The purpose of this memorandum is to clarify how the hazardous waste regulations for universal waste and recycling apply to lithium-ion batteries. Recent interest in the regulation and management of lithium-ion batteries at the end of life has prompted the EPA to examine specifically how universal waste handling requirements, hazardous waste recycling regulations, and other RCRA Subtitle C provisions apply to this waste stream.
The universal waste standards in 40 CFR part 273, as adopted by Chapter 62-730.185, F.A.C., are for certain hazardous wastes that are generated by a wide variety of establishments and are meant to streamline the collection of these hazardous wastes for proper management at a hazardous waste recycler or a permitted treatment, storage, or disposal facility.
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