SB 615 builds a statewide framework that makes the entities that place vehicle traction batteries into California responsible for those batteries’ end‑of‑life management. The bill defines battery-related roles, adopts a battery management hierarchy (reuse/repair/remanufacture → repurpose → recycle), requires annual reporting to the Department of Toxic Substances Control (DTSC), and directs DTSC to certify qualified battery recyclers and issue implementing regulations by mid‑2028.
The statute also creates a Battery Traction Recovery Fund funded by battery suppliers to cover DTSC’s regulatory costs, requires suppliers to fully fund collection and certain transport costs, establishes recordkeeping and access requirements, and bars criminal penalties while preserving civil and administrative enforcement. For manufacturers, dealers, recyclers, and secondary markets, SB 615 rewrites who is financially and operationally responsible for EV battery lifecycle outcomes and forces traceability and certification into the supply chain.
At a Glance
What It Does
The bill makes the party that supplies a vehicle traction battery into California—typically the vehicle manufacturer or branded battery supplier—responsible for ensuring batteries are reused, repaired, remanufactured, repurposed, or recycled according to a prescribed hierarchy and reported annually to DTSC. It requires DTSC to adopt regulations, certify qualified recyclers, and establish reporting systems and fees to recover regulatory costs.
Who It Affects
Vehicle manufacturers and branded battery suppliers, aftermarket and replacement battery importers, automobile dismantlers and repair shops that act as secondary handlers, secondary users that repurpose batteries, and qualified recyclers seeking certification. Retailers and dealers must check DTSC’s compliance list before selling new batteries.
Why It Matters
SB 615 operationalizes extended producer responsibility for traction batteries, creating mandatory traceability, reuse pathways, and recycler performance metrics. It shifts collection and end‑of‑life costs onto suppliers, which will affect product design, aftermarket pricing, and the development of in‑state recycling capacity and domestic material recovery chains.
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What This Bill Actually Does
SB 615 opens by defining the vocabulary it will use—who counts as a battery supplier, what qualifies as a vehicle traction battery, and who are secondary handlers and users. The law excludes lead‑acid batteries and any battery under seven kilowatt‑hours from its scope, but otherwise captures manufacturer‑supplied battery packs installed in vehicles registered in California and standalone traction batteries brought into the state.
At its core, the bill assigns clear, ongoing responsibilities to the battery supplier. A supplier must follow a battery management hierarchy that prioritizes reuse, repair, or remanufacture first; when those are infeasible or uneconomic, the supplier must ensure the battery is repurposed or recycled.
The supplier must also fully fund collection costs for batteries it is responsible for, provide accessible battery state‑of‑health data to secondary actors where feasible, and report sales, transfers, and dispositions annually to DTSC.DTSC gets rule‑writing authority with a hard date: adopt implementing regulations by July 1, 2028. Those regulations will create the reporting form and method, set criteria for when a battery’s unique identifier is required (and when the vehicle identification number can substitute), specify the certification process for qualified battery recyclers, and define how regulatory costs are allocated among suppliers.
DTSC must publish aggregated disposition data publicly while protecting proprietary information.The bill also reshuffles responsibilities downstream. Secondary handlers that remanufacture become treated as battery suppliers and must rebrand remanufactured batteries per DTSC guidance.
Auctioneers, salvage auctions, and qualified recyclers must report transactions; dealers and retailers must monitor DTSC’s compliance list and cannot sell batteries from suppliers not listed as compliant. SB 615 establishes the Vehicle Traction Battery Recovery Fund to receive supplier payments to cover DTSC’s implementation and enforcement costs, and it limits penalties to civil and administrative measures.
The Five Things You Need to Know
DTSC must adopt implementing regulations by July 1, 2028, or sooner, that create reporting forms, certification criteria, and cost‑allocation rules.
The law excludes lead‑acid batteries and any traction battery with less than seven kilowatt‑hours from its scope.
Battery suppliers must fully fund collection of batteries they are responsible for and may be required to transport vehicles or buy back vehicles if a dealer cannot sell a delivered vehicle due to supplier noncompliance.
A secondary handler that remanufactures a traction battery becomes a battery supplier under the statute and must rebrand and label the remanufactured battery per DTSC requirements.
DTSC will publish annual compliance lists (suppliers and qualified recyclers); retailers and dealers may not sell batteries manufactured on or after the most recent list date unless the supplier is listed as compliant, and violations are subject to civil or administrative penalties only.
Section-by-Section Breakdown
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Definitions and scope
This opening section establishes all operative definitions: battery cell/module, battery supplier (a cascading definition that covers manufacturers, brand owners, importers, and ultimately distributors/retailers), secondary handler/user, orphaned and stranded batteries, qualified battery recycler, and the exclusion for lead‑acid batteries and batteries under seven kWh. Practically, the cascading ‘‘battery supplier’’ definition creates predictable legal target(s) at each level of the supply chain and prevents suppliers from evading responsibility by hiding behind intermediaries.
Primary duties of battery suppliers, secondary users, and handlers
This provision assigns who must ensure responsible end‑of‑life management and when. A battery supplier must follow the battery management hierarchy, fund collection costs, provide state‑of‑health information when feasible, and accept batteries offered or returned. Secondary users and handlers must also follow the hierarchy and report transfers, but a secondary handler that remanufactures becomes the functional battery supplier and picks up full supplier obligations (including rebranding). Operationally, this creates a set of decision points—who owns the battery at removal, whether remanufacture occurs, and contractual pathways to transfer financial responsibility.
Regulation, reporting, and recycler certification
DTSC must write detailed regs covering annual reporting (initial sale, interstate exports, transfers, unique identifier rules, and final disposition), certification and recertification criteria for qualified battery recyclers, data DTSC will post publicly, and how to assign regulatory costs to suppliers. The regs must include traceability elements (chemistry, voltage, capacity), standards to exclude recycling technologies that produce significant hazardous waste, and processes for safety training and appeals for recycler certification. These mechanics will determine how traceable and audit‑ready the battery stream becomes.
Registration, audits, records, and funding
Suppliers must register contact info and product lists with DTSC and update them annually; failure to account for a sold battery in reporting triggers noncompliance after two years. DTSC may audit facilities, demand records within 14 days, and require five‑year retention of records, with noncooperation constituting a violation. DTSC will estimate and bill suppliers for actual regulatory costs; monies flow into the newly created Vehicle Traction Battery Recovery Fund to pay for implementation, enforcement, and to reimburse start‑up loans.
Transfers, orphaned batteries, compliance lists, and dealer obligations
The bill provides routes for non‑suppliers to hand off batteries—return to suppliers or sell to secondary handlers or recyclers—and directs DTSC to study orphaned and stranded batteries and propose regulatory fixes if needed. DTSC must publish annual lists of compliant suppliers and certified recyclers; retailers and dealers must consult that list and are barred from selling batteries from noncompliant suppliers. The statute also gives dealers a right to request manufacturer buyback of unsellable vehicles or batteries in certain cases.
Enforcement and penalties
Violations are subject to civil and administrative enforcement under DTSC’s existing statutory framework; the bill expressly disallows criminal penalties for breaches of this article. DTSC can also publicly identify noncompliant suppliers on its website, which functions as a compliance lever separate from monetary penalties.
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Who Benefits
- Secondary users and remanufacturers — clearer access to state‑of‑health data and formalized pathways to repurpose or remanufacture batteries increases secondary‑use markets and creates legal clarity for resale and reuse activities.
- Qualified battery recyclers that meet certification standards — certification and annual reporting create predictable demand signals and price‑setting ability for recyclers that can demonstrate high recovery yields for lithium, cobalt, nickel, and copper.
- Municipalities and public health actors — the bill reduces the risk of abandoned or improperly disposed batteries by creating traceability, supplier accountability, and an explicit mechanism to study and address orphaned batteries.
- Battery suppliers that invest in design for reuse and recyclability — suppliers that build traceability and easy‑to‑service batteries will face lower lifecycle costs and reputational risk as the law incentivizes design choices consistent with the hierarchy.
Who Bears the Cost
- Battery suppliers and vehicle manufacturers — they must fund collection, pay DTSC’s regulatory costs, invest in traceability systems, and potentially buy back vehicles or transport batteries at their expense.
- Retailers and small distributors — required to check DTSC compliance lists and may lose saleability for inventory from noncompliant suppliers, increasing operational risk and potential inventory write‑downs.
- Secondary handlers and recyclers seeking certification — meeting DTSC’s qualified recycler criteria (safety training, recovery yield reporting, technology constraints) may require capital investment and process changes.
- DTSC and the state budget — although the Recovery Fund is intended to cover implementation costs, DTSC must stand up new regulatory and certification workflows and staffing before full cost recovery ramps up, creating near‑term administrative burdens.
Key Issues
The Core Tension
SB 615 pits a state interest in circularity, traceability, and public‑health‑safe recycling against the practical and financial burden placed on suppliers and downstream actors: the law advances material recovery and liability clarity but forces suppliers and smaller participants to absorb collection, reporting, and certification costs that could raise prices, inhibit aftermarket competition, or delay deployment of new recycling technologies.
SB 615 sets a clear regulatory direction but leaves consequential implementation choices to DTSC’s forthcoming regulations. Key operational questions include how unique identifiers will be standardized across manufacturers, whether vehicle identification numbers will be an adequate surrogate for some OEM‑installed packs, and how the state will reconcile data access and intellectual property or safety concerns when suppliers are asked to make state‑of‑health data ‘‘easily interpretable and accessible.’n
The bill also creates economic tradeoffs. Allocating full collection and reporting costs to suppliers pressures product design and business models, but it may also concentrate costs among a few large OEMs while smaller aftermarket actors struggle to comply.
The qualified recycler standards (including exclusions for recycling technologies that generate substantial hazardous waste) aim to steer recycling toward cleaner processes, yet they could disadvantage lower‑cost or international recyclers and slow scaling of domestic capacity if criteria are too restrictive. Finally, the remanufacturer → supplier conversion clarifies liability but may discourage small remanufacturers unless DTSC sets proportional compliance pathways and realistic labeling requirements.
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