Introduction

On September 20, 2026, Governor Newsom signed California Senate Bill (SB) 501. The law expands California’s Responsible Battery Recycling Act of 2022 to include medium-format batteries, found in products such as e-bikes, portable generators, electric lawn and garden equipment, and UPS backup systems. SB 501 does not substantively change producers’ core obligations to participate in and fund battery stewardship.

The Responsible Battery Recycling Act of 2022 has not yet been implemented in California, pending CalRecycle’s finalization of implementing regulations (which have been proposed).

Key Changes

• “Covered batteries” now includes medium-format batteries, in addition to the smaller-format batteries.
• Stewardship programs must address format-specific collection networks, and program operators must demonstrate recycling performance.
• A device provided by a producer solely to prevent theft or tampering with the battery (e.g., a key, application, or other locking device) does not prevent the battery from being considered designed to be easily removed by a product user.

Covered Batteries and Battery-Containing Products

The law continues to cover qualifying batteries sold separately, designed to be easily removed from a product by the user with no more than common household tools, or packed with—but not installed in—the product they are intended to power. SB 501, however, expands the framework to include medium-format batteries in addition to small-format batteries.

SB 501 also clarifies when a battery is considered easily removable. A key, application, or other locking device provided by the producer does not prevent a battery from qualifying as easily removable if the producer warrants that the device serves solely to prevent theft or third-party tampering and does not inhibit the consumer’s ability to remove, replace, or recycle the battery.

Producer and Retailer Requirements

Producer obligations remain largely unchanged. Producers must still comply with the law’s extended producer responsibility requirements individually or through a stewardship organization, and provide CalRecycle with a list of all covered batteries and brands of covered batteries that they sell, distribute for sale, import for sale, or offer for sale in or into California.

SB 501, however, modifies retailers’ collection obligations. Retailers with five or more locations in California must continue to make all locations permanent collection sites, but those locations must now collect only small-format batteries. A retailer is not required to collect medium-format batteries unless the location otherwise qualifies as a medium-format collection site under the stewardship plan.

Stewardship Plans

Program operators – individual producers or a stewardship organization – must still develop and submit a stewardship plan addressing the collection, transportation, recycling, and safe and proper management of covered batteries. Under SB 501, a stewardship plan can now cover single-format batteries, medium-format batteries, or both, but the program operator must specify the format(s) covered.

Additionally, program operators must now annually demonstrate achievement of a minimum recycling efficiency rate of 60% for rechargeable batteries and 70% for non-rechargeable batteries and primary batteries.

Looking Ahead

Companies should reevaluate their product portfolios to assess whether the expanded scope brings new products within the law and whether the revised “easily removable” standard affects prior applicability assessments.

Businesses should also monitor CalRecycle’s rulemaking. CalRecycle held a public workshop earlier this summer regarding proposed regulations. Given SB 501 amendments, CalRecycle may restart the rulemaking process to include these changes.

California is one of more than a dozen states that have enacted EPR laws covering various types of batteries in recent years. Legislation is also advancing in Congress that would require EPA to change Universal Waste Rules for Lithium-ion Batteries.

Beveridge & Diamond’s Battery industry group has extensive experience with a full range of environmental and related regulatory issues associated with recycling of batteries and other products containing critical minerals, including requirements for management of hazardous wastes, transboundary movement of such wastes, transport of dangerous goods, extended producer responsibility, toxic substances control, and hazard. The firm also led a webinar series on environmental issues across the lifecycle of batteries. With offices in Seattle and San Francisco, our lawyers in the Consumer Products and Product Stewardship, Global Supply Chains practices work with West Coast, U.S., and multinational companies that make, distribute, transport, or sell consumer products in a hyper-competitive and evolving consumer goods market. For more information, please contact the authors.