A wave of state-level battery stewardship and end-of-life packaging regulations is tightening across the United States, forcing auto parts manufacturers, distributors, and retailers to prepare for overlapping and often inconsistent compliance obligations in multiple jurisdictions. With key deadlines clustering between 2026 and 2028, the absence of a binding federal standard is leaving suppliers to navigate a fragmented regulatory environment state by state.
Background
As of January 1, 2026, the regulatory landscape governing batteries has fractured into a complex patchwork of 50 different standards. Extended producer responsibility (EPR) laws now exist in 34 states and the District of Columbia across 22 product categories, including packaging1California SB615 | 2025-2026 | Regular Session, and battery-specific mandates are rapidly expanding that count. EPR in the United States is typically implemented at the state level and can cover batteries, e-waste, and other products. The Infrastructure Investment and Jobs Act requires the EPA and the U.S. Department of Energy to develop a national EPR framework for batteries addressing recycling goals, cost structures, reporting requirements, product design, collection models, and transportation of collected materials.2Extended Battery Producer Responsibility (EPR) Framework | US EPA
For auto parts producers, the challenge is compounded by uneven state definitions. California's Responsible Battery Recycling Act (AB 2440) explicitly excludes batteries contained in motor vehicles, including cars and bicycles, while New Jersey has moved in the opposite direction. New Jersey's law, signed in January 2024, is the nation's most comprehensive EPR law specifically for propulsion batteries. As of January 8, 2026, all vehicle battery producers must report to the New Jersey Department of Environmental Protection, and an absolute prohibition on disposing of these batteries as solid waste takes effect January 8, 2027.
Details
Several states reached major compliance milestones in early 2026 or face deadlines approaching in 2027. In Illinois, the Battery Stewardship Act requires producers of covered batteries or battery-containing products to implement and participate in an approved stewardship plan starting January 1, 2026. The mandate applies to brand owners, manufacturers, importers, and first distributors. Retailers are prohibited from selling products from non-compliant producers. Non-compliance can result in a civil fine of $7,000 per violation, doubling if unpaid.
In California, producers of covered batteries must participate in a stewardship plan approved by CalRecycle no later than April 1, 2027, and must achieve a minimum recycling efficiency rate of 60% for rechargeable batteries and 70% for primary batteries beginning January 1, 2027, under the Responsible Battery Recycling Act of 2022. On the packaging side, California producers must join a Producer Responsibility Organization or obtain approval for individual compliance by January 1, 2027, with escalating recycling targets through 2032.3Manufacturers’ Blueprint: Solving the US & EU Battery Compliance Puzzle
Washington State added new obligations in 2026. Administrative rules took effect January 16, 2026, but while portable battery collection begins in 2027, large-format vehicle battery collection is not mandated until 2029. Until then, hybrid and EV batteries in Washington remain under Universal Waste Rules, meaning the dismantler is still financially responsible for downstream recycling.
Colorado passed its own battery stewardship program: Colorado SB25-163, through the state House on May 6, 2025, establishing a program requiring producers to manage battery disposal and recycling, with compliance deadlines starting in 2026 and performance goals and penalties for non-compliance. Wisconsin's battery stewardship law takes effect in January 2027, requiring battery producers to join a stewardship organization and submit a collection and management plan for approval by the state's Department of Natural Resources. The organization is responsible for collecting covered batteries on a free, continuous, and convenient basis, using producer fees to reimburse local governments.
On packaging, in 2025 alone at least eight additional states-including New York, Massachusetts, Rhode Island, New Jersey, Illinois, Tennessee, North Carolina, and Hawaii-introduced comprehensive EPR packaging bills similar in scope to laws already enacted in seven states. The greatest challenge for producers is the lack of harmonization: they must manage disparate deadlines, conflicting material definitions, and different fee structures across a growing list of jurisdictions.
Legal risk is also escalating. On February 6, 2026, the U.S. District Court for the District of Oregon granted the National Association of Wholesaler-Distributors a preliminary injunction blocking enforcement of Oregon's Plastic Pollution and Recycling Modernization Act. The Oregon litigation could affect the scope of EPR programs nationwide, potentially extending beyond packaging to other product categories.
Outlook
The EPA is developing a voluntary battery EPR framework expected for publication in summer 2026. The framework is not intended as a model bill for states but rather as a high-level examination of design, collection, reporting, and regulatory considerations that could inform battery EPR programs. It will offer an overview of current practices and challenges from existing battery EPR states. The EPA and DOE initiative will not displace state programs but will provide best practices to support state design and implementation and promote cross-jurisdictional consistency.
Industry advocates have pressed for stronger action. "We would love to see there be a federal legislation so that there's consistency across the United States and that these batteries are kept out of disposal facilities nationwide," said Scott Cassel, CEO and founder of the Product Stewardship Institute. Until such alignment materializes, auto parts producers face the practical burden of registering with multiple stewardship organizations, tracking state-specific reporting schedules, and absorbing escalating PRO fees-all within tightening timelines.
