Regulatory Compliance

Managing Battery Regulations Throughout the Life Cycle

Addressing Industrial Battery Regulations

Numerous complex, ever-changing regulatory requirements affect the transportation, handling, storage and disposal of batteries throughout their life cycle. When a battery reaches the end of its useful life and is destined for disposal, it is considered waste and additional regulations apply.

A common misconception among those involved with deploying battery energy storage systems is that the liabilities associated with managing their batteries is something they do not need to worry about for several years. The reality is that a number of regulatory requirements apply throughout the entire life cycle.

Regulatory Obligations in the U.S.

At the beginning of their life and throughout the full life cycle, most batteries used in energy storage applications are considered hazardous material and, as such, are regulated by the U.S. Department of Transportation Hazardous Material Regulation (HMR) under Title 49 of the Code of Federal Regulations (CFR), Subchapter C. In addition to regulating the packaging, marking, labeling and transporting of hazardous materials, HMR also contains requirements for training, safety, security and recordkeeping that apply to anyone who handles hazardous material.

Battery Disposal and Recycling Regulations

Various lithium ion battery disposal regulations apply when a battery reaches its end of life. At this point, the battery is considered waste and hazardous waste regulations also apply. The U.S. Resource Conservation and Recovery Act (RCRA) regulates the generation, transportation, treatment, storage and disposal of hazardous solid wastes under Title 40 of the CFR, parts 262 through 273.

The U.S. EPA created universal waste regulations to ease the burden of managing hazardous waste, promoting the collection and recycling of commonly generated waste, including batteries. Intact batteries can be managed as universal waste, while batteries that are not intact, such as a battery that has been damaged to the point of leaking electrolytes, must be managed as fully regulated hazardous waste.

Renewance Helps You Stay Compliant

If you have deployed a battery energy storage system and are not aware of the associated obligations, you are at risk of noncompliance. Penalties for noncompliance can be severe and can include civil and criminal penalties as well as significant reputational risk. Renewance has the expertise and tools to help you manage these regulations so you remain compliant.

Renewance has comprehensive knowledge of the applicable regulations, and we have operationalized this knowledge in our Renewance Connect™ digital platform. This platform not only provides automated alerts that notify you of applicable regulatory requirements, but it also acts as a repository for all relevant records so you remain fully compliant.

Manages time- and quantity-based on-site accumulation limits
Triggers alerts for impending regulatory obligations
Provides full recordkeeping to meet retention obligations

The Renewance Connect™ platform also connects you with highly qualified transportation and recycling and repurposing partners, while ensuring that you receive the most competitive rates to minimize the end-of-life financial liabilities.