with numbering capacity for many years. 40 CFR section 262.21(f)(2) requires each registrant to print a unique MTN that consists of its unique suffix following nine digits. This 12-character numbering scheme will enable a registrant to print up to a billion unique numbers.

How can I satisfy the requirement for a signed certification in my initial application under 40 CFR section 262.21(b)(8)?

40 CFR section 262.21(b)(8) requires the application to include a signed certification by a duly authorized employee of the registrant that the organizations and companies in its application will comply with the procedures of its approved application and the requirements of 40 CFR section 262.21 and that it will notify the EPA Director of the Office of Solid Waste, OSW (renamed Office of Resource Conservation and Recovery, ORCR, on January 18, 2009) of any duplicated manifest tracking numbers on manifests that have been used or distributed to other parties as soon as this becomes known.

A good way to satisfy this requirement is to include the language of 40 CFR section 262.21(b)(8) in your application and sign it.  For example:

I, [name of signatory], certify that [name of registrant organization and any other companies] will comply with the procedures of our approved application and the requirements of 40 CFR section 262.21 and that we will notify the EPA Director of the Office of Resource Conservation and Recovery (ORCR) of any duplicated manifest tracking numbers on manifests that have been used or distributed to other parties as soon as this becomes known.

[signature and date]
[title of signatory]

For additional information on who the signatory should be, refer to the “Instructions for Preparing Application Materials for Submittal to EPA’s Manifest Registry,” which is posted at EPA’s Manifest Registry web site.

Once I am approved to print the manifest, are there any circumstances under which my printing privileges could be suspended or revoked?

Yes. EPA may suspend and, if necessary, revoke your printing privileges if we find that you: 1) have used or distributed forms that deviate from your approved form samples with regard to paper weight, paper type (i.e., manufacturer and grade), ink color of the instructions or binding method; or 2) exhibit a continuing pattern of behavior in using or distributing manifests that contain duplicate manifest tracking numbers. In such cases, we will send a warning letter to you that specifies the date by which you must come into compliance with the requirements. If you do not come into compliance by the specified date, we will send a second letter notifying you that we have suspended or revoked your printing privileges. We expect that suspension or revocation of printing privileges will be very rare.

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Last updated on June 17, 2024