Managing Electric Vehicle Batteries

Guidance for electric vehicle (EV) battery recycling regulations in Texas. EV batteries can be managed as universal waste and recycled.

What Are EV Batteries?

Electric vehicle (EV) batteries are large, rechargeable batteries that power light-duty, electric passenger vehicles and some medium and heavy-duty vehicles. With the increase in electric vehicles driving on Texas roads, there will be more EV batteries reaching end-of-life and requiring recycling or disposal.

Currently, most EV batteries are lithium-ion batteries. Lithium-ion batteries can store a large amount of energy in small, light-weight cells. The batteries often contain valuable metals, such as lithium, copper, cobalt, and nickel. Lithium ion-batteries can vary by size, design, and chemistry, and these characteristics have an impact on how EV batteries are properly handled at end-of-life.

Note that some EV batteries may be repaired or reused. In these cases, a battery that can still function and used as a battery is not considered a waste. The guidance below applies to EV batteries that can no longer function or used as a battery

Summary of the Recycling Process for EV Batteries

Graphical description of the regulatory recycling process for electric vehicle batteries.

Text version of the infographic about the recycling process—in English and Spanish.

Managing EV Batteries as Universal Waste

When an EV battery reaches the end of its life—meaning it is no longer usable as a battery—the remaining electrical charge will give the waste battery a hazardous waste classification.

EV batteries that are classified as hazardous waste may be managed as universal waste.
Universal Waste is a specific type of hazardous waste that is subject to more relaxed standards of accumulation, recordkeeping, and shipping requirements than those of normal hazardous wastes.
Batteries, fluorescent lights, and mercury-containing equipment (including thermostats) are examples of materials that, if hazardous, could qualify to be regulated as universal waste.
EV batteries that are not classified as hazardous may be managed as industrial non-hazardous waste.

Universal Waste Handlers

A universal waste handler can collect and store EV batteries. Universal waste handlers are categorized by the amount of universal waste they manage. Only large quantity universal waste handlers—handlers that store more than 5,000 kg (11,000 lbs.) of universal waste at one time—must register with the U.S. Environmental Protection Agency (EPA) and obtain an EPA ID. No other registration or permits are required for managing universal waste.

Learn more about managing hazardous waste, including the registration process for large quantity handlers, at Managing Hazardous Waste as Universal Waste.

Managing Universal Waste Batteries

Universal waste is hazardous waste. When an EV battery is considered hazardous only because of ignitability (D001), discharging it will render it non-hazardous. In this example, the discharged battery would be considered industrial non-hazardous waste, not subject to universal waste regulations. However, batteries of different chemical composition may continue to be classified as hazardous after discharge.

Universal waste regulations do not allow for the treatment of hazardous waste, but they do allow certain management activities like the disassembly of a EV battery pack and the electrical discharge of an EV battery.

Industrial Waste Generators

Certain industrial waste generators will need to register with TCEQ. For example, facilities that generate more than 100 kg (220 lbs.) of Class 1 non-hazardous industrial waste per month will need to register.

Learn more about obtaining an EPA ID and other registration requirements at Industrial and Hazardous Waste Registration and Reporting: Am I Regulated?

Recycling EV Batteries

A facility that sends or receives industrial waste to be recycled must notify TCEQ of recycling activities under 30 TAC 335.6 . To begin recycling EV batteries, submit one of the following recycling notification forms to the IHW Permits Section:

Other Recycling Requirements

Some recycling activities may require a storage permit prior to recycling. Certain recycling activities may also require an air permit or a wastewater permit. For more information, visit: