An additional consideration, particularly for small businesses or those that generate small amounts of hazardous waste per month, are the RCRA “very small quantity generator” (VSQG) regulations. Li-ion batteries discarded by businesses that generate less than 100 kg (220 pounds) of hazardous waste per month are considered very small quantity generator waste and may be subject to reduced hazardous waste requirements. Prior to using the VSQG exemption, check with your state regulatory program, as they may have different requirements. Although EPA recommends that all batteries be managed under the universal waste standards, persons collecting or storing used Li-ion batteries from households or from VSQGs for the purposes of either exemption should keep them separate from other collected Li-ion batteries that are subject to more stringent requirements. Otherwise, they risk having the entire commingled collection subjected to the more stringent requirements (e.g., the streamlined universal waste requirements or the standard hazardous waste generator regulations).

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Because of the size and complexity of these battery systems, medium and large-scale Li-ion batteries may not be able to be removed by the consumer. Refer to the manufacturer’s instructions and heed warnings and safety instructions.

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Lithium-ion batteries with different chemical compositions can appear nearly identical yet have different properties. In addition, some discarded Li-ion batteries are more likely to have hazardous properties if they contain a significant charge, yet such batteries can appear to the user to be completely discharged. Therefore, EPA recommends that businesses consider managing Li-ion batteries under the federal “universal waste” regulations in Title 40 of the Code of Federal Regulations (CFR) part 273.

There are two types of lithium batteries that the U.S. consumers use and need to manage at the end of their useful life: single-use, non-rechargeable lithium metal batteries and re-chargeable lithium-polymer cells (Li-ion, Li-ion cells).

The DOT’s “Check the Box” campaign is a public awareness campaign that seeks to prevent serious incidents by increasing public awareness of everyday items that are considered hazardous materials in transportation – this includes batteries that are packaged and sent for recycling or disposal. Batteries must be correctly identified, packaged, and labeled via package markings before being sent for recycling or disposal. For more information, go to DOT’s Check the Box campaign and check out the campaign video.

Li-ion batteries that are easily separated from the product (e.g., power tools): Find a recycling location near youto properly dispose of Li-ion batteries. Send individual batteries to specialized battery recyclers or retailers that are participating in takeback services or contact your local solid waste or household hazardous waste program for more options.

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Additionally, if the battery or electronic device that contains the battery is disposed of in the trash or placed in the municipal recycling bin with household recyclables such as plastic, paper or glass, it may become damaged or crushed in transport or from processing and sorting equipment, creating a fire hazard.

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Due to the increase of fires at recycling and waste facilities across the country, industry groups have worked together to develop the ‘Avoid the Spark. Be Battery Safety Smart.’ campaign. This campaign seeks to educate the American consumer about battery safety and proper management of used Li-ion batteries. The main message of the campaign is that batteries can and should be recycled when they reach the end of their useful life. For more information go to Call2Recycle’s website.

The increased demand for Li-ion batteries in the marketplace can be traced largely to the high “energy density” of this battery chemistry. “Energy density” means the amount of energy that a system stores in an amount of space. Lithium batteries can be smaller and lighter than other types of batteries while holding the same amount of energy. This miniaturization has allowed for a rapid increase in the consumer adoption of smaller portable and cordless products.

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EPA recommendation: Contact the manufacturer, automobile dealer or company that installed the Li-ion battery for management options; do not put it in the trash or municipal recycling bins.

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Lithium-ion (Li-ion) batteries are used in many products such as electronics, toys, wireless headphones, handheld power tools, small and large appliances, electric vehicles and electrical energy storage systems. If not properly managed at the end of their useful life, they can cause harm to human health or the environment.

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Handling precautions: Place each battery or device containing a battery in a separate plastic bag. Place non-conductive tape (e.g., electrical tape) over the battery’s terminals. If the Li-ion battery becomes damaged, contact the battery or device manufacturer for specific handling information. Even used batteries can have enough energy to injure or start fires. Not all batteries are removable or serviceable by the user. Heed battery and product markings regarding safety and use.

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DDR lithium batteries, including those that have been misused and abused, are more likely to catch fire during transportation than non-DDR lithium batteries. Unfortunately, misused, abused, and other kinds of DDR lithium batteries can be difficult to identify. Without the proper information and awareness, many shippers and carriers may continue to ship DDR lithium batteries in the same manner as non-DDR ones, creating additional risks for their communities. This guidance is intended to help you identify DDR lithium batteries and properly package them for shipment.

EPA recommendation: Find a location to recycle Li-ion batteries and products that contain Li-ion batteries using one of the suggested links; do not put them in the trash or municipal recycling bins.

Most lithium-ion batteries on the market are likely to meet the definition of hazardous waste under the Resource Conservation and Recovery Act (RCRA). Most lithium-ion batteries when discarded would likely be considered ignitable and reactive hazardous wastes (carrying the waste codes D001 and D003, respectively). Persons who generate wastes that are defined as hazardous under RCRA are referred to as “hazardous waste generators.” These regulations do not apply to households because under RCRA, hazardous wastes discarded by households are generally exempt from hazardous waste regulations. In contrast, commercial establishments are responsible for determining whether any waste they produce is hazardous waste, including Li-ion batteries at their end of life.

The universal waste regulations provide a streamlined set of requirements for generators of specific types of common hazardous wastes (e.g., fluorescent lamps containing mercury, batteries) from a wide variety of commercial settings. Requirements differ depending on whether you accumulate less or more than 5,000 kg of total universal wastes on site at one time, but they include instructions on how to manage the waste, how to label containers, how long the waste can be accumulated on site, and where the waste can be sent, among others. Universal waste regulations do not require shipment using a hazardous waste manifest but do require that the waste be sent to a permitted hazardous waste disposal facility or a recycler. International shipments of Li-ion batteries managed as universal waste must also comply with RCRA requirements for export and import of universal waste. EPA recommends that businesses consult their state solid and hazardous waste agencies for additional information on applicable universal waste regulations.

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Li-ion batteries, or those contained in electronic devices, should therefore be recycled at certified battery electronics recyclers that accept batteries rather than being discarded in the trash or put in municipal recycling bins.

In May 2022, DOT’s Pipeline and Hazardous Materials Safety Administration issued a Safety Advisory Notice for Disposal and Recycling of Lithium Batteries in Commercial Transportation. The Safety Advisory Notice aims to increase the public’s overall awareness about the dangers related to shipping lithium batteries for recycling or disposal. The Safety Advisory Notice:

Lithium batteries are hazardous materials and are subject to DOT's Hazardous Materials Regulations (HMR; 49 CFR Parts 171–180). This includes packaging and standard hazard communication requirements (e.g., markings, labels, shipping papers, emergency response information) and hazmat employee training requirements. Hazard communication requirements are found in part 172 of the HMR and requirements specific to lithium batteries are found in 49 CFR section 173.185.

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On October 23, 2023, EPA announced a new rulemaking effort to improve the recycling and management of end-of-life solar panels and lithium batteries. EPA is developing a proposed rule to add solar panels to the universal waste regulations and to add tailored universal waste standards for lithium batteries. EPA is working on this rulemaking in part in response to a petition submitted by a broad coalition of industry associations to regulate solar panels as universal waste. EPA is also working on adjustments within the universal waste regulations to improve safety standards and reduce fires from mismanaged end-of-life lithium batteries. Read about this effort on our website.

The Department of Labor’s Occupational Safety and Health Administration (OSHA) issued a Safety and Health Information Bulletin: Preventing Fire and/or Explosion Injury from Small and Wearable Lithium Battery Powered Devices. The Bulletin is advisory in nature, informational in content, and intended to educate workers and assist employers in providing a safe and healthful workplace.

Li-ion batteries in electronics: Send electronic devices containing Li-ion batteries to certified electronics recyclers, participating retailers and recyclers in electronics takeback services or contact your local solid waste or household hazardous waste collection program for more options.

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