California SB 1215 Embedded Battery Fee Compliance Overview

California Senate Bill 1215 expands the scope of the Electronic Waste (CEW) Recycling Act to include products that contain embedded batteries. The bill introduces a mandatory Covered Battery Embedded Waste Recycling Fee for eligible products sold or shipped into California.

SB 1215 applies to products where the battery cannot be removed using commonly available household tools. Many automotive electronics and accessories fall into this category, including diagnostic devices, portable power tools, and sealed battery components. Several product types are excluded under the statute, including display devices already regulated by existing CEW rules, specific medical equipment, large scale energy storage systems, and electronic cigarettes.

Manufacturers are required to evaluate their product catalog and identify any items that qualify for exemption. By July 1, 2025, manufacturers must provide an annual exemption list to California retailers as well as to CalRecycle. On October 1, 2025, CalRecycle will publish the annual recycling fee schedule for covered battery embedded products. Retailers must begin collecting this fee from California consumers starting January 1, 2026.

The law requires retailers to collect the recycling fee on each qualifying product at the point of sale. The fee must appear as a separate line item during checkout. In ecommerce environments, this requires identifying all affected products within the catalog and associating them with a structured product attribute indicating the presence of an embedded battery. Retail systems then evaluate whether the shipping destination is located within California and apply the appropriate fee when both criteria are met. If the product is removed from the order or the shipping address is changed to a non California destination, the fee must be removed automatically.

Many ecommerce implementations support this by defining a boolean product field, such as an “embedded battery included” attribute, which is used by automated logic to determine whether a recycling fee applies. This enables consistent handling across large catalogs, including automotive and parts SKU sets that may include thousands of affected items.

Although SB 1215 currently applies only to California, state level battery embedded product regulations continue to evolve. Retailers operating nationwide may require adaptable product data structures and fee logic to support future regulatory changes across additional states.

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