The Illinois Portable and Medium-Format
Battery Stewardship Act

by Barb Day

The Illinois Portable and Medium-Format Battery Stewardship Act, signed into law in August 2024, establishes a statewide program requiring battery producers to fund and manage the collection, transportation, and recycling of covered batteries. This includes portable primary and rechargeable batteries, as well as medium-format batteries (weighing 4.4 to 25 pounds). The program, overseen by the Illinois Environmental Protection Agency, aims to ensure convenient collection and promote public awareness about proper battery disposal. It takes effect on January 1, 2026, with the stewardship program beginning on that date. Starting January 1, 2028, it will be illegal to dispose of covered batteries in regular trash or recycling. Retailers cannot sell batteries from producers not participating in an approved program starting July 1, 2026.

The Act aims to encourage material recovery, reduce environmental impact, increase safety, and improve battery recycling. The act excludes medical devices and vehicle batteries.

Non-compliance with this Act in Illinois can result in significant penalties for battery producers, retailers, and other obligated parties. These penalties may include a $7,000 fee per violation, enforced by the Illinois Environmental Protection Agency (IEPA). Knowingly making a false material statement to the IEPA in relation to or required by the Act constitutes a Class 4 felony, with each false statement considered a separate offense.

The definition of “producer” under the Act depends on whether the item is a covered battery sold individually or a product containing a covered battery:

• For Covered Batteries (sold individually): the producer is typically the battery manufacturer if sold under their brand, or the brand owner if sold under a retail or other brand. If neither applies, it's the brand or trademark licensee. If none of these are in the US, the importer of record is the producer. If none of the above are commercially present in Illinois, the first person to sell or distribute the battery in Illinois is the producer.

The IEPA has specific criteria for approving battery stewardship plans submitted under this Act. These criteria aim to ensure the program effectively manages end-of-life batteries and promotes responsible recycling. Key requirements for a battery stewardship plan to be approved include:

• Performance Goals: The plan must set targets for collection rates (both primary and rechargeable batteries), recycling efficiency rates (at least 60% for rechargeable and 70% for primary), and increasing public awareness.
• Collection Infrastructure: The plan needs to detail how statewide collection will be provided, specifying the number and location of permanent sites and events for both portable and medium-format batteries based on population distribution.
• Funding: A system for collecting charges from participating producers to cover program costs is required.
• Education and Outreach: The plan must include activities to educate the public about battery recycling, such as developing a website and using various promotional methods.
• Safety: Procedures for collection site safety training must be included.
• Annual Reporting: The plan should outline how annual reports detailing the program's effectiveness, finances, collection data, and progress will be submitted.

On June 30, 2025, Call2Recycle Stewardship, Inc. (Call2Recycle) submitted a Battery Stewardship Plan to the Illinois Environmental Protection Agency (IEPA) for approval to operate a Battery Stewardship Program on behalf of over 250 producers. In developing this plan, Call2Recycle engaged in discussions with key stakeholders across the state, including the IEPA, household hazardous waste (HHW) and electronics recycling groups, and city officials. The final plan reflects the valuable input gathered from these stakeholders, ensuring that Call2Recycle delivers a compliant and comprehensive program that effectively serves the businesses and residents of Illinois.