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On Nov. 8, CalRecycle held a workshop on labels required for products with batteries. This workshop was a good opportunity to point out that, under California law: "no person shall sell or offer for sale in this state any rechargeable consumer product unless the product meets all of the following requirements: (1) The rechargeable battery is easily removable from the rechargeable consumer product or is contained in a battery pack that is easily removable from, the product."
You have probably noticed that you have a lot of products with batteries that are not only easily removable, they are essentially impossible. The original law specified the battery types which the law would apply to, and it not include lithium-ion cells, which are the most common batteries in our modern electronics.
We submitted the letter below to improve the labeling of products, but we believe more needs to be done to address the issues around consumer products with unremovable batteries.
Re: CalRecycle Informal Rulemaking Workshop Dry Cell Battery Management Act: Amendment to Labeling Requirements
Friday, November 8, 2019
We are pleased to see CalRecycle addressing issues with batteries in the waste stream. The stated goals of PRC § 15013 include requiring that for all products which contain rechargeable batteries, those batteries should be easily removable. As you know, there are many consumer products that fall far short of these goals.
The law describes the commonly-used battery types at the time of its adoption, but battery technologies have changed rapidly since then, and lithium-ion batteries are the most common type of rechargeable batteries in consumer products.
The gap between the rules for older rechargeable battery types and the way batteries are used in modern products is enormous, and this comes at a cost. We believe an important intermediate step in addressing this gap is to label whether or not a lithium-ion battery is replaceable.
We believe the best way to define whether or not a battery is replaceable would be whether the manufacturer provides instructions on how to replace the rechargeable battery using commonly available tools (these instructions, ideally, would also include how to safely handle the used battery). Products that contain a non-replaceable battery should be labeled as such on the outside packaging of the product. We also request that the label for a product with a non-replaceable battery should include the lifespan of the product.
These additional changes would enable consumers to include battery-replaceability as a part of their purchasing decisions. Rechargeable batteries are guaranteed to eventually wear out and are a common mode of failure for electronic devices. If manufacturers design products this way, they should indicate the lifespan to the consumer. When the batteries cannot be replaced, it significantly reduces the long term value of the device. Consumers should be informed.
Consumers who buy products with replaceable batteries should be given proper instructions for safely replacing the battery. This would also make processing safer at waste management facilities -- addressing well-documented safety concerns.
Our recent report, What are Californians Fixing?, shows that of the near 8 million unique visitors to iFixit’s online repair guides in California in 2018, the most popular guides dealt with battery replacement and other battery-related issues.
By labeling whether or not batteries are replaceable, consumers would be given the chance to extend the life of their device, providing a better value, and reduce the amount of e-waste that is produced in our state. We are also concerned with fires at waste facilities caused by batteries which are not properly removed, or are too challenging to remove safely. We hope to provide better instructions to facilities, and reduce the amount of battery-powered products disposed of improperly.
There are many benefits to be had by labeling whether or not the rechargeable battery in a device is replaceable and including instructions on how to do the replacement. For these reasons, we recommend that CalRecycle includes these changes in their suggestions.
National Right to Repair Advocate for CALPIRG and U.S. PIRG
National Right to Repair Campaign Director for CALPIRG and U.S. PIRG
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