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Reference Library

Battery Recycling Program (BRP)

by Industrial Battery & Charger, Inc.

Introduction and Scope
Regulatory Requirements
Standard Battery Recycling Procedures
Documented Battery Recycling Program
Nickel-Cadmium (NiCd) Battery Information
Comparative Risk

Introduction and Scope:
Industrial Battery & Charger, Inc. (IBCI) has been in the battery business since 1977. Long before the environment became a social issue, IBCI was actively involved with the collection and recycling of lead-acid batteries. We are pleased to be a part of an industry where over 95% of its products are recycled.

In recent years, regulatory and social pressures have combined to necessitate the proper management of lead containing products. In the case of lead-acid batteries, it is widely recognized that protection of human health and the environment is a shared responsibility between industry and those who distribute, collect, process and use these products.

IBCI maintains a leadership role in environmental stewardship by offering a program to accept used lead-acid batteries. The purpose is to provide a proper and safe means of recycling scrap lead-acid batteries through an approved secondary smelter. Upon request, documentation confirming proper transport and disposal will be provided. This program provides our customers with documentation that goes beyond regulatory requirements.

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Regulatory Requirements:
The following paragraphs summarize the regulatory status of used lead-acid batteries.

Facilities, which generate certain recyclable material, are not subject to most of the hazardous waste regulations of the Resource Conservation and Recovery Act (RCRA). This general exemption applies to spent lead-acid batteries being reclaimed and is found in Title 40 CFR 261.6 (a) (2) (v).

Title 40 CFR 266.80 Applicability and Requirements, Subpart G of RCRA states: “The regulations of this subpart apply to persons who reclaim spent lead-acid batteries that are recyclable material ‘(spent batteries)’. Persons who generate, transport, or collect spent batteries, or who store spent batteries, but do not reclaim them, are not subject to regulation under Parts 262 through 266 or part 270 or 124 of this chapter and also are not subject to the requirements of section 3010 of RCRA.”

This generally exempts generators from the requirements for hazardous waste manifests, placarding, labeling, marketing, record-keeping (262), EPA Identification Number (263), and personnel training and contingency planning (265).

Regardless of the hazardous waste exemptions, the sulfuric acid and lead components of a lead- acid battery are hazardous materials which could be hazardous wastes if improperly managed or disposed. Under “cradle to grave” provisions of RCRA, waste generators remain responsible for the ultimate disposal of their materials. No person nor company can relieve the generator of their responsibility for proper waste management or disposal.

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Standard Battery Recycling Procedures:
IBCI does not own or operate a recycling facility. However, we have established relations with only those secondary smelters that have environmentally clean records and proper federal and state approvals. The following facilities are currently IBCI approved:

EPA ID: PDA 990753089

EPA ID: ALD 046481032

EPA ID: NYD 030485288

EPA ID: IND 000199653


    EPA ID: NYD 030485288
    EPA ID: IND 000199653
    EPA ID: CAD 066233966

Batteries received may be shipped directly to the EPA approved facility or to an IBCI facility prior to transport to a smelter. Temporary storage practices at Industrial Battery & Charger, Inc. include proper handling, consolidation and packaging thus preventing potential exposure to individuals and/or release of contaminants to the environment. All Industrial Battery & Charger, Inc. facilities are exempt from registration under RCRA. This exemption is noted in Title 40 CFR Part 266.80, Subpart G.

There is currently no regulatory standard for documentation of scrap lead-acid battery shipments to secondary smelter facilities beyond DOT bill of lading requirements. Therefore, under the standard practices of the Battery Recycling Program, IBCI retains only general records of scrap lead-acid batteries collected and shipped to secondary smelters. A documented program is available on request.

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Documented Battery Recycling Program:
The following program provides documentation of the collection, transportation and delivery of specific shipments to EPA approved secondary smelter facilities. The basic mechanism used to implement this documentation is a multi-part bill of lading which confirms pickup, transport and receipt by an approved smelter.


  1. The Battery Recycling Program is limited to only whole batteries and cells such as automotive, industrial steel case and industrial cells which are of lead/antimony or lead/calcium alloy. Any other composition such as nickel/cadmium or nickel/iron will be returned to the generator at their expense.
  2. All shipments are subject to pre-approval by IBCI.
  3. All shippers/generators must agree to follow Industrial Battery & Charger, Inc. shipping document and labeling standards.
  4. Transportation will be coordinated and scheduled by IBCI.


  1. Battery packaging, marking and labeling must conform to all appropriate Department of Transportation and state regulations. This is the responsibility of the shipper or generator. This can be done at customer locations or at IBCI facilities. Note: the shipper or generator is defined as the customer or the person originating the battery recycling process.
  2. Automotive and Industrial batteries cannot be shipped on the same pallet.


  1. Shipper/generator must agree to cooperate with transportation scheduling and pickup arrangements made through Industrial Battery & Charger, Inc.
  2. Upon delivery and acceptance of the shipment by the IBCI approved smelter, a “Document of Waste Material Recycling” and a copy of the “Bill of Lading” will be returned to the shipper/generator.

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Nickel-Cadmium (NiCd) Battery Information:
EXCLUSION: Industrial Battery & Charger, Inc. does not accept nickel-cadmium (NiCd) batteries under this Battery Recycling Program. NiCd batteries are subject to special regulations and requirements that are distinctly different. Therefore, NiCds that are intended for disposal must be managed accordingly. They can be shipped only by appropriate manifest destined to a facility legally permitted to manage this type of waste. Neither Industrial Battery & Charger, Inc. nor its secondary lead-acid smelters are registered or otherwise permitted to accept or dispose of NiCd batteries. Furthermore, nickel-cadmium and lead-acid batteries cannot legally be packaged or processed together.

However, our Stationary Power Division is set up to support your Industrial size Nickel-Cadmium (NiCd) battery disposal/recycling needs. For more information and a quotation covering regulatory compliant disposal/recycling of your Industrial size nickel-cadmium (NiCd) batteries, please contact our Stationary Power Division at 800-833-8412 or 704-597-7330.

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Comparative Risk:
The use of several EPA approved secondary smelters allows Industrial Battery & Charger, Inc. the opportunity to minimize potential Superfund remedial liabilities. Under the “joint and several liability” provisions of the Superfund regulations, the liability for disposal and waste management remains with the generator. However, the potential risk to the generator may be diminished by utilizing the IBCI approved secondary smelting facilities.

The Battery Recycling Program gives our customers assurance that each secondary smelter being used by IBCI meets the regulatory criteria for operation under the Resource Conservation and Recovery Act. Our customers can rely on the experience and expertise of IBCI with regard to the disposal of their lead-acid batteries. Your environmental concerns are our concerns. It is our opinion that a customer assumes less risk by disposing of its scrap lead-acid batteries through IBCI than by dealing directly with a battery manufacturer who owns its own smelter.

We offer the advantages of numerous qualified facilities and over 24 years of experience in the battery industry. The major advantage is placing Industrial Battery & Charger, Inc. between you and the EPA.

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