California Battery-Embedded Product Recycling Fee: Confirm Your Compliance Status

California's Covered Battery-Embedded Waste Recycling Fee has applied since Jan. 1, 2026, and it may affect more members than TPMS sensor sellers alone.

What it is

California expanded its Covered Electronic Waste Recycling Program under SB 1215 (2022) to include Covered Battery-Embedded Products, or CBEPs. A CBEP is any product containing a battery that is not designed to be easily removed by the user with commonly used household tools. This is a functional test, not a fixed product list. Certain items are excluded: some medical devices, video display devices already covered under the existing e-waste program, energy storage systems, electronic nicotine delivery systems, and motor vehicles (including factory-installed components).

CalRecycle has confirmed that standalone aftermarket TPMS sensors with a non-removable embedded battery are CBEPs when sold separately as a replacement part. Factory-installed TPMS sensors sold with a vehicle are not. The same functional test applies to any other standalone embedded-battery part or accessory a member may sell, including certain tools, diagnostic equipment, and similar products.

What retailers must do if a product qualifies

• Charge the consumer a recycling fee of 1.5% of the retail sales price at the point of sale. The fee is currently capped at $15 per unit. CalRecycle has proposed lowering that cap to $1, effective Jan. 1, 2027, pending final action.
• Register a separate Covered Battery-Embedded Waste Recycling Fee account with the California Department of Tax and Fee Administration (CDTFA). This is a distinct account from any existing eWaste account.
• File and remit the fee quarterly with CDTFA.
• Collect the fee even if the manufacturer never sent the required annual notice identifying the product as a CBEP. A manufacturer's failure to notify does not relieve a retailer of the obligation.
• The fee does not apply to warranty replacements where no sale occurs.

What the Association cannot do

The association does not have visibility into individual member product catalogs and cannot tell members which specific products qualify. If a member is unsure whether a product meets the CBEP definition, CalRecycle directs retailers to contact the product's manufacturer directly.

Action for members

Review products sold standalone, separate from a vehicle or other host product, for a non-removable embedded battery. If a product qualifies, confirm CDTFA registration and fee collection are in place. Contact the manufacturer with any product-specific questions.

CalRecycle resources

• Program overview: https://calrecycle.ca.gov/electronics/embeddedbatteries/
• Covered Battery-Embedded Products Q&A: https://www2.calrecycle.ca.gov/Docs/Web/137572
• Manufacturer Notice Guidance: https://calrecycle.ca.gov/electronics/embeddedbatteries/noticeguide/
• What's a CBEP? flyer: https://www2.calrecycle.ca.gov/Docs/Web/138256
• Program overview flyer: https://www2.calrecycle.ca.gov/Docs/Web/138259
• CDTFA Covered Electronic Waste Recycling Fees Guide: contact CDTFA directly for account registration at https://onlineservices.cdtfa.ca.gov/