Managing Batteries as Universal Waste

The Universal Waste Rules are alternative rules for some common wastes that allow them to be handled more easily.  See more general information at Manage Waste as Universal Waste.  This page is specific to batteries.

The Universal Waste Rule can apply to all batteries that are dangerous waste. It is the generators responsibility to determine, by designation methods, if their batteries are a dangerous waste. Batteries that do not designate as dangerous waste do not have to be managed as universal waste.  Examples of battery types that could be managed as universal waste  include:

Alkaline Button cell mercuric oxide
Mercuric-oxide Silver oxide
Alkaline-manganese Lithium
Zinc-carbon Nickel-cadmium (Ni-Cd) Zinc air
Lead acid*

*Note that while spent lead-acid batteries (typically automotive batteries) can be managed as universal waste, they are most often managed under the optional Lead-acid Battery Exemption.

Lead-acid Battery Exemption is the easiest management method for those businesses that handle lead-acid batteries, such as automotive and marine batteries

Consumer products with difficult-to-remove batteries can be managed as universal waste. Miniature batteries, used in numerous products, like toys, hearing aids, watches, calculators, and other portable devices can also be managed as universal waste.

Contact a Hazardous Waste Specialist if you are unsure.

Labeling, Marking, Storing Universal Waste Batteries

Clearly label or mark individual batteries or containers of universal waste batteries with one of the following phrases:

Accumulate batteries for up to one year from the date they are generated.  Mark with the first date batteries began to be stored in the collection container to documents storage time.  Damaged or leaking batteries must be stored in closed containers to prevent releasing toxic materials to the environment. Batteries must be compatible with one another and with the container.

Free Waste Labels are available for download, and Universal Waste labels are part way down the page.

Related information

Universal Waste Rule for Batteries is a published Ecology fact sheet detailing the how the Universal Waste Rule can apply to battery management.

Universal Waste Rule for Mercury-containing Equipment is a published Ecology fact sheet details the how the Universal Waste Rule can apply to thermostats and other mercury-containing equipment.

Universal Waste Rule for Lamps is a published Ecology fact sheet detailing the how the Universal Waste Rule can apply to lamp management.