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California Embedded Battery Recycling Fee Kicks in January 1, 2026

By Sheila Millar & Anushka R. Stein on December 17, 2025
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Starting January 1, 2026, retailers of covered battery-embedded (CBE) products in California must charge consumers a CBE Waste Recycling Fee at point of purchase or cover the costs of the fee themselves. Per regulations finalized last week, the fee will be 1.5% (capped at $15) of the retail sales price of a CBE product. Proposed regulations that would clarify related requirements are still pending as of this writing.

The CBE Waste Recycling Fee is required under SB 1215, which we previously wrote about here. To review, CBE products are those that contain batteries that are “not designed to be easily removed from the product by the user of the product with no more than commonly used household tools.” These do not include products that incorporate video display devices measuring greater than four inches diagonally (such products are separately subject to California’s Covered Electronic Waste (CEW) Recycling Fees) or standalone batteries (which will be covered by future requirements under AB 2440, as we wrote about here). However, the scope of CBE products remains unclear since the proposed regulations add new definitions, including one for “commonly used household tools.” If finalized in their current form, these definitions could affect how broadly the fee applies.

Read the full article here.

Photo of Sheila Millar Sheila Millar

Sheila A. Millar is a partner at Keller and Heckman LLP, where she represents businesses and trade associations on a variety of public policy and regulatory issues, including privacy, data security, cybersecurity and advertising matters, as well as product safety issues. She has…

Sheila A. Millar is a partner at Keller and Heckman LLP, where she represents businesses and trade associations on a variety of public policy and regulatory issues, including privacy, data security, cybersecurity and advertising matters, as well as product safety issues. She has been involved in a variety of audit and compliance projects, including, among other issues, privacy and data security audits, and is experienced in providing crisis management legal support to a variety of national and international companies and associations.

Ms. Millar is a frequent speaker on regulatory and public policy matters, and has authored many articles. Ms. Millar is one of the vice chairs of the International Chamber of Commerce (ICC) Marketing and Advertising Commission, and chair of its Working Group on Sustainability, where she spearheaded the development of the ICC Framework Guides on Environmental Marketing Claims.

Ms. Millar is AV® PreeminentTM Rated by Martindale-Hubbell and for the eigth consecutive year was selected by her peers for inclusion in The Best Lawyers in America® 2018 for her work in practicing Advertising Law. She has also received the distinguished honor of Advertising Law “Lawyer of the Year” 2014 in Washington, DC by Best Lawyers®, and was awarded Advertising and Marketing Lawyer of the Year USA by Finance Monthly for their Finance Monthly Global Awards 2017.

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Photo of Anushka R. Stein Anushka R. Stein
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  • Posted in:
    Environmental and Climate
  • Blog:
    Consumer Protection Connection
  • Organization:
    Keller Heckman
  • Article: View Original Source

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