The rules that apply in United States
The US has no federal extended producer responsibility law for EV batteries. Lithium-ion batteries can be managed under EPA's universal waste rules, transport follows DOT PHMSA hazardous materials regulations, and states such as California and New Jersey are moving towards producer responsibility for EV batteries. Recycled material processed in North America can also count towards IRA critical mineral requirements.
End-of-life volume comes from early Tesla, Nissan and GM fleets, plus large production scrap from gigafactories across the Midwest and South.
What producers and holders must do
Producer responsibility follows whoever placed the battery on the market, but the practical burden often lands on the fleet or workshop holding the retired asset.
- Manage retired batteries under universal waste or state hazardous waste rules
- Package, mark and document shipments under 49 CFR hazardous materials rules
- Track state-specific EV battery take-back and reporting requirements
- Keep chain-of-custody evidence to support IRA critical mineral sourcing claims
Local permitting around Detroit, Michigan
The campus operates under permits administered by Michigan's Department of Environment, Great Lakes, and Energy (EGLE), and manages spent lithium-ion batteries under the US EPA universal waste framework where it applies. Transport follows US DOT hazardous materials regulations for lithium batteries, including the separate provisions for damaged, defective or recalled cells.
The document set
Shipments follow DOT PHMSA 49 CFR requirements, with damaged or defective batteries under stricter special permits and packaging. Each consignment carries a dangerous goods declaration, a transporter authorisation, a weighbridge record and a chain-of-custody sheet.
| Document | When | Purpose |
|---|---|---|
| Dangerous goods declaration | Before pickup | UN 3480 / UN 3481 classification and damage status |
| Chain-of-custody sheet | At handover | Links serials to transporter and destination |
| Weighbridge record | At gate-in | Verified mass for certificates and settlement |
| Recovery certificate | After processing | Quantity, recovery per metal and downstream vendors |
Booking a collection in the Detroit, Michigan catchment
These site-specific notes help collections run on time.
- Send architecture drawings or a disassembly note with prototype packs so the right procedure is prepared.
- Engineering centres can book recurring collections for validation and test waste.
- Damaged, defective or recalled units must be declared so they ship under the correct DOT provisions.
- Truck and large commercial packs need advance notice so rigging and crew are scheduled.