What Changed

California’s SB 1215 expanded the state’s existing Electronic Waste Recycling program to cover products with non-user-removable embedded batteries. The recycling fee went into effect Jan. 1, 2026. If your company manufactures or retails these products in California, compliance obligations are active now.

Does This Apply to Your Products?

A “covered battery-embedded product” (CBEP) is any product containing a battery that is not designed to be easily removed by the user with no more than commonly used household tools.

The definition is intentionally broad. For auto care companies, products potentially in scope include portable jump starters, Bluetooth diagnostic tools, dash cams, cordless shop lights, and similar battery-powered items where the battery is not user-serviceable.

Manufacturers are responsible for making their own determination about which of their products fall within the CBEP definition and which are exempt. If your team has not done this review, do it now. When in doubt, consult legal counsel.

Excluded product categories: certain medical devices, existing covered video display devices, energy storage systems, and electronic nicotine delivery systems.

CalRecycle Q&A on covered products: calrecycle.ca.gov/electronics/embeddedbatteries

The Recycling Fee

• Amount: 1.5% of the retail sales price for each CBEP sold in California
• Cap: Maximum $15.00 per product (applies to products priced at $1,000 or above)
• Effective date: January 1, 2026

If You Are a Retailer

These requirements are active now:

• Collect the 1.5% fee (max $15.00) from the consumer at the time of sale
• State the fee separately on the customer’s receipt
• Retain 3% of collected fees to offset your compliance costs
• Remit the balance to CDTFA quarterly. Q1 (Jan. 1 – March 31, 2026) was due April 30, 2026. Q2 (April 1 – June 30, 2026) is due July 31, 2026. If Q1 has not been filed, act immediately.
• Confirm that manufacturers of CBEPs you carry have sent you the required product notice. If CalRecycle or DTSC determines a manufacturer is not in compliance, you cannot sell those products.
• Note: A CBE waste recycling fee account is separate from your seller’s permit and any existing eWaste fee account. If you are already registered for the e-waste program, you still need a separate CBE account.

Marketplace Facilitators: If your company facilitates third-party sales through an online platform, you may be responsible for collecting the fee on behalf of marketplace sellers. Confirm your obligations with CDTFA.

Register with CDTFA: onlineservices.cdtfa.ca.gov

CDTFA fee guide: cdtfa.ca.gov/taxes-and-fees/covered-electronic-waste-recycling-fee

If You Are a Manufacturer

The following were required by Jan. 1, 2026:

• Products labeled with manufacturer name or brand
• Battery chemistry identified on product label or posted on your company website

  The following was required by July 1, 2025 (and annually thereafter):

• An annual notice sent to all California retailers identifying, by brand and model number, which of your products are covered CBEPs and which are exempt, along with a copy to CalRecycle at CEDManufacturers@calrecycle.ca.gov

  Failure to provide the required notice to all retailers by July 1, 2025 may result in enforcement action by CalRecycle. If your company has not yet sent this notice, treat it as overdue and act promptly.

  Coming up:

• July 1, 2027: First annual manufacturer reports due to CalRecycle, covering calendar year 2026. Required content includes sales data, battery chemistry, recycled content, list of retailers notified, and consumer disposal information.

Manufacturer notice guidance: calrecycle.ca.gov/electronics/embeddedbatteries/noticeguide

Optional notice template: CalRecycle recommended template (PDF)

Manufacturer reporting information: calrecycle.ca.gov/electronics/manufacturer

Immediate Action Steps

For manufacturers:

1. Audit your product lines against the CBEP definition
2. If you have not sent the annual retailer notice, send it now and copy CalRecycle at CEDManufacturers@calrecycle.ca.gov
3. Confirm product labeling (manufacturer name/brand; battery chemistry) is in place
4. Confirm CDTFA registration

For retailers:

1. Register with CDTFA at onlineservices.cdtfa.ca.gov if not already done
2. Confirm the fee is being collected and receipts are compliant for California sales
3. File Q1 return immediately if not yet filed (due April 30, 2026). File Q2 by July 31, 2026.
4. Follow up with your manufacturers to confirm they have sent the required product notice

Questions?

CalRecycle guidance: calrecycle.ca.gov/electronics/embeddedbatteries

CDTFA fee guide: cdtfa.ca.gov/taxes-and-fees/covered-electronic-waste-recycling-fee

Contact the Auto Care Association Government Affairs team: GovernmentAffairs@autocare.org.

This is presented for informational purposes and is not legal advice. Please consult counsel regarding your obligations.