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Understanding California’s SB 1215 & AB 2440: A Guide to the Essentials

California passed two new legislative measures in 2022, SB 1215 and AB 2440, to address electronic waste management, specifically two different aspects of battery management. The new regulations are soon to take effect so we have set out to highlight some of the key points of these laws to help manufacturers, recyclers, and collectors understand their responsibilities and upcoming changes.

Overview of the Legislation

SB 1215

  • Scope: Expands what is considered “Covered Electronic Waste” (CEW) in CalRecycle’s existing program, specifically devices with embedded batteries.
  • Objective: To define battery embedded waste and improve recycling and proper disposal of this increasingly significant category of e-waste. Establish clearer guidelines, facilitate reporting, and promote product stewardship.
 

AB 2440

  • Scope: Focuses specifically on battery recycling and stewardship programs.
  • Objective: Complements SB 1215 by establishing clear battery recycling obligations for loose and user-serviceable batteries.
 

Who is affected by SB 1215?

  • Manufacturers will have labeling and reporting requirements for products containing embedded batteries.
  • Recyclers will have new standards for recycling battery embedded electronics and additional data reporting obligations for reimbursement
  • Collectors must prepare for handling, accepting and reporting a new category of covered electronic waste
 

And by AB 2440?

  • Manufacturers must join specific stewardship programs for batteries and create detailed recycling reports.
  • Recyclers will have clear guidelines for specific procedures from manufacturers and stewardship organizations
  • Collectors, which will include a large number of battery retailers based on the retailer’s number of locations, will have specified collection practices and obligations.
 

Similarities

  • Both aim to enhance environmental responsibility through recycling and product stewardship.
  • Both will increase transparency and accountability through detailed reporting requirements
 

Key Dates for SB 1215

  • July 1, 2025: Manufacturers of battery embedded products must list covered and exempt products in an annual notice
  • October 1, 2025: CEW recycling fees will be established for covered products
  • January 1, 2026: Consumers will pay the recycling fee at purchase. Additionally the covered products must be labeled with the manufacturers’ name and information identifying the battery chemistry. This information can also be made available online.
  • April 1, 2026: CalRecycle will begin accepting payment claims for CEW collected after January 1, 2026
  • Additional dates indicate when CalRecycle may make adjustments and implement reporting requirements for manufacturers.
 

AB 2440

  • April 1, 2027:Producers of batteries must participate in a CalRecycle-approved stewardship plan
  • AB 2440 also is set to replace the Rechargeable Battery Recycling Act of 2006 and the Cell Phone Recycling Act of 2004 on Jan. 1, 2027, and Jan. 1, 2028, respectively
 
 

Additional Resources

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