Batteries

• Who is covered by the regulations?
• What is the purpose of the regulations?
• Regulations
• Compliance Options
• Best Practices
• More Resources

This page is concerned with spent batteries, including lead-acid vehicle and railroad signal batteries, as well as other types of industrial batteries that have hazardous characteristics. For links to information on smaller batteries, such as those used in electronic devices, see the TERC topic page on Universal Waste.

Who is covered by the regulations?

Any facility that collects or disposes of batteries. To encourage recycling, many batteries that would otherwise be classified as hazardous wastes can be handled as universal wastes, with somewhat less stringent requirements. Specific regulations can vary from state to state.

What is the purpose of the regulations?

Lead-acid batteries contain a highly toxic metal (lead), and corrosive sulfuric acid. Batteries that stay in the recycling loop are valuable resources that have been successfully recycled for decades. Batteries that find their way into landfills or waste dumps are potentially dangerous, and are significant pollution sources. The regulations are intended to make the batteries easy to recycle, and to discourage improper disposal with fines and other penalties.

Regulations

Universal Waste Rule (40 CFR Part 273). Due to their characteristics, spent lead-acid and certain other batteries (e.g., nickel-cadmium, nickel iron, and carbonaire railroad signal batteries) would be classified as hazardous wastes, but special rules have been developed to make it easier to recycle them. Batteries and several other common waste items (e.g., florescent bulbs containing mercury), have been grouped into a regulatory classification called "universal waste". The federal standards for universal waste describe the rules for handling batteries for recycling. Many states have adopted the federal rules, but some variations exist from one state to another.

If a facility accumulates more than 5000 kg (11,000 lb) of universal waste at any point during a given year, it is required to register as a "large quantity handler of universal wastes (LQHUW)". An LQHUW is required to obtain an EPA registration number and to provide process and contact information. A heavy-duty vehicle battery can weigh 50 - 80 pounds or more, so a facility accumulating several dozen batteries at a time could cross the threshold and become an LQHUW. Facilities accumulating smaller amounts do not have to register, but do have to comply with the rules for small quantity handlers of universal waste (SQHUWs).

Federal hazardous waste management regulations draw a sharp distinction between facilities that are permitted to add items and materials to the waste stream ("generators") and those who take the waste from there (treatment, storage, and disposal facilities, or "TSDFs"). TSDFs are regulated much more strictly than generators. In practice, it was found that under certain circumstances, allowing generators to carry out a few simple processes makes it easier to recycle, or to more conveniently manage, certain kinds of wastes. But it became necessary to spell out in detail what processes would be allowed.

For batteries, the federal standards for universal waste management specify the processes that may be carried out by universal waste handlers (both large and small quantity). In brief (consult 40 CFR 273, or the EPA summary page, for the exact wording):

• If a battery is leaking, put it in a container that won't leak
• Universal waste handlers are allowed to:
  • sort and pack intact batteries for shipment
  • discharge the batteries (run down the charge through a suitable load so they won't spark if the terminals are shorted)
  • conversely, recharge them if they are going to be used again
  • extract the intact batteries if they are contained in other products, and disassemble the batteries into smaller intact modules or cells
  • remove the electrolyte

Note that if the electrolyte is removed, the handler is required to determine if it is itself a hazardous waste (since it would no longer be covered under the universal waste regulations), and to manage it accordingly.

Batteries or containers must be marked with one of the following:

• "Universal Waste -- Battery(ies)"
• "Waste Battery(ies)"
• "Used Battery(ies)"

The following table lists resources provided by state environmental agencies and other groups that contain state-specific information on managing spent lead-acid batteries.

Streamlined Lead Acid Batteries Standards (40 CFR Part 266, Subpart G). Spent lead-acid batteries being reclaimed may alternatively be managed under 40 CFR 266, Subject G. This rule only applies to spent lead-acid batteries. It does not apply to any other types of batteries that can otherwise be recycled under the Universal Waste Rule. The streamlined lead acid battery standards generally exempt persons who generate, transport, or collect spent lead-acid batteries destined for reclamation from the majority of hazardous waste regulations. Persons who store spent lead-acid batteries before reclaiming them must notify EPA and obtain a RCRA permit for that storage. Lead-acid batteries that are regenerated rather than reclaimed remain exempt from the hazardous waste regulations throughout the management cycle. Most states have adopted by reference the streamlined lead acid battery standards.

Compliance Options

If a vehicle battery is being replaced, the easiest option is to exchange the old battery at the same location where the new one is purchased. Retailers in most areas are required to accept old batteries for recycling. Some retailers will accept them even if the battery is not being replaced. Lists including companies in addition to retailers that will accept batteries for recycling may be found for some locations in the table in the previous section.

Best Practices

Recycling is generally the only sensible option for spent lead-acid batteries. A large fraction -- 96%, according to one recent study -- of the lead in lead-acid batteries is recycled, which probably makes battery lead the most recycled material in commerce today.

The situation will become more complicated over the next few years, as new battery types find wider applications in vehicles. Lead-acid batteries store enough power to start an engine, but do not store enough power per pound to be used as a component of the power train. Lithium-ion batteries, rapidly decreasing in cost as they are incorporated into passenger vehicles, may start finding uses in some freight applications. If so, vehicle maintenance facilities will have to manage spent lithium-ion batteries, at least initially without the benefit of the recycling infrastructure that has been established for lead-acid.

More Resources

Text of the federal universal waste regulation (40 CFR 273)

Battery Council International