Li-ion batteries are everywhere, are a growing part of the waste stream, and present unique additional hazards when improperly managed. Improving the status quo is clearly possible.
By David Nightingale, CHMM, S.C.

Call2Recycle® was the first nationally-coordinated U.S. product stewardship program. The Call2Recycle municipal partner program for rechargeable consumer batteries has always been free to local recycling and HHW collection programs. This month we will look at the development and adaptation of that program as well as some hands-on issues surrounding the safe handling and shipment of rechargeable consumer batteries.

Photo courtesy of U.S. Department of Energy.

The First Voluntary Product Stewardship Program
In 1994, when the Call2Recycle program was created, the term product stewardship had yet to enter the general lexicon of waste managers in the U.S. Although many states had “bottle bills” and other deposit-return systems, which have some elements of product stewardship, there were no U.S. models suitable to meet the needs and aspirations of the battery companies that started the Call2Recycle initiative.
On May 11, 1995, EPA adopted the universal waste rule. That rule encouraged the removal of batteries from the waste stream by establishing streamlined collection and management
requirements for universal waste batteries, as well as certain pesticides and mercury thermostats. Most states with authorized hazardous waste programs have chosen to adopt the federal universal waste rules in some form.1

Nowadays, most state product stewardship laws require all companies selling their covered products into the state to be part of an approved stewardship organization or have an alternative system for collecting and responsibly managing their products at their end-of-life. Because the Call2Recycle program lacks a mandatory participation feature, not all battery manufacturers participate.

Non-participating manufacturers are called “free riders”—manufacturers that choose not to participate in a program, but benefit from their batteries being collected, as mentioned in last month’s HHW Corner (Waste Advantage Magazine, January 2021).2 The free rider issue was clearly presented by the Northwest Product Stewardship Council’s policy factsheet supporting the passage of a Washington State rechargeable battery law in 2013, but such legislation has not yet passed in Washington.3

States Modify the National Program
Vermont passed legislation to, in part, require all primary battery manufacturers to fund and participate in a product stewardship program. That solved the free rider problem in that state for primary batteries, but not for rechargeable batteries. Other states require battery producers to offer or fund recycling of rechargeable consumer batteries including MN, IA, NY, NH, ME, MD and FL.4

Although some states have banned batteries from solid waste disposal, surprisingly, no states have yet passed legislation for mandatory manufacturer’s participation in battery collection and recycling for all consumer batteries, primary and rechargeable batteries. Therefore, the free rider problem persists in most states for rechargeable and primary batteries.

Li-ion Battery Fires and Chemistry
Lithium Ion (Li-ion) batteries have been great for consumers: powering laptops, cellphones, power tools and other cordless devices. However, Li-ion batteries have also been associated with fires that have caused damage to transfer stations, MRFs and shippers. Nonetheless, I am not aware of any Li-ion battery fires that have damaged an HHW collection facility. This is likely due to the relatively intensive inspection and waste handling practices at HHW facilities compared to the bulk materials handling at other types of solid waste facilities. In that way, HHW facilities provide battery fire mitigation and should be promoted.

The volatility of Li-ion batteries can be traced to their use of electrolytes. The electrolytes in Li-ion batteries are a mixture of lithium salts and organic solvents. Of the five commonly used organic solvents in Li-ion battery electrolytes, dimethyl carbonate has the lowest flash point, 31°F (18°C), which is a flammable liquid according to the National Fire Protection Association’s classification of materials criteria.5 Other organic solvents used in Li-ion cells have significantly higher flash points, up to 293°F (145°C) for Ethylene Carbonate, which is not a flammable liquid.6 Because Li-ion battery makers use a mixture of organic solvents depending on the application, the flash point of a specific electrolyte mixture is difficult to know.7 Suffice it to say that the Li-ion electrolytes can and will burn if exposed to enough heat and an ignition source in the presence of air.

Li-Ion batteries are designed to discharge their energy at a fast rate, which creates heat. If a battery is damaged so that it discharges faster than designed, and the battery’s electrolyte is spilled, you have the necessary ingredients for a fire: heat, fuel and air. Or, if Li-ion batteries are shipped with exposed terminals, there is a potential to create an electrical short circuit while in transit. This would cause the remaining battery energy to be discharged very rapidly, quickly creating heat, potentially compromising the containment of the electrolyte, which would again create the ingredients for fire. Interestingly, Li-ion batteries contain lithium ions not metallic lithium. Therefore, use of metal fire suppression materials or techniques are not appropriate in response to a Li-ion battery fire.8

Figure 1: Rechargeable batteries with taped terminals.
Photo Courtesy of Nick Saelee, King County Hazardous Waste Program.

Safe HHW Battery Collection and Shipping
HHW programs as well as other solid waste facilities receive batteries of all types and in all conditions. Damaged rechargeable batteries often appear bloated or swollen and cannot be safely
handled in typical battery collection containers. However, they can be shipped using Call2Recycle’s approved containers under U.S. DOT Special Permit 20549 (DOT SP 20549).9 This special
permit specifically allows for bulk shipment of damaged, defective or recalled (DDR) batteries.10

But what about undamaged or other rechargeable batteries? The current DOT SP 20549 requires that for transportation, any dry cell, non-spillable battery, lithium metal or Li-ion battery with a rating of more than 9 volts must have any exposed battery terminals protected from short circuiting.11 This can be accomplished by placing each battery in a separate plastic bag or putting plastic tape over any exposed terminals.12 Figure 1 shows a drum of batteries in Seattle with taped terminals.

Recycling and the Department of Energy Lithium-Ion Prize
Li-ion batteries now dominate the market and are rapidly increasing in their application globally. The Call2Recycle program now collects more Li-ion batteries than any other rechargeable battery chemistry. One global estimate is that just over half of all Li-ion batteries were recycled in 2019.13 Battery recycling capacity is expanding with Li-Cycle announcing that the largest Li-ion recycling plant in North America, located in Rochester, NY, is now operational. Another expansion slated for 2022 will produce “battery-grade materials”.14

Supplementing the efforts to build additional capacity to recycle Li-ion batteries is the U.S. Department of Energy’s Lithium-Ion Battery Recycling Prize. It focuses on identifying innovative solutions for collecting, sorting, storing and transporting discarded lithium-ion batteries, including consumer electronics, for eventual recycling.

The Battery Recycling Prize is a $5.5-million competition designed to incentivize American entrepreneurs to develop and demonstrate processes that, when scaled up, have the potential to profitably capture 90 percent of all discarded or spent lithium-based batteries in the U.S. and recover key materials. If achieved, 90 percent recovery would boost the Li-ion recycling rate, approaching the current levels of recycling automotive lead-acid batteries.

Lack of Public Awareness for Proper Rechargeable Battery Management
Although many HHW programs participate in battery recycling programs, a recent national survey performed in March and April of 2020 for Call2Recycle by the Harris Poll company revealed that the public is not clear on the recyclability of consumer batteries. According to the survey, one in five well-meaning residential curbside recyclers have placed their discarded batteries in their recycling bin, where they cause problems at MRFs. Only about one third of survey respondents said that they recycle their used consumer batteries. So, the majority of the public is not aware of their role to properly manage their end-of-life batteries.

Li-ion batteries are everywhere, are a growing part of the waste stream, and present unique additional hazards when improperly managed. Improving the status quo is clearly possible. Improvements should include:
• More inclusive state or federal consumer battery recycling laws that eliminate free riders,
• Increased public awareness of appropriate battery management, including promotion of HHW collection programs,
• Realization of improved Li-ion battery management from DOE’s Battery Recycling Prize, and
• Improved product designs that make consumer batteries more easily identifiable and removable from products at end-of-life. | WA


Next month’s HHW Corner will have an interview with one of the U.S. Product Stewardship luminaries, Scott Cassel.

David Nightingale, CHMM, S.C., is Principal at Special Waste Associates (Olympia, WA), a company that assists communities in developing or improving HHW and VSQG collection infrastructure and operations. They have visited more than 145 operating HHW collection facilities in North America. As a specialty consulting firm, Special Waste Associates works directly for program sponsors providing independent design review for new facilities or upgrading existing facilities—from concept through final design for safer, more efficient and cost-effective collection infrastructures. Special Waste Associates also published the book, HHW Collection Facility Design Guide. He can be reached at (360) 491-2190 or e-mail contact@
*Thanks to Linda Gabor, Call2Recycle’s Executive Vice President, External Relations, for assistance with this article.


  1. The current Universal Waste Rules have been expanded to apply to certain batteries, pesticides, mercury-containing equipment, lamps, and aerosol cans. See
  2. and
  5. and
  6. Milolajczak, Celina, et. al., Lithium-Ion Batteries Hazard and Use Assessment – Final Report, Exponent Failure Analysis Associates, Inc., Fire Protection Research Foundation, Quincy, MA, July 2011, page 15.
  7. A flash point is the temperature at which a substance creates enough vapor to be ignited in air with the addition of an ignition source, such as a spark. The higher the flash point temperature the less flammable or combustible is the material.
  8. Milolajczak, Celina, et. al., Lithium-Ion Batteries Hazard and Use Assessment – Final Report, Exponent Failure Analysis Associates, Inc., Fire Protection Research Foundation, Quincy, MA, July 2011, page 3.
  10. DDR Li-ion batteries might also be shipped using Procyon-Alpha Squared’s DOT Special Permit 20432. See
  11. 12-volt automotive-style lead-acid batteries have a separate US DOT exemption for safe shipping.
  12. Ibid, page 4.
  15. Ibid, page 8-9.