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  • While universal wastes should be sorted by type, different kinds of batteries may be mixed if desired.
  • Not all lithium batteries exhibit the characteristics of hazardous waste.

40 CFR 273.9 defines a battery as a device consisting of one or more electrically connected electrochemical cells which is designed to receive, store, and deliver electric energy. 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.

Some batteries meet the above definition but are not universal wastes. These include spent lead-acid batteries that are being managed under the requirements of 40 CFR part 266 subpart G; batteries that are not waste because they have not been discarded; and batteries that are not hazardous waste.

Specific types of batteries covered under the rule include the following:

  • Batteries such as nickel-cadmium (Ni-Cd)
  • Small, sealed lead-acid batteries, which are found in many common items in the business and home setting, including:
    • Electronic equipment;
    • Mobile telephones;
    • Portable computers; and
    • Emergency backup lighting.

While universal wastes should be sorted by type (e.g., batteries, lamps), different kinds of batteries may be mixed if desired. Battery cell casings should not be breached, except that cells may be opened to remove electrolyte, but must be immediately closed after removal.

What about lithium-ion batteries?

Before disposing of lithium batteries, determine if it is a hazardous waste. Not all lithium batteries exhibit the characteristics of hazardous waste (ignitability, corrosivity, reactivity, and toxicity). If the battery exhibits a hazardous characteristic, it may be eligible to be managed as a universal waste. Many lithium batteries exhibit the characteristic of toxicity because of heavy metals. Others exhibit the characteristic of reactivity because of the presence of unreacted lithium.

Because it can be difficult to tell if a lithium battery is a hazardous waste, a facility may optionally manage all lithium batteries as universal wastes.