Manufacturer Notice Guidance
Note: CalRecycle will not be making any determinations regarding whether a specific product is a “covered battery-embedded product” (CBEP) that is subject to Senate Bill (SB) 1215. Consult with your own legal counsel regarding how statutory requirements apply to your business and products.
- The SB 1215 covered battery-embedded product (CBEP) definition is provided in Public Resources Code (PRC) section 42463(f).
- For batteries subject to the AB 2440 Responsible Battery Recycling Act, “covered battery” is defined at PRC section 42420.1(d).
- View the CBEP Decision Tree.
Manufacturer Notice Chart and Data
PLEASE BE ADVISED:
CalRecycle compiled a list of products from notices sent to CalRecycle by manufacturers per PRC section 42466.2. The information contained in the documents was provided by manufacturers, and questions about specific product determinations should be directed to them.
- The PDF Table document consolidates the data from the Manufacturer Notices into an easy-to-read chart that lists categories of products, manufacturer and brand names, and examples of products within each category.
- The Notices Excel spreadsheet lists all noticed products from copies of the Manufacturer Notice that have been provided to CalRecycle. This list is sortable by brand, manufacturer, and device type, and contains product model numbers and UPC numbers (if provided).
By posting these lists of products, CalRecycle does not endorse the accuracy of the list or confirm that these products are covered battery-embedded products (CBEPs), as defined in PRC section 42463(f).
These lists may erroneously include devices that are not CBEPs, such as:
- Products that are video display devices (as defined by PRC section 42463(g)(1)(A))
- Products that are a loose battery (as defined at PRC section 42420.1(d))
- Products that are not considered covered electronic waste
These lists are not complete lists of all CBEPs and are based on the notices that manufacturers provided to CalRecycle.
The absence of a CBEP from these lists does not relieve a manufacturer’s responsibility to notice retailers (per PRC section 4266.2), or a retailer’s obligation to collect the covered battery-embedded waste recycling fee on a CBEP from a consumer.
This list is subject to change. It will be updated periodically, and a listserv notice will be sent out.
*If a retailer, consumer, or other interested party has a concern that one of the products listed is not a CBEP, CalRecycle recommends contacting the manufacturer directly to seek clarification on whether the product is a CBEP. If the manufacturer determines the product is not a CBEP, the manufacturer may re-notice retailers and contact CalRecycle.
Note: CalRecycle will not be making any determinations regarding whether a specific product is a “covered battery-embedded product” (CBEP) that is subject to SB 1215. Consult with your own legal counsel regarding how statutory requirements apply to your business and products.
This decision tree is provided to help the manufacturer determine if their product is a CBEP.
Question 1: Does your electronic device contain a battery?
Answer:
Yes – Go to Question 2
No – Not a CBEP
Question 2: Is your device a covered video display device (VDD)?
i A video display device (VDD) is defined in PRC section 42463(g)(1) as a display device containing a screen greater than 4 inches, measured diagonally, and that is identified in the laws adopted by the Department of Toxic Substances Control (Health and Safety Code section 25214.10.1(c)). See the current list of covered VDDs in the California Code of Regulations (CCR) 66260.201(e).
Answer:
Yes – Not a CBEP
No – Go to Question 3
Question 3: Is the battery-embedded product an excluded energy storage system, medical device, or electronic nicotine delivery system?
i Products with embedded batteries that are identified in the law as excluded from the definition of a CBEP are listed in PRC section 42463(f)(2). This includes: certain medical devices, existing covered electronic devices (video display
devices), certain energy storage systems, and electronic nicotine delivery systems.
Answer:
Yes – Not a CBEP
No – Go to Question 4
Question 4: Does the product contain a battery that is not designed to be easily removed by the user with no more than commonly used household tools? (PRC 42463(f)(1))
i See CalRecycle’s proposed regulatory definitions of “commonly used household tools,” and “designed to be easily removed…” which were submitted for public comment on 11/20/2025 but are not yet approved.
Note: loose batteries are regulated under the Responsible Battery Recycling Act.
Answer:
Yes – It is a CBEP
No – Visit the Battery Stewardship webpage
‘Yes, It Is a CBEP’ Examples
Your product is a covered battery-embedded product (PRC section 42463(f)(1)). Also see CalRecycle’s proposed regulatory definition of covered battery-embedded product, which were submitted to OAL on 11/20/2025 but are not yet approved.
Covered Battery-Embedded Products (CBEPs) Questions and Answers (Q&A)
Download the PDFIf you have general questions about what is a video display device (VDD) versus what is a CBEP, contact embeddedbatteries@calrecycle.ca.gov.
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.
NOTE: CalRecycle intends to upload these forms directly to its website without review for or consideration of any confidential, trade secret, or proprietary information.
For more information, contact EmbeddedBatteries@calrecycle.ca.gov