“The ink is just now dried, probably.”
That was the first thing Danielle Spalding said when asked about Colorado Gov. Jared Polis signing SB26-003 into law, legislation specifically targeting electric vehicle (EV) propulsion batteries. The bill was signed on June 3.
SB26-003 is an extended producer responsibility (EPR) framework specifically targeting EV propulsion batteries, making it one of the first states to leverage legislation to manage large-format batteries.
Spalding, senior vice president of corporate and external affairs at Cirba Solutions, helped shape the legislation that the General Assembly passed on May 14. It expands Colorado’s Battery Stewardship Act, established under SB 25-163 in 2025, to cover the largest and most hazardous battery stream in the vehicle recycling system.
California is moving on the other end of that spectrum.
SB 501, authored by Senator Ben Allen and co-sponsored by NSAC, the Resource Recovery Coalition of California and the Rural County Representatives of California, passed the Senate 30-10 on May 27 and heads to an Assembly Environmental Safety and Toxic Materials Committee hearing June 16.
The bill revises California’s Responsible Battery Recycling Act of 2022 to add medium-format batteries, defined in the bill text as rechargeable batteries weighing between 11 and 25 pounds, or rated between 300 and 2,000 watthours. The category covers e-bikes, lawn equipment and portable power systems.
Handle with care
Battery EPR has spent years building out coverage for small format items. Large-format propulsion batteries have operated largely outside those frameworks because the logistics, regulation and collection pathways are on a different scale.
“The shape, size, weight and energy density create much more unique challenges,” Spalding told Resource Recycling. “Large format batteries for propulsion batteries specifically are more business-focused versus consumer-focused. The education target is very different, but also how you handle them.”
The transactions don’t look the same either. A consumer dropping off an e-bike battery at a collection site and a dismantler routing a 1,000-pound EV pack through a secondary market are operating under entirely different conditions, she said.
Under SB26-003, automakers and EV battery manufacturers are required to collect unwanted batteries from secondary handlers such as dismantlers and solid waste facilities at no cost to them. Approximately 330,000 vehicles reach end-of-life in Colorado annually, and automotive recycling facilities process the majority of them.
The Automotive Recyclers Association, which supported the bill, said SB26-003 “addresses emerging battery management challenges that are already putting pressure on vehicle recycling infrastructure.”
Step by step
Colorado’s implementation rolls out in defined stages. A landfill disposal ban takes effect July 1, 2029. Labeling requirements and secondary handler obligations begin on the same date.
Battery recyclers face minimum critical mineral recovery targets starting in 2031 at 90% for cobalt and nickel and 50% for lithium. The lithium threshold climbs to 80% by 2035. Recovery is calculated using a mass balance approach at the facility level, with annual public reporting beginning in 2030.
The four-year gap between now and first public reporting drew questions about whether the interim period operates without accountability. Spalding pushed back.
“There’s a lot of vetting that happens before even contracts are put into place,” she said. “Making sure partnerships can meet expectations on recycling efficiency rates, logistics and transportation, DOT compliance. There are so many inner workings that go on behind the scenes, even though reporting is only at one point.”
Eyes on California
CalRecycle estimates 7,294 tons of batteries are improperly disposed of in California landfills annually, and batteries are the top cause of fires in the state’s waste facilities.
Medium-format batteries have largely fallen outside the reach of mandatory collection requirements.
SB 501 builds on work California has been doing since 2022 to build out safer collection infrastructure. AB 2440 that year required producers of loose batteries to set up a producer-run take-back program.
SB 1215 added battery-embedded products to the state’s e-waste program in September 2022. SB 501 adds the medium-format tier neither bill captured.
The California bill is another piece of legislation other states are carefully watching.
“California is often not the end point. It’s a signal within the market,” Spalding said. “Many states have yet to adopt and fully address newer battery types like e-bikes and portable power systems, and that can sometimes leave a gap.”
Spalding stressed the importance of consumer education.
“Oftentimes the biggest gaps for people to recycle batteries is one, I didn’t know you could do it, and two, I don’t know where to do it,” she said. “Consumer education is truly the starting point to ensure that we can enhance and close the loop on the battery supply chains that we have.”
Keeping up
Domestic recyclers can already process used batteries to black mass. What’s still being built is the refining capacity that takes that black mass the rest of the way, extracting the critical minerals that feed back into new battery production, Spalding said.
“Domestic battery recyclers in North America today could recycle all of the used batteries if they were to be recycled to black mass,” she said. “What we’re focused on building out now is the refinement of that black mass.”
As for what comes next, Spalding said the domestic recycling infrastructure is already there. The work now is refining black mass into the critical minerals that feed back into new battery production.
“I think we see a future that allows the United States to be at the forefront of not just EV battery recycling,” Spalding said. “It is truly going to hopefully be an export event of critical minerals on a global scale, and believe it or not, all of that begins with recycling your batteries.”
