Revised On: Nov. 6, 2023 - 10:00 a.m.

Properly disposing of spent or waste batteries helps protect public health and the environment. Disposal methods depend on a battery’s chemistry. Some batteries, such as single-use alkaline batteries, are easy to remove and dispose of. Other batteries, such as rechargeable lithium-ion, can be more difficult to remove and even dangerous if not handled properly. The following guidance is intended to help the regulated community by providing general information and guidance on universal waste battery management.

For battery type and disposal method guidance for homeowners, visit the Environmental Protection Agency (EPA) used household battery webpage or read ADEQ's at-home guide | Visit EPA Page > | View ADEQ Guide English > | Spanish >

How is a battery defined according to the Resource Conservation and Recovery Act (RCRA)?

A battery is defined by the Code of Federal Regulations (CFR) as a device consisting of one or more electronically connected electrochemical cells which is designed to receive, store, and deliver electric energy | See 40 CFR 273.2 >

An electrochemical cell is a system consisting of an anode, cathode and an electrolyte, plus such connections (electrical and mechanical) as may be needed to allow the cell to deliver or receive electrical energy. The term "battery" also includes an intact, unbroken battery from which the electrolyte has been removed.

What is the difference between a waste battery and a universal waste battery?

Once “spent” or “discarded” (the facility no longer has a use for it), a battery becomes a waste battery. The battery may be RCRA hazardous waste if it exhibits a characteristic of hazardous waste (D001 — ignitability, D002 — corrosivity, D003 — reactivity, or D004 to D043 — toxicity). For example, if the battery is damaged or leaking, the battery is likely considered hazardous waste and subject to specific regulations for proper disposal. Depending on the battery design, this may also include heavy metal classifications.

If the battery is fully intact and non-leaking, the battery may be managed as universal waste | See 40 CFR § 273 >

Universal waste is a sub-category of hazardous waste. A battery is considered universal waste if it meets regulatory applicability requirements and the definition in regulation | See 40 CFR § 273.2 > | See 40 CFR § 273.9 >

Universal waste batteries are not:

• spent lead-acid batteries managed under 40 CFR § 266 | Learn More >
• batteries that are not yet waste (i.e., not disposed of)
• batteries that do not exhibit a characteristic of hazardous waste (for example, a used, single-use alkaline battery, which often does not exhibit hazardous characteristics)

What can a universal waste handler do?

If you are a small quantity handler (SQH) or large quantity handler (LQH), you can store universal waste batteries for up to a year. If you are a SQH, you may only accumulate up to 5,000 kg at any time (this is the quantity limit for SQHs for accumulating all universal wastes, such as aerosol cans and lamps).

As long as the casing of each individual battery cell is not breached and remains intact and closed (except in the event that you open a cell to remove electrolyte, but then immediately close it), SQHs and LQHs may do the following to universal waste batteries:¹

• Sort batteries by type
• Mix battery types in one container
• Discharge batteries to remove electric charge
• Regenerate used batteries
• Disassemble batteries or battery packs into individual batteries or cells
• Remove batteries from consumer products
• Remove electrolytes from batteries

SQHs and LQHs removing electrolytes or generating solid waste as a result of the handling activities must determine if the waste exhibits hazardous characteristics and manage it appropriately.

What is the difference between a universal waste handler and a recycler?

If your facility accepts universal waste batteries and manages the batteries in ways other than as specified above, you are likely classified as a universal waste destination facility, and may also be classified as a recycler | See 40 CFR § 273 >

Destination facilities are subject to the full requirements of a hazardous waste treatment, storage, and disposal facility.2 If your facility is recycling a particular universal waste in compliance with the recycling exemptions, you must be able to prove the recycling activities are legitimate and comply with ADEQ’s substantive policy regarding storage prior to recycling | See 40 CFR § 261.6(c)(2) > | View Substantive Policy >

This policy states that a facility cannot store waste batteries for longer than a single operational day, prior to recycling, without a hazardous waste permit for storage.

To reduce the incidence of noncompliance, we recommend that waste battery recycling facilities contact ADEQ’s hazardous waste permitting team to receive a determination on the legitimacy of the recycling operation | Email Permitting Team >

ADEQ can assist you in achieving compliance with recycling requirements and our substantive policy on storage prior to recycling. Note that if you are storing batteries in a facility that is on a contiguous property to your recycling facility (i.e., your long-term storage warehouse is on the same property as your processing facility), you will likely need a hazardous waste storage permit | Learn More >

Best Management Practices

• Make sure batteries are individually packed or have taped terminals to avoid short-circuiting: For those areas managing batteries that are ignitable or reactive, or are damaged, partially reclaimed, or include exposed cells, ensure that the potential for electrical discharge or sparking is minimized. Use appropriate means and measures such as spark-proof tools, and grounding straps to ensure that the areas are properly grounded.
• Store batteries in temperature-controlled areas and as a best management practice, do not stack large batteries more than two high to avoid thermal activations or damage.
• Do not store batteries in metal (or otherwise conductive) containers.
• Minimize the potential for batteries to be dropped, crushed, or punctured.
• Have contingency plans for handling damaged batteries and for fire responses (will vary based on the type of battery being stored or processed). This could include isolating damaged batteries, methods for detecting battery damage, testing and calibrating fire response equipment, etc.
• Have an up-to-date, properly coded and designed fire protection system that is appropriate for your facility’s operations and batteries. Contact your local fire department and building review agency 

Industry Waste Battery Disposal

Fact Sheet | English > | Spanish >

1Per 40 CFR § 273.13(a) | View > & 40 CFR § 273.33(a) | View >
2Per 40 CFR § 273 Subpart E | View >