Posted October 8th, 2026 in Top Stories, Legal Insights with Tags Kathleen Curtis, David DJ Warden, Micromobility

California Expands Battery Stewardship Law to Cover E-Bike and Other Medium-Format Batteries

On September 20, 2026, Governor Newsom signed SB 501 (Sen. Benjamin Allen, D-Santa Monica), now Chapter 414, Statutes of 2026, significantly expanding California’s Responsible Battery Recycling Act of 2022. The amendment adds a new “medium-format” battery category, covering batteries used in products such as e-bikes, portable generators, electric lawn and garden equipment, and UPS backup systems. Medium-format batteries will now be included in the state’s producer stewardship framework alongside the small-format batteries already covered. While SB 501 takes effect on January 1, 2027, CalRecycle’s implementation of the regulations remains pending final approval of the currently proposed regulations. Companies should use this time to confirm any necessary stewardship-plan participation and evaluate whether their products/batteries are now covered under the law’s amended scope.

What’s changing:

New battery category. “Covered batteries” now include medium-format batteries (generally, rechargeable batteries weighing more than 11 lbs. or rated above 300 watt-hours, up to 25 lbs./2,000 watt-hours). This brings many e-bike battery packs squarely within the scope of California’s battery stewardship program, and eliminates prior battery exclusions.

Format-specific stewardship plans. Program operators must submit plans identifying which format(s), small, medium, or both, they cover, with format-specific collection networks and demonstrated recycling performance.

Retailer collection obligations narrow, not disappear. Retailers with five or more California locations must still maintain permanent collection sites, but those sites are required to accept only small-format batteries unless separately designated as medium-format collection points under a stewardship plan. Therefore, it must not be assumed that all existing collection sites will accept medium-format batteries.

“Easily removable” clarified. A theft-deterrent lock, key, or app doesn’t disqualify a battery from being “easily removable,” so long as it doesn’t block the consumer’s ability to remove, replace, or recycle the battery.

Recycling efficiency targets. Once the law takes effect, program operators must achieve a 60% recycling efficiency rate for rechargeable batteries and 70% for non-rechargeable batteries, reported annually.

Practical guidance for e-bike and micromobility companies:

Reassess product scope. Confirm whether your battery packs now fall into the medium-format category under the new weight/watt-hour thresholds. This may pull products that were previously exempt or unclassified into the stewardship program.
Revisit “easily removable” design and marketing claims. If your battery uses a lock, an app-based release, or a similar anti-theft feature, confirm that your design and consumer disclosures align with the clarified standard.
Check your stewardship plan (or your stewardship organization’s plan). If you participate through a third-party program operator, confirm they are amending their plan to specify medium-format coverage and are building out compliant collection infrastructure.
Watch CalRecycle’s rulemaking. The underlying 2022 Act still isn’t implemented. CalRecycle’s regulations are pending, and SB 501 may prompt the agency to revise its proposed rules to reflect the new categories.
Don’t assume retail collection covers you. With retailer obligations now split by format, confirm your take-back and recycling logistics for medium-format batteries independently. Don’t rely on general in-store bins.

We’re continuing to monitor CalRecycle’s regulatory process and will provide updates as implementing rules take shape.

NJL partners with manufacturers designing and building the next generation of electric vehicles, including bikes and scooters, and tracks this fast-moving regulatory landscape so our clients can bring products to market with confidence. In today’s world, this includes advising manufacturers on extended producer responsibility programs, battery end-of-life obligations, product labeling, and emerging state stewardship requirements that increasingly affect the sale, warranty, and/or return of micromobility products.