Manufacturer Information

Requirements to Notify Retailers by July 1

Senate Bill (SB) 1215 (Newman, Chapter 370, Statutes of 2022) amended the Electronic Waste Recycling Act of 2003 by adding covered battery-embedded products to the types of electronic devices covered by the law. Starting July 1, 2025, manufacturers of covered battery-embedded battery products must comply with new requirements (Public Resources Code (PRC) section 42466.2).

SB 1215 Covered Battery-Embedded Products Page

What is required for manufacturers of covered battery-embedded products?
  • Manufacturers are responsible for making determinations regarding which of their products fall within the definition of a covered battery-embedded product and which products are exempt from the covered battery-embedded product definition (PRC sections 42463(g)(1), 42463(f)(1)-(2), and 42466.2).
  • On or before July 1, 2025, and every year thereafter, a manufacturer of a covered electronic device, as defined in PRC section 42463(g)(1)(B), is required to send a notice to all retailers selling those products in California to ensure those retailers know which products are subject to the battery-embedded waste recycling fee in accordance with PRC section 42464(b).
Summary of Manufacturer Requirements to Notify Retailers
  • On or before July 1, 2025, and every year thereafter, a manufacturer of a covered battery-embedded product is required to send a notice to all retailers selling those products in California.
    • The notice must identify, by brand and model number, the covered battery-embedded products manufactured by that manufacturer that are subject to the law.
    • The notice must inform the retailers that the covered battery-embedded products included in the notice are subject to a covered battery-embedded waste recycling fee pursuant to PRC Section 42464(b).
    • The notice does not have to specify the fee amount. Rather, the notice must specify that the product is subject to a covered battery-embedded waste recycling fee.
    • Please note, the covered battery-embedded waste recycling fee has not yet been determined. CalRecycle presented proposed regulatory language establishing a covered battery-embedded waste recycling fee at an informal emergency rulemaking workshop on May 28, 2025. The proposed covered battery-embedded waste recycling fee regulations are available on CalRecycle’s covered battery-embedded products informal rulemaking workshop public notice.
  • On or before July 1, 2025, and every year thereafter, a manufacturer shall also send a notice that identifies any product manufactured by that manufacturer that is exempt from the covered battery-embedded definition.
  • Manufacturers subject to the requirements of PRC section 42466.2 must send copies of the notices to CalRecycle by emailing them to CEDmanufacturers@calrecycle.ca.gov.

Failure to provide the required information to all retailers by July 1, 2025, may result in enforcement action by CalRecycle.

Template for Notifying Retailers
  • CalRecycle has developed a recommended template that may be used to notify all retailers. This template is optional.
    • The template includes required fields, which are marked with an asterisk.
    • The template also includes optional fields.
      • Manufacturers are strongly encouraged to complete the optional fields, particularly the individual covered battery-embedded product’s universal product code (UPC) to help all retailers easily identify covered battery-embedded products subject to the covered battery-embedded waste recycling fee.
    • Please note that CalRecycle intends to upload these forms directly to its website without review for or consideration of any confidential, trade secret, or proprietary information.

Manufacturer Reporting Information for Video Display Devices

Video display device manufacturers (PRC Section 42463 (q)(1)(A)-(C)) that sell Covered Electronic Devices (CEDs) in California are required to submit an annual report to CalRecycle. The manufacturer report is due on or before July 1 of each year, covering the previous calendar year.

Updated reporting template forms, revised in May 2025, are available to assist in complying with regulations:

  • CalRecycle 242: This form is intended to help manufacturers meet the annual reporting requirements for CEDs sold in California. A separate form 242 is required for each brand.
  • CalRecycle 242 Instructions

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Report Content Requirements

Refer to the applicable statute and regulations for reporting requirements. The annual manufacturer report must include the following information per Title 14 of the California Code of Regulations, section 18660.41:

  • General Information.
  • Sales Data.
  • Material Reporting.
  • Recycled Content.
  • Design for Recycling.
  • List of Retailers Notified.
  • Consumer Information.
  • Manufacturer Certification.

The manufacturer is responsible for submitting the reporting requirements covering the general information and bullets 4 through 8 above when a “collective report” is submitted on their behalf.

Top Problems with Recent Reporting

  • Failure to submit.
  • Reports submitted late.
  • Failure to submit information by brand.
  • Reports did not contain all the required information.
  • Manufacturer submitted with a collective report, but did not submit the other required information, therefore report is incomplete.
  • Manufacturer submitted report without a signature.

To ensure compliance with the CED manufacturer reporting requirements, CalRecycle recommends carefully reading and following the statute and regulations. Interested parties are encouraged to subscribe to an email newsletter for developments and event information.

Submit completed reports and supplemental documentation electronically to CEDManufacturers@CalRecycle.ca.gov

Manufacturer Reporting Information for Covered Battery Embedded Products

On or before July 1, 2027, manufacturers of covered battery-embedded products must begin sending CalRecycle annual Manufacturer Reports, covering the previous calendar year.

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Report Content Requirements

Refer to the applicable statute and regulations for reporting requirements. The annual manufacturer report must include the following information per Title 14 of the California Code of Regulations, section 18660.41.5:

  • General Information.
  • Sales Data.
  • Embedded-battery Chemistry.
  • Recycled Content.
  • List of Retailers Notified.
  • Consumer Information.
  • Manufacturer Certification.

The manufacturer is responsible for submitting the reporting requirements covering the general information and bullets 4 through 8 above when a “collective report” is submitted on their behalf.

Manufacturer Take-Back Program  

CalRecycle implements portions of legislation that establish a funding system for the collection and recycling of certain electronic wastes. Prospective participants must be approved prior to participating.

This application form is to be used by manufacturers intending to participate in the Covered Electronic Waste (CEW) Recycling Program. Interested parties should review all requirements in the regulations and comply with all federal, state and local laws and regulations.

Note: No payments will be made for activities conducted prior to registration approval.

Note that, depending on a handler’s activities, other DTSC requirements may apply. See DTSC’s Electronic Waste page for details.

This page is for informational purposes only; it does not list all requirements in statute and regulations.

For more information contact: Covered Electronic Waste Recycling Program, CEDManufacturers@calrecycle.ca.gov