The United State Environmental Protection Agency (EPA) issued on June 1, 2023 a 12-page memorandum containing 19 frequently asked questions (FAQ) on lithium ion battery recycling and the applicability of the Agency’s hazardous waste regulations (RCRA) to lithium ion batteries.
The document is at least the second “informal” statement by EPA in recent years that used lithium ion batteries may be considered hazardous wastes under RCRA due to the ignitability (D001) and reactivity (D003) characteristics. It also addresses a host of other issues. These include the applicability of the RCRA universal waste regulations; black mass; damaged, defective, and recalled lithium ion batteries; reused, repurposed, or repaired lithium ion batteries; permitting; and storage.
A meeting of PRBA’s Environmental and Recycling Committee has been scheduled to discuss the memorandum and FAQ and whether a follow-up meeting with EPA is warranted. For more information, contact George Kerchner at 202.719.4109 or [email protected].
PRBA serves as advocates between lawmakers enacting federal and state battery legislation and its valuable membership base. Learn more about becoming a member here.