Requirements for Manufacturers of Battery-Embedded Products

Senate Bill (SB) 1215 (Newman, Chapter 370, Statutes of 2022) amended and expanded the Electronic Waste Recycling Act of 2003 by adding battery-embedded products to the types of electronic devices covered by the law. Public Resources Code (PRC) section 42463 (f)(1)-(2) specifies the statutory definition of “covered battery-embedded product” and product exclusions.

SB 1215 also established new requirements for manufacturers of covered battery-embedded products to send notices to all retailers in California selling those products. As a courtesy, CalRecycle has included a summary of the manufacturer notice requirements below. The complete notice requirements can be found at PRC section 42466.2.

Summary of Manufacturer Requirements to Notify Retailers

• On or before July 1, 2025, and every year thereafter, a manufacturer of a covered battery-embedded product is required to send a notice to all retailers in California selling those products. The notice must identify the covered battery-embedded products manufactured by that manufacturer that are subject to the law.
• On or before July 1, 2025, and every year thereafter, a manufacturer of a covered battery-embedded product is required to send a notice to retailers covering any product manufactured by that manufacturer that is exempt from the covered battery-embedded product definition.
• All covered battery-embedded products included in a notice sent to retailers must be identified by brand and model number.
• The notice must inform retailers that covered battery-embedded products included in the notice are subject to a covered battery-embedded waste recycling fee pursuant to PRC section 42464(b).
  • Please note, the covered battery-embedded waste recycling fee has not yet been determined. CalRecycle must establish this fee on or before October 1, 2025, and each year thereafter, pursuant to PRC section 42464(b)(3)).
• Manufacturers subject to the requirements of PRC section 42466.2 must send copies of the notices to CalRecycle by emailing them to CEDmanufacturers@calrecycle.ca.gov.

If, after reviewing the statute, there are questions about the requirements for manufacturers of covered battery-embedded products to notify retailers, please contact embeddedbatteries@calrecycle.ca.gov.