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November 01, 2023
Compliance Tip: Lithium batteries disposal

Q. How do you properly dispose of lithium batteries that are no longer in use?

Most lithium-ion batteries are considered hazardous wastes when they are disposed of because of their hazardous characteristics of ignitibility and reactivity. Consequently, disposal would require compliance with your state’s hazardous waste regulations which include storage restrictions and transporting the batteries with a hazardous waste manifest to a disposal facility that is permitted to dispose of hazardous waste. However, a guidance memorandum issued by the U.S. EPA on May 24, 2023 (EPA Memo) concludes that such batteries can be managed as a “universal waste” pursuant to the EPA regulations at 40 CFR 273. The EPA Memo recommends management as a universal waste as this set of requirements is more “streamlined” than the otherwise applicable hazardous waste regulations that have a greater regulatory compliance burden. The universal waste requirements include those for employee training (e.g. proper handling and emergency procedures appropriate to the type of universal waste handled at the facility), container labeling, an on-site accumulation limit of one year, and shipment to a universal waste destination facility (a permitted hazardous waste disposal facility or recycler). A manifest is not required.