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Is the brand name not on the compliance list for exporting batteries to the United States? The new EPR regulations have been implemented, and without this' admission ticket ', the entire market will be lost
Author.
LCS
Source:
Post time:
2026-07-13
A batch of battery packs worth hundreds of thousands of dollars were shipped to a port in the United States. When the purchaser opened the box for inspection, the first thing they asked was not the parameters, but rather: "Is your battery brand on The Battery Network list? ”If the answer is' not available ', this batch of goods may be returned by the original route.
This is not an exaggeration. Starting from January 1, 2026, the Extended Producer Responsibility (EPR) regulations for batteries in multiple states in the United States will officially come into effect. Whether battery brands are included in the Stewards List of compliance management organizations has become a mandatory prerequisite for products to enter these state markets. However, a large number of domestic battery export companies still lack awareness of this issue, with unregistered, uninspected, and unclassified brands, and only realize the seriousness of the problem when the goods are rejected or orders are cancelled.
Core Interpretation
There is no unified federal battery recycling law in the United States, and each state legislates on its own. Currently, multiple states have implemented mandatory Extended Producer Responsibility (EPR) systems, with core requirements progressively progressing:
① Market access ban
In states where legislation has been passed (California CA, Illinois IL, New York NY, Vermont VT, Washington DC, etc.), battery brand owners must join a battery management organization approved by the state government (such as The Battery Network), otherwise the product cannot be sold in that state. This is the lowest entry threshold - not registering is equivalent to not having an "admission ticket".
② California CBE Fee Collection Mechanism
California takes the lead in implementing the CBE Fee for Embedded Battery Waste Recycling, with specific rules:
Levy ratio: levied at 1.5% of the retail price of the product
Single item cap: up to $15 per item
Collection node: charged by retailers to consumers during the sales process
Declaration and Payment: Retailers need to register with the California tax department and regularly declare and pay taxes
Effective date: January 1, 2026, officially implemented
③ Dual prohibition on sales and disposal
(Taking Illinois as an example)
Illinois regulations set two key time points:
Starting from July 1, 2026, retailers are not allowed to sell battery products from manufacturers who have not participated in the compliance program
Starting from January 1, 2028: It is prohibited to throw batteries into ordinary garbage and they must be disposed of through designated recycling channels
④ The cost of illegal activities is high
Non compliant enterprises will face: mandatory product removal, administrative fines, termination of cooperation by purchasers, and even being blacklisted, which will affect subsequent customs clearance.
Compliance channel
What is The Battery Network?
The Battery Network is one of the largest battery compliance management organizations in the United States and an officially approved compliance program operator by multiple state governments. By completing registration through this organization, battery brands can meet the EPR compliance obligations of the aforementioned states.
Relationship with Call2Recycle
The Battery Network and Call2Recycle are the same organization. Call2Recycle has recently been officially renamed as The Battery Network. If the enterprise has a registration record on Call2Recycle before, it is necessary to confirm whether the qualifications will be automatically migrated after the name change. It is recommended to directly log in to the new official website to verify.
Self-check Portal
Brand compliance list inquiry address:
https://batterynetwork.org/stewards/compliant-brands/
Please make sure to confirm if the brand name of the battery used for export (including any aliases or former names) is listed. Some companies use brand names that are inconsistent with their export declaration names during registration, which can easily lead to misjudgments of "not found but actually registered".
The risk of the brand not being on the list
1 cannot be sold in legislated states
If the brand is not registered, the relevant state government may prohibit the sale of the brand's batteries and complete products containing the batteries in accordance with the law. For embedded battery products such as power tools, consumer electronics, energy storage devices, etc., the ban not only applies to the battery itself, but also affects end products.
2 were directly rejected by downstream buyers
More and more American buyers are explicitly requiring suppliers to provide EPR registration certificates for batteries in their contracts. If the brand is not on the Stewards List, the purchaser may directly cancel the order, reject the goods, or request an emergency replacement of the battery supplier - either outcome will result in significant trade losses.
3. Misalignment between declaration classification and charging standards
Brands on the list will be marked with the battery type by the system (such as "Primary disposable battery"). If they are not on the list, the charging standards, declaration fields, and product identification requirements will be different. Even if the technical indicators of the product itself fully meet the standards, it may be judged as "non compliant" due to the brand not being registered, resulting in the invalidation of the test report and certification documents.
Action Guide
Step 1
Immediately self check if the brand is listed
Log in to The Battery Network official website to check the list of compliant brands.
Key verification points:
Confirm if the full name of the brand used for export is listed
Check if there are any registered aliases or previous names
Confirm whether the battery type label registered by the brand is consistent with the actual product
Step 2
Accurately determine battery classification
According to the weight and capacity of the battery, determine its category, and the registration fees and declaration cycles for different categories are different:
Portable battery
Weight ≤ 11 pounds (5kg), or capacity ≤ 300Wh
Medium sized battery
Weight>11 pounds and ≤ 25 pounds, or capacity>300Wh and ≤ 2000Wh
Primary batteries
Non rechargeable and weighing ≤ 4.4 pounds (2kg)
Classification errors will directly lead to inconsistent declaration information, which may trigger compliance review or even fines.
Step 3
Start the registration process immediately
Confirmed unregistered brands should immediately initiate the registration process to join The Battery Network. The normal registration period is about 2 months. Considering that regulations in various states have gradually come into effect and the time window is tight, it is not advisable to delay.
The compliance chain for exporting batteries to the United States is extending from "technical compliance" to "brand registration". The EPR regulation requires brand owners to fulfill their registration obligations at the producer responsibility level, which are two independent systems of product safety certification (UN 38.3, FCC, UL, etc.) - companies must work in parallel, obtaining safety testing reports and completing brand EPR registration in order to have smooth and unobstructed access to the US market.
If you need to obtain battery safety testing solutions or US market access certification consultation, please contact LCS for customized compliance solutions.
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