California Embedded Battery Recycling Fee Kicks in January 1, 2026

Starting January 1, 2026, retailers of covered battery-embedded (CBE) products in California must charge consumers a CBE Waste Recycling Fee at point of purchase or cover the costs of the fee themselves. Per regulations finalized last week, the fee will be 1.5% (capped at $15) of the retail sales price of a CBE product. Proposed regulations that would clarify related requirements are still pending as of this writing.

The CBE Waste Recycling Fee is required under SB 1215, which we previously wrote about here. To review, CBE products are those that contain batteries that are “not designed to be easily removed from the product by the user of the product with no more than commonly used household tools.” These do not include products that incorporate video display devices measuring greater than four inches diagonally (such products are separately subject to California’s Covered Electronic Waste (CEW) Recycling Fees) or standalone batteries (which will be covered by future requirements under AB 2440, as we wrote about here). However, the scope of CBE products remains unclear since the proposed regulations add new definitions, including one for “commonly used household tools.” If finalized in their current form, these definitions could affect how broadly the fee applies.

July 2025 Manufacturer Notice

While clarifying regulations on the scope of SB 1215 are still pending, in addition to the January 1, 2026, fee deadline applicable to retailers, manufacturers of CBE products were subject to an earlier notification deadline. By July 1, 2025, manufacturers were required to send annual notices to retailers and the California Department of Resources Recycling and Recovery (CalRecycle) identifying covered and exempt CBE products. Depending on the number of SKUs involved, completing that notice could be a significant undertaking, but the January 1 fee requirements may pose the greatest logistical challenges, as retailers grapple with implementation while simultaneously dealing with the holiday season and end-of-year restrictions on their ability to implement website and other software updates.

January 2026 Retailer Fee Collection and Receipt Notices

In addition to collecting fees starting January 1, 2026, retailers must also update language on receipts provided to consumers by that date. Retailers must ensure that consumer receipts separately identify and state the CBE Waste Recycling Fee as of the effective date. If the retailer pays the CBE Waste Recycling Fee on behalf of consumers, then an express statement must be provided on the receipt to make clear that the fee was paid on the consumer’s behalf.

The fees must be remitted to the California Department of Tax and Fee Administration (CDTFA) on or before April 30, 2026. The portal for retailers to register with CDTFA and remit fees is currently open. Guidance on CDTFA’s website states that the fee cannot be included in a sales or use tax calculation; it must be on the retail sales price of a CBE product. A retailer may retain 3% of fees collected as reimbursement for its fee collection costs.

Neither CDTFA nor CalRecycle provide much additional guidance on how receipt disclosures should be communicated. On the one hand, this affords retailers some flexibility in the disclosure, but many retailers may find themselves scrambling to implement the new fees and update receipt language.

Any business selling covered CBE products to consumers in California must register with the CDTFA and collect the fee, even if they are not physically located in the state.