# Treat used lithium-ion batteries as likely hazardous waste: EPA recommends universal waste handling for businesses > EPA says most lithium-ion batteries are likely RCRA hazardous waste when discarded, ignitable and reactive, and that businesses must determine whether their waste is hazardous. It recommends managing them under the federal universal waste rules, keeping them out of trash and municipal recycling, and taping terminals and bagging each battery. - Canonical URL: https://update.dsesecurity.com/updates/epa-lithium-ion-batteries-business-universal-waste-hazardous-waste-handling/ - Publisher: Detection Systems & Engineering (DSE Security) - Author: DSE Security Editorial Team - Published: 2026-10-19T00:27:50+00:00 - Modified: 2026-10-19T01:55:07+00:00 - Last reviewed by DSE: 2026-10-19 - Resource type: Guide - DSE priority: Advisory - Topics: Business Continuity, IT - Reading time: 2 minutes ## What you need to know EPA says most lithium-ion batteries are likely RCRA hazardous waste when discarded, ignitable and reactive, and that businesses must determine whether their waste is hazardous. It recommends managing them under the federal universal waste rules, keeping them out of trash and municipal recycling, and taping terminals and bagging each battery. ## Potentially affected Businesses that replace UPS, laptop, phone, camera, tool and backup batteries, and the facilities and IT staff who collect them. ## DSE recommendation DSE recommends collecting used lithium-ion batteries separately, taping terminals and bagging each one, and sending them to a recycler under universal waste rules rather than the trash. ## Article EPA says most lithium-ion batteries are likely RCRA hazardous waste when discarded, ignitable and reactive, and that businesses must determine whether their waste is hazardous. It recommends managing them under the federal universal waste rules, keeping them out of trash and municipal recycling, and taping terminals and bagging each battery. ## Source facts EPA’s [used lithium-ion batteries page](https://www.epa.gov/recycle/used-lithium-ion-batteries) says most lithium-ion batteries are likely to meet the definition of hazardous waste under RCRA, generally as ignitable and reactive wastes with codes D001 and D003, and that while households are generally exempt, commercial establishments are responsible for determining whether their waste is hazardous. Because batteries with different chemistries can look alike and may still hold a charge when they appear discharged, EPA recommends businesses consider managing them under the federal universal waste regulations in 40 CFR part 273. EPA says the universal waste rules cover how to manage and label the waste, how long it can be kept on site and where it can be sent, with requirements that differ above and below 5,000 kg accumulated, and that shipments go to a permitted hazardous waste facility or recycler without a hazardous waste manifest. Businesses generating less than 100 kg of hazardous waste per month may qualify as very small quantity generators with reduced requirements, after checking with their state. EPA warns that batteries placed in trash or municipal recycling can be damaged or crushed and start fires, and advises placing each battery or device in a separate plastic bag and covering terminals with non-conductive tape such as electrical tape. Citing the Department of Transportation’s Check the Box campaign, it says batteries must be correctly identified, packaged and labeled before being sent for recycling or disposal. ## Applicability Use this for businesses in the United States; state hazardous waste programs may have different or stricter rules. Large batteries in energy storage systems and vehicles go back through the manufacturer or installer. ## DSE recommendation DSE recommends collecting used lithium-ion batteries separately, taping terminals and bagging each one, and sending them to a recycler under universal waste rules rather than the trash. Label collection containers, keep damaged or swollen batteries apart in a non-combustible container, track accumulation dates, and keep recycler receipts with asset disposal records. ## Verification Inspect collection points monthly for damaged batteries and accumulation dates, confirm shipments went to an accepting recycler, and review the program against state rules each year. ## Official reference [U.S. EPA — Used Lithium-Ion Batteries](https://www.epa.gov/recycle/used-lithium-ion-batteries). Reviewed October 19, 2026. ## Primary reference - Name: U.S. EPA — Used Lithium-Ion Batteries - Authority: www.epa.gov - URL: https://www.epa.gov/recycle/used-lithium-ion-batteries - Source publication date: Not stated by the source ## Citation and use Preferred citation: “Treat used lithium-ion batteries as likely hazardous waste: EPA recommends universal waste handling for businesses,” DSE Security, https://update.dsesecurity.com/updates/epa-lithium-ion-batteries-business-universal-waste-hazardous-waste-handling/ Publishing principles: https://update.dsesecurity.com/updates/dse-updates-editorial-methodology/ Usage and citation policy: https://update.dsesecurity.com/usage/ Copyright © 2026 Detection Systems & Engineering. All rights reserved.