The compliance calendar

Regulation enters into force

Regulation (EU) 2023/1542 enters into force, twenty days after publication in the Official Journal on 28 July 2023.

Regulation begins to apply

The general date of application. Most provisions start applying from this date, phasing in progressively, while the 2006 Batteries Directive is gradually replaced.

Performance, durability and CE marking

From this date, rechargeable industrial batteries above 2 kWh, LMT batteries and EV batteries must be accompanied by documentation of electrochemical performance and durability parameters (Annex IV). CE marking and conformity assessment obligations, and performance and durability requirements for portable batteries under Article 10, also apply.

Section 301 tariff on Chinese EV lithium-ion batteries rises to 25%

Following USTR's four-year statutory review, the tariff on lithium-ion batteries used as the primary power source in electric and hybrid passenger vehicles rose from 7.5% to 25%. Parts of rechargeable lead-acid batteries rose to 25% on the same date.

New Jersey: propulsion battery producers must register with NJDEP

Registration deadline under the Electric and Hybrid Vehicle Battery Management Act, signed 8 January 2024. Producers include vehicle manufacturers, brand or trademark licensees and importers for batteries embedded in vehicles, and battery manufacturers, remanufacturers and importers for batteries sold separately.

EV Battery Safety Certification System takes effect

Government certification replaces manufacturer self-certification. Automakers must obtain certification from the Ministry of Land, Infrastructure and Transport for the batteries used in their electric vehicles, and must assign an identification number to each individual battery, recorded in the vehicle register. Certified batteries must undergo further safety inspection every three years. The measure followed an electric vehicle fire in an underground car park in Incheon in August 2024.

Motor Vehicle Management Act, as amended

Carbon footprint declaration, EV batteries (deferred)

The scheduled date for the carbon footprint declaration requirement for electric vehicle batteries. The obligation applies from this date or 12 months after the entry into force of the relevant delegated and implementing acts, whichever is the latest. Those acts have not been adopted, so the published date has passed without the obligation becoming operative, and the clock will run from the acts when they arrive.

Digital labelling permitted, marking thresholds relaxed

Gazette notification S.O. 958(E) allows a barcode or QR code carrying the producer's EPR registration details, printed on the battery, the vehicle, the packaging or the product brochure. Marking requirements are relaxed for trace cadmium up to 0.002 percent and lead up to 0.004 percent.

Battery Waste Management (Amendment) Rules 2025, S.O. 958(E) of 24 February 2025

Section 45X: prohibited foreign entity restrictions begin

The One Big Beautiful Bill Act (Public Law 119-21) provides that, for tax years beginning after enactment, a component is not an eligible component for the 45X advanced manufacturing production credit if it involves material assistance from a prohibited foreign entity. Such entities cannot claim the credit themselves.

Recycling calculation methodology in force

Commission Delegated Regulation (EU) 2025/606, the harmonised methodology for calculating and verifying recycling efficiency and recovered materials with a standard reporting format, comes into force.

2006 Batteries Directive repealed

Directive 2006/66/EC is repealed and Regulation (EU) 2023/1542 becomes the sole framework, though certain reporting obligations under the old Directive continue for a transitional period to ensure continuity.

Lithium-ion battery coding measures take effect

Standardised coding for lithium-ion batteries, introducing a battery identifier that supports traceability across the lifecycle. It is the identification layer the 2026 recycling measures are built on.

MIIT lithium-ion battery coding measures

First recycling efficiency deadline

Minimum recycling efficiency by weight must reach 75% for lead-acid batteries, 65% for lithium-based, 80% for nickel-cadmium and 50% for other batteries.

Section 301 tariffs rise on non-EV batteries, natural graphite and magnets

The second tranche of the USTR schedule took effect. Lithium-ion batteries for uses other than electric vehicles rose from 7.5% to 25%, and natural graphite and permanent magnets rose from zero to 25%.

California: point-of-sale fee on battery-embedded products

SB 1215 expands the Electronic Waste Recycling Act of 2003 to cover battery-embedded products, meaning devices whose battery is not designed to be easily removed by the user. Consumers pay a recycling fee at the point of sale on any new or refurbished product with an embedded battery, and the fee is set by CalRecycle. Producers must also label each product with their name or brand and the battery chemistry.

Illinois: producers must participate in an approved stewardship plan

The Portable and Medium-Format Battery Stewardship Act, signed 9 August 2024, took effect. Illinois EPA states that producers selling batteries in Illinois are now required to participate in an approved Battery Stewardship Plan. Plans were due for submission by 1 July 2025.

New Jersey: annual reporting begins

Producers must report annually to NJDEP the number of covered propulsion batteries they sell, offer for sale or distribute in or into New Jersey. NJDEP publishes a Producer Annual Reporting Form for this purpose.

Washington: battery stewardship rule takes effect

Chapter 173-905 WAC, adopted by the Department of Ecology on 16 December 2025, took effect. It implements RCW 70A.555, passed in 2023, and sets out producer definitions, plan requirements, marking rules, collection and handling safety standards, and agency fees. Ecology's 2026 plan review fee is $63,066 and its 2026 administrative fee is $357,634.

Interim Measures on retired NEV power batteries published

MIIT, with the National Development and Reform Commission, the Ministry of Ecology and Environment and other central agencies, jointly issued the Interim Measures for the Administration of Recycling and Comprehensive Utilization of Spent Power Batteries from New Energy Vehicles. They codify the State Council's 2025 Action Plan and specify eco-design and extended producer responsibility obligations for manufacturers and importers of power batteries and NEVs, a simultaneous scrapping system for vehicles and their batteries, and a digital identification management system.

Interim Measures for the Administration of Recycling and Comprehensive Utilization of Spent Power Batteries from New Energy Vehicles

EPA proposed rule on lithium battery universal waste (projected date passed)

EPA announced in October 2023 that it would create a distinct universal waste category for lithium batteries under RCRA, tailored to fire risk, and add waste solar panels to the existing rules. The regulatory agenda projected a proposed rule in February 2026 and a final rule in August 2027. That February date has now passed with no proposal published, and earlier agendas had already targeted June 2025 and December 2026, so the schedule has slipped three times. In September 2026 the House passed the BRACE Act, which would require EPA to issue a lithium-ion universal waste rule within 18 months of enactment; it is not yet law, and practitioners do not expect a proposal before early 2027.

Carbon footprint declaration, industrial batteries (deferred)

The scheduled date for the carbon footprint declaration requirement for rechargeable industrial batteries above 2 kWh. The obligation applies from this date or 18 months after the entry into force of the relevant delegated and implementing acts, whichever is the latest. Those acts have not been adopted, so the published date has passed without the obligation becoming operative.

Traceability required on e-bike parts and batteries

Under a safety reform, certified e-bike components and batteries must carry a code that traces the product back to its certification documentation, manufacturer and production batch. Newly certified products must comply from this date; products already certified move across on a later timetable.

China e-bike safety certification reform

Ministries decide to bring lithium battery products into scope

The Ministry of the Environment and METI decided to expand the Act on the Promotion of Effective Utilization of Resources to cover lithium-ion battery products, including mobile batteries, portable power supplies, heated tobacco products and electronic cigarettes. The stated purpose is to address fire risk from improper disposal while recovering valuable materials.

Act on the Promotion of Effective Utilization of Resources, scope expansion decided 10 March 2026

Interim Measures take effect: binding recycling rules begin

The Measures become enforceable, moving China from policy guidance to a mandatory compliance framework with defined obligations and administrative penalties. Automakers and battery manufacturers must build collection outlets, publish collection information and may not refuse retired batteries. Vehicles must be scrapped together with their batteries. No organisation or individual may use waste power batteries, directly or after processing, in electric bicycles or in other fields prohibited by law or mandatory standard.

Interim Measures, Articles on EPR, simultaneous scrapping and prohibited uses

Mandatory collection and recycling begins (FY2026)

Covered products are designated specified recyclable products, and producers and importers above set volume thresholds must collect them, including through in-store or public collection boxes. Reported thresholds are more than 1,000 mobile batteries, 10,000 smartphones or 300,000 heated tobacco devices a year. Implementation runs through cabinet orders during the fiscal year, so individual obligations commence on their own dates. This replaces the voluntary JBRC collection scheme, which has operated since April 2017.

Act on the Promotion of Effective Utilization of Resources, implementing cabinet orders, FY2026

CPSC proposes a mandatory safety standard for micromobility batteries

CPSC published a notice of proposed rulemaking at 91 FR 38162 covering lithium-ion batteries in e-bikes, e-scooters, self-balancing scooters, e-skateboards and e-unicycles, and in battery management systems, chargers, user-replaceable packs, aftermarket chargers and conversion kits. It would make UL 2849, UL 2272 and UL 2271 mandatory, but with modifications including tamper-resistant enclosures and additional charging and reverse-polarity testing. Written comments closed on 24 August 2026 and CPSC heard oral presentations on 21 October 2026. No final rule has been issued; if one is, compliance would be required 180 days after it is published.

Washington: deadline for the stewardship organisation to submit its plan

A battery stewardship organisation must submit its plan to Ecology for approval. The plan must identify the collection network, participating producers and brands, transporters and processors, funding, performance goals and safety procedures.

GB 38031-2025 EV battery safety standard takes effect

The mandatory national standard Safety Requirements for Power Batteries Used in Electric Vehicles applies to new vehicle type approvals from this date. Battery systems must not catch fire or explode during thermal runaway, with a warning still required and smoke not harming occupants. The standard adds a battery bottom impact test and an external short circuit test after 300 fast-charge cycles, and replaces the 2020 edition, which required a five minute warning before a fire. Compliance is required for vehicle type approval, so it decides market access in China.

GB 38031-2025, Safety Requirements for Power Batteries Used in Electric Vehicles, MIIT

Illinois: retailers may not sell batteries from non-participating producers

Retailers are prohibited from selling covered batteries and battery-containing products whose producer is not participating in an approved stewardship programme. This shifts enforcement onto the shelf, so a producer that has not joined loses its route to market rather than simply risking a penalty.

Commission due diligence guidelines due (date passed)

The regulation required the Commission to publish guidelines supporting the battery due diligence obligations by this date, ahead of the obligations themselves applying from 18 August 2027. The date has passed with no published guidelines found. Companies building their due diligence systems are, for now, working from the regulation's text and existing OECD guidance.

Presidential Determination on recoverable critical minerals

Presidential Determination No. 2026-19, issued under Section 101 of the Defense Production Act of 1950, found that certain recoverable critical minerals and materials are scarce and essential to the national defense, and directed the Department of Commerce to act. It delegates authority to restrict exports of black mass, end-of-life rare earth permanent magnets, swarf, and other waste and scrap containing critical minerals. Published at 91 FR 50,465 on 4 August 2026.

BIS temporary final rule published, exception requests open

BIS published a temporary final rule, DPAS Directive Allocation Order and Additional Requirements for Recoverable Critical Minerals and Materials, at 91 FR 50,701. It was effective immediately on publication, with the allocation order itself starting 21 days later. BIS relied on the Defense Production Act to forgo the usual notice and comment process. Requests for adjustments and exceptions may be submitted on a rolling basis from this date.

General labelling requirements (deferred)

Batteries placed on the market must carry a label with the general information in Annex VI Part A, including the manufacturer, battery category, chemistry and capacity information, with the information on the packaging or documentation where the battery is too small. The date applies from 18 August 2026 or 18 months after the entry into force of the Article 13 implementing act on harmonised labelling specifications, whichever is the latest. That act had still not been adopted at the end of October 2026, so the obligation was not operative on 18 August 2026; it will apply 18 months after the act enters into force.

Recycled content methodology delegated act due (date passed)

The deadline for the Commission to adopt the delegated act establishing the methodology for calculating and verifying the percentage of recycled cobalt, lithium, lead and nickel in batteries under Article 8. The JRC study published on 13 July 2026, commissioned by DG ENV and DG GROW, provides the technical basis, including the proposed mass balance approach. The deadline has passed without an adopted act. On 12 August 2026 the Commission published a draft delegated regulation for a four-week feedback period (Ares(2026)7823470); it is not yet adopted. The recycled content disclosure and minimum content dates in 2028 and 2031 run from the act when it arrives, applying 24 months after its entry into force where that is later than the published dates.

EV carbon footprint threshold delegated act due (date passed)

The deadline for the Commission to adopt the delegated act setting the maximum life cycle carbon footprint threshold for electric vehicle batteries. The date has passed with no adopted act found; the underlying carbon footprint methodology act for EV batteries, published in draft in April 2024, had still not been adopted at the end of September 2026. Later deadlines follow for rechargeable industrial batteries by 18 February 2028, LMT batteries by 18 February 2030 and industrial batteries with external storage by 18 February 2032.

Deadline for written comments on the CPSC micromobility rule

Written comments on the proposed rule, and on its Paperwork Reduction Act elements, must be received by this date under docket CPSC-2025-0012. The proposed effective date is 180 days after publication of a final rule, applying to products manufactured after that date, though CPSC has invited comment on setting a later date. Companies already certified to the current UL standards should not assume their products would pass.

Black mass: 100% domestic sales requirement takes effect

US persons selling covered black mass and tungsten waste and scrap must allocate 100 per cent of monthly sales to US persons, unless BIS has granted an adjustment or exception in advance. Black mass is defined as any shredded lithium-ion battery scrap containing cathode material, including lithium, cobalt, nickel and manganese, anode material such as graphite and silicon, or other residual battery cell materials, within the covered Schedule B codes. The order runs to 27 August 2027 unless adjusted or extended, and BIS will enforce it with US Customs and Border Protection.

Battery consumption tax begins at 2 percent

A 2 percent consumption tax applies to mercury-free primary batteries, nickel-metal hydride, lithium primary, lithium-ion and all-vanadium redox flow batteries, ending an exemption that had run since February 2015. Sodium-ion batteries, solid-state batteries and fuel cells are exempt from this date to 31 December 2028, as are perovskite, tandem and gallium arsenide photovoltaic cells. Announced 17 July 2026.

Ministry of Finance, General Administration of Customs and State Taxation Administration announcement, 17 July 2026

California: Rechargeable Battery Recycling Act of 2006 becomes inoperative

The 2006 Act becomes inoperative on this date under AB 2440, and is repealed on 1 January 2027. The Cell Phone Recycling Act of 2004 follows a year later, becoming inoperative on 30 September 2027 and repealed on 1 January 2028.

New South Wales mandatory battery stewardship scheme begins

Australia's first mandatory product stewardship scheme for batteries. Brand owners that supply regulated batteries in or into New South Wales, including power banks and e-bike and e-scooter batteries under 5 kg, must join a product stewardship organisation with an EPA agreement, or meet the requirements themselves. Batteries must be recovered and recycled wherever practicable, to the NSW Batteries Product Stewardship Recycling Standard. Penalties run to AU$880,000.

Product Lifecycle Responsibility Regulation 2026 (NSW), under the Product Lifecycle Responsibility Act 2025

Comments due on the black mass allocation framework

Comments are due on the temporary final rule's framework, and on whether sales requirements should be extended to additional materials, consistent with the underlying Presidential Determination. This is the route by which the order could be widened beyond black mass and tungsten.

Section 45X: same-facility and domestic content test for integrated components

For tax years beginning after 31 December 2026, a taxpayer may treat a primary component as sold to an unrelated person only where it is produced in the same manufacturing facility as the secondary component it is incorporated into, the secondary component is sold to an unrelated person, and at least 65% of the total direct material costs of producing that secondary component are attributable to primary components mined, produced or manufactured in the United States. This is a domestic content test, not simply an integration threshold.

California: AB 2440 stewardship regime in force, with recycling efficiency rates

The Responsible Battery Recycling Act of 2022 takes full effect. Producers, individually or through a stewardship organisation, must run a programme for the collection and recycling of covered batteries, with a stewardship plan approved by CalRecycle in consultation with the Department of Toxic Substances Control. From this date the programme must achieve a minimum recycling efficiency rate of 60% for rechargeable batteries and 70% for primary batteries. Unlike most state battery EPR laws, AB 2440 covers all chemistries.

Pre-disposal performance evaluation for used batteries

The government has said it will introduce performance evaluation of EV batteries before disposal, classifying each battery for remanufacture, reuse in another application, or recycling. Legislative proposals to define used and remanufactured batteries and to assign the assessment role were before the National Assembly. Treat the timing as indicative until the enabling amendment is passed.

Proposed amendments to the Motor Vehicle Management Act

New Jersey: permanent labelling requirement, currently held back

The Act requires all propulsion batteries sold in New Jersey from this date, embedded in a vehicle or not, to carry a permanent label. The detail is to be set by NJDEP rules. NJDEP says it intends to fold labelling into its wider rulemaking on battery management plans, and cannot adopt those rules until the needs assessment is complete, so it is not requiring permanent labels until rules are in place. The statutory date stands, but the obligation is not yet operative.

New Jersey: landfill disposal ban on propulsion batteries

Disposal of propulsion batteries in New Jersey landfills is banned. Solid waste collectors and facilities may not knowingly accept them for disposal unless authorised by NJDEP. Producers remain responsible for any used battery they produced if it is offered back to them by the current owner.

Battery passport, and portable removability

Each EV battery, LMT battery and industrial battery above 2 kWh placed on the market must carry a digital battery passport, accessed via QR code (Article 77). From the same date, portable batteries in appliances must be readily removable and replaceable by the end user (Article 11). SLI batteries are not given a passport deadline.

Sodium-ion energy storage safety standard takes effect

GB/T 48072-2026 sets safety requirements for sodium-ion cells and batteries used in electrical energy storage systems. It was published on 28 August 2026. Meeting applicable national standards is also a condition of the consumption tax exemption for sodium-ion batteries.

GB/T 48072-2026, safety requirements for sodium-ion batteries for electrical energy storage

EV battery material recovery reaches 90 percent (FY 2026-27)

Material recovery targets for EV batteries rise to 90 percent of dry battery weight for the financial year ending 31 March 2027, up from 70 percent in FY 2024-25. Lead-acid battery collection targets also reach 90 percent. Targets are set out in the progressive schedule to the 2022 Rules.

Battery Waste Management Rules 2022, Schedule II

Photovoltaic cell consumption tax begins at 2 percent

Photovoltaic cells become subject to a 2 percent consumption tax, rising to 4 percent from 1 April 2028. Perovskite, tandem and gallium arsenide cells remain exempt to the end of 2028. Included here because the same announcement governs both batteries and PV, and storage projects are commonly procured alongside solar.

Ministry of Finance, General Administration of Customs and State Taxation Administration announcement, 17 July 2026

Washington: programme begins and the retail prohibition bites

Collection sites begin accepting covered portable batteries, and retailers are prohibited from selling or distributing covered portable batteries or battery-containing products unless the producer participates in an approved plan. Portable means rechargeable batteries under 11 pounds and under 300 watt-hours, and single-use batteries under 4.4 pounds.

GB 38031-2025 extends to models already type approved

Vehicle models that already hold type approval must comply with GB 38031-2025 from the 13th month after the standard took effect. From this date the no fire, no explosion requirement covers the existing fleet of approved models as well as new ones.

GB 38031-2025, transition arrangements

California: e-waste reporting requirements begin

The expanded reporting requirements under SB 1215 take effect. Manufacturers of covered electronic devices, including battery-embedded products, must report put-on-market data to CalRecycle annually. Producers must also notify retailers of the products subject to the recycling fee by 1 July each year.

Colorado: propulsion battery providers must register

Senate Bill 26-003, End-of-Life Management of Electric Vehicle Batteries, signed in June 2026, expands the state's Battery Stewardship Act to cover propulsion batteries, the packs that power electric and hybrid vehicles. It is the first state EPR law aimed specifically at EV batteries. On or before 1 July 2027, anyone selling, offering for sale or distributing propulsion batteries, or vehicles containing them, in or into Colorado must register with the Department of Public Health and Environment.

Colorado: retailers may only sell batteries from participating producers

Under the Battery Stewardship Act (Senate Bill 25-163, 2025), producers of covered batteries must join and fully fund a battery stewardship organisation, which submits its programme plan to the Department of Public Health and Environment. By 1 August 2027, retailers in Colorado may only sell batteries from manufacturers and brands participating in the approved plan. The department states that collection sites for most common household and smaller rechargeable batteries follow by October 2028. Large lead-acid batteries over 11 pounds, embedded non-removable batteries, EV batteries and medical device batteries are excluded.

EPA final rule on lithium battery universal waste (projected)

The agenda date for a final rule, which is likely to slip because the proposed rule has not yet been published. It would not take effect in an authorised state until that state adopted it, though tightened lithium battery standards would likely count as more stringent requirements that authorised states must adopt. There is an open question about preemption under the Battery Act.

Supply chain due diligence begins

Due diligence obligations on the sourcing of cobalt, lithium, nickel and natural graphite take effect. Originally 18 August 2025, postponed by two years by Regulation (EU) 2025/1561.

Black mass allocation order expires

The Directive Allocation Order expires one year after taking effect, unless BIS adjusts or extends it. BIS may change the dates at any time, and has signalled that further directives on other recoverable critical minerals and materials are possible. Requests for adjustments and exceptions may be submitted up to this date.

Battery consumption tax rises to 4 percent

The rate on the covered battery types rises from 2 percent to the full 4 percent, matching the standard rate that applied to lead-acid batteries and other products before the 2015 exemption list. Sodium-ion, solid-state and fuel cells remain exempt to 31 December 2028.

Ministry of Finance, General Administration of Customs and State Taxation Administration announcement, 17 July 2026

Material recovery targets begin

Minimum recovery of specific materials reaches 90% for cobalt, copper, lead and nickel, and 50% for lithium.

Washington: batteries must be marked with the producer's brand

Retailers are prohibited from selling a large format battery, a covered battery or a battery-containing product unless it meets the marking requirements in WAC 173-905-310. Markings must be permanent, clearly visible and legible.

Illinois: disposal ban on covered batteries

Covered batteries may no longer be placed in regular refuse or recycling in Illinois.

Wisconsin: disposal and burning ban on covered batteries

2025 Wisconsin Act 170, enacted 2 April 2026, creates a battery stewardship programme administered by producer-funded battery stewardship organisations under Department of Natural Resources oversight, covering portable and medium-format batteries that are easily removable. From 1 January 2028, no person may dispose of or burn a covered battery in a solid waste disposal facility. Producers must participate in an approved battery stewardship plan to keep selling covered batteries and battery-containing products in the state.

Lithium-ion collection reaches 70 percent (FY 2027-28)

Producers must ensure 70 percent collection of the lithium-ion and EV batteries they placed on the market, measured against sales in prior years. The obligation can be met by collecting batteries or by purchasing EPR certificates from CPCB-authorised recyclers through the EPR portal. Shortfalls attract Environmental Compensation, priced by chemistry.

Battery Waste Management Rules 2022, Schedule II, and the CPCB EPR framework

Domestically recycled content becomes mandatory (FY 2027-28)

From FY 2027-28, batteries manufactured in India must incorporate a minimum percentage of recycled materials recovered from end-of-life batteries processed within India, scaling upward over the following years. Exact percentages are notified by the CPCB in advance. The domestic recovery condition is what distinguishes this from the EU recycled content thresholds, which do not specify where the material was recovered.

Battery Waste Management Rules 2022 as amended, recycled content provisions

Photovoltaic cell consumption tax rises to 4 percent

The consumption tax on covered photovoltaic cells, which begins at 2 percent on 1 April 2027, rises to 4 percent. Perovskite, tandem and gallium arsenide cells are exempt to 31 December 2028.

Ministry of Finance, General Administration of Customs and State Taxation Administration announcement, 17 July 2026

Washington: first annual report due from the stewardship organisation

By 1 June 2028, and each 1 June after, the stewardship organisation must report to Ecology on the preceding calendar year, covering collection, transport and recycling methods and the processing technology used.

Nebraska: producers must join a Battery Stewardship Organization

The Safe Battery Collection and Recycling Act (LB36), signed 20 May 2025, establishes a producer-funded stewardship programme for portable and medium-format batteries. Beginning in 2028, producers must join a state-approved Battery Stewardship Organization to sell batteries in Nebraska, free statewide collection must be available including rural areas, and covered batteries may no longer be landfilled or incinerated. The Nebraska Department of Environment and Energy approves and monitors programme plans. Check the Act for the precise commencement date within 2028 before relying on it.

Recycled content disclosure begins (date depends on delegated act)

Recycled content disclosure obligations start, covering the recycled cobalt, lead, lithium and nickel present in industrial, SLI and EV batteries. The operative date is tied to the entry into force of the Article 8 methodology delegated act, applying from this date or 24 months after that act, whichever is the latest.

Oregon: producer responsibility organisation plan due to DEQ

House Bill 4144, signed 7 April 2026, creates a battery extended producer responsibility programme covering certain portable and medium-format batteries up to 25 pounds. The producer responsibility organisation must submit its battery producer responsibility programme plan to the Department of Environmental Quality by 1 September 2028, including the participating producers and brands and the statewide collection network.

Exemption for sodium-ion, solid-state and fuel cells expires

The temporary consumption tax exemption granted to sodium-ion batteries, solid-state batteries, fuel cells and advanced photovoltaic cell types runs out. Unless extended, those chemistries move onto the standard rate from 1 January 2029.

Ministry of Finance, General Administration of Customs and State Taxation Administration announcement, 17 July 2026

Washington: medium-format batteries join the collection programme

Collection sites begin accepting medium-format batteries: rechargeable batteries of 11 to 25 pounds or 300 to 2,000 watt-hours, and single-use batteries of 4.4 to 25 pounds. This is the band that captures e-bike and scooter packs.

Washington: retail prohibition extends to medium-format batteries

Retailers may not sell or distribute covered medium-format batteries or battery-containing products unless the producer participates in an approved plan.

Colorado: education and outreach plan required to sell, labelling begins, landfill ban

Under SB26-003, a propulsion battery provider or group of providers must submit an education and outreach plan to the Department of Public Health and Environment on or before 2 January 2029. On and after 1 July 2029, a provider may not sell, make available for sale or distribute a propulsion battery in or into the state unless it has submitted a compliant plan. On and after the same date, providers must label propulsion batteries with the information the act specifies, and disposal of propulsion batteries at solid waste disposal sites and facilities is prohibited. Providers must also maintain at least one public website carrying the plan's information, collect certain unwanted propulsion batteries and ensure their responsible management.

Oregon: producers must participate to sell, and the programme begins

From 1 July 2029, producers of covered batteries or battery-containing products may not sell, offer for sale or distribute them in or into Oregon unless they participate in the producer responsibility organisation, and the statewide collection and recycling programme begins. The law also bans disposal of removable lithium-ion batteries in mixed municipal solid waste.

Washington: marking must show chemistry and the crossed-out bin symbol

The second stage of the marking rules. Batteries must carry the crossed-out wheeled bin symbol and information on battery chemistry, meaning the names, symbols or codes recognised by ANSI, IEC or SAE for the electrochemical system.

Colorado: first annual report due from propulsion battery providers

On or before 1 June 2030, and each 1 June after, a propulsion battery provider must submit an annual report to the Department of Public Health and Environment covering the preceding calendar year's responsible management of the propulsion batteries it collected.

Second recycling efficiency deadline

Minimum recycling efficiency by weight rises to 80% for lead-acid batteries and 70% for lithium-based batteries.

Section 45X: critical minerals credit phases out

Under pre-OBBBA law there was no phase-out for applicable critical minerals. The credit now phases out across 2031 to 2033. Metallurgical coal, newly designated a critical mineral, ends after 2029 and at a reduced rate.

Colorado: minimum critical mineral recovery rates for propulsion battery recycling

SB26-003 sets per-mineral recovery rates for propulsion battery recycling rather than a single aggregate rate, calculated annually on a mass balance approach at facility level, with the recovered material identified as elemental, compound or intermediate form. From 2031 the minimums are 90% for cobalt, 90% for nickel and 50% for lithium. From 2035 the lithium rate rises to 80%, with cobalt and nickel staying at 90%. Check the act for the precise commencement dates within 2031 and 2035 before relying on them.

Recycled content minimums begin

Batteries must meet minimum recycled content: 85% for lead, 16% for cobalt, 6% for lithium and 6% for nickel, applying to industrial, SLI and EV batteries.

Second material recovery deadline

Minimum material recovery rises to 95% for cobalt, copper, lead and nickel, and 80% for lithium.

Second recycled content tier

Minimum recycled content rises to 26% for cobalt, 12% for lithium and 15% for nickel. The lead threshold does not rise and remains at 85%.

New Jersey: battery management plans due 180 days after rules are adopted

Producers must fund, develop and implement an NJDEP-approved management plan for the collection and management of used propulsion batteries. Plans are due within 180 days of NJDEP adopting programme regulations, and NJDEP cannot adopt those regulations until its needs assessment is complete. The clock therefore has not started, and the deadline will be set by an event rather than a calendar date. Plans must then be reviewed at least every five years.

California: CalRecycle implementing regulations for AB 2440

AB 2440 directs CalRecycle, in consultation with the Department of Toxic Substances Control, to adopt implementing regulations with an effective date no earlier than 1 April 2025. Formal rulemaking had been expected to begin in early 2026, with the timeline for plan submission and approval tied to when the regulations become effective. Until they are adopted, the operational detail of the programme is not settled.

Maine: battery stewardship deadlines run from plan approval

LD 474, An Act to Establish a Stewardship Program for Primary and Rechargeable Batteries, was signed in April 2026. Its deadlines are keyed to the Department of Environmental Protection's approval of a stewardship plan rather than to calendar dates: producers and retailers must participate in the approved programme within six months of plan approval, and covered products may not be sold or distributed in or into Maine from two years after approval unless the producer or retailer participates. Press reporting indicates the requirement extends to products with internal batteries in 2030. The clock starts when DEP approves a plan.