Managing Hazardous Waste

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Discarded Battery Management at Facilities Handling Solid Waste and Recyclable Materials Fact Sheet

September 2016*

Batteries may not be disposed in trash or household recycling collection bins intended to receive other non-hazardous waste and/or recyclable materials:  it is prohibited by law.

Batteries, when discarded, are a waste, and may not be placed in the trash or into household paper, plastic, and glass recycling collection bins. A discarded battery that exhibits a hazardous waste characteristic or contains a listed hazardous waste, as described in chapter 11 of title 22, division 4.5, California Code of Regulations, is subject to regulation under articles 10.6 and 10.8 of California Health and Safety Code and California Code of Regulations, title 22, chapters 11, 12, 16 and 23 by the Department of Toxic Substances Control (DTSC) and the Certified Unified Program Agencies (CUPAs). Many types of batteries regardless of size exhibit hazardous characteristics and are considered hazardous waste when they are discarded. These include common rechargeable and single use triple and double A size, C, D, button cell, and 9 Volt batteries. 

How Should Transfer Stations, Landfills and Recycling Centers Handle Batteries?

An owner/operator of solid waste transfer stations, municipal landfills, and recycling centers, that discovers batteries in the waste or recyclable materials they are processing should remove and manage the batteries separately according to the applicable regulations. The facility that removes the batteries from the municipal solid waste stream or recyclable materials becomes the generator of the hazardous waste batteries and must comply with the hazardous waste management regulations in California Code of Regulations, title 22, chapters 10 through 12, 16, and 23.

The determination whether to manage the batteries under the universal waste standards (small household batteries as described in chapter 23 of California Code of Regulations, title 22), spent lead-acid battery standards (automotive type batteries as described in article 7 of chapter 16 in California Code of Regulations, title 22), or as fully regulated hazardous waste (primarily found in chapters 10 through 20 of California Code of Regulations, title 22), is at the discretion of the facility generating the hazardous waste batteries.

Universal waste batteries, spent lead-acid batteries, and hazardous waste batteries must be managed according to the applicable requirements for handling, accumulation, labeling, transport, and disposal. There are different management standards for each.

For more information, view the following fact sheets:

In addition, as a generator, the facility should contact the CUPA in their area for more information about the CUPA’s generator program and any notifications or permits they may require.

To find the CUPA in your area, search the Unified Program Regulator Directory (opens new window).

Which Discarded Batteries are Hazardous Waste?

Batteries that exhibit a hazardous characteristic or contain a listed hazardous waste are hazardous waste in California when they are discarded.  These include single use alkaline and lithium batteries and rechargeable lithium metal, nickel cadmium, and nickel metal hydride batteries of various sizes (AAA, AA, C, D, button cell, 9 Volt, and small sealed lead-acid batteries). Some batteries do not meet the hazardous waste characteristics or contain a listed hazardous waste but these may be difficult to differentiate from their hazardous counterparts. As a general rule, a person who does not know a battery’s type or chemistry should presume that battery is hazardous waste and should not dispose of it in the trash or recyclable waste bins. Lead acid batteries (such as automotive cranking batteries) are also hazardous wastes, but may be managed under requirements specific to lead acid batteries as described in article 10.5 of California Health and Safety Code. Lead acid battery management requirements do not apply to small sealed lead acid batteries which are managed as universal waste as described in articles 10.6 and 10.8 of California Health and Safety Code along with article 7, chapter 16, title 22 of California Code of Regulations.

What if Batteries are not Managed Separately from Other Wastestreams?

Facilities that do not properly manage hazardous waste may be subject to regulatory enforcement and may be liable for monetary penalties.

Where Can A Facility Send Batteries?

Depending on the type of battery and applicable management requirements batteries must be sent to a facility permitted to accept hazardous waste batteries, universal wastes, or spent lead-acid batteries. Only facilities that have a DTSC permit or other type of authorization to treat, store or dispose of hazardous wastes may accept hazardous waste batteries. Persons that do not have a DTSC permit may accept and store universal waste batteries and spent lead-acid batteries if they operate according to the regulations specifically tailored for those types of batteries. For management and disposal requirements and options for Universal Waste batteries, spent lead-acid batteries, and hazardous waste batteries, go to the above links for Universal Waste, Spent Lead-acid Batteries, and hazardous waste management requirements.

Load Checking at Solid Waste Facilities

This fact sheet is focused on the management of batteries.  For more information about other hazardous waste requirements that also apply to load checking at facilities, see our Load Checking for Hazardous Waste at Municipal Landfills and Transfer Stations fact sheet.


This fact sheet does not replace or supersede relevant statutes and regulations. The information contained in this fact sheet is based upon the statutes and regulations in effect as of the date of the fact sheet. Interested parties should keep apprised of subsequent changes to relevant statutes and regulations.