The hardest object in the fleet
Retired hardware is mostly inert. Steel, aluminum, glass, plastic, and silicon sit in a closet for years and do nothing. Batteries are the exception, and the data on what they do is not abstract.
In 2021 the U.S. Environmental Protection Agency published an analysis of lithium-ion battery fires in the waste and recycling system. Working from news reports and industry sources, it identified 245 fires at 64 waste facilities between 2013 and 2020 that were caused or likely caused by lithium-ion batteries — 68 at materials recovery facilities, 139 at landfills, 15 in transport vehicles, and 23 at other sites including scrap yards and electronics recyclers. Two-thirds of the affected facilities needed the fire department; 27% experienced more than one battery fire. One materials-recovery facility fire caused about $8.5 million in damage; another facility needed a roughly $30 million replacement. EPA's own caveat — that the count reflects only incidents that made the news — means the real number is higher.
The mechanism behind every one of those incidents is the same, and it is the reason this guide exists. In EPA's words, "when a battery casing is punctured, crushed, or otherwise mechanically damaged, the separator may be pierced," shorting the cell and triggering a fire. Waste and recycling systems are full of things that puncture and crush. So, for that matter, are loading docks, storerooms with pallets stacked on pallets, and shipping boxes packed by someone who did not know there was a battery inside.
Enterprise IT is a large, steady source of the batteries in that stream: every laptop, tablet, and phone retired carries at least one, uninterruptible power supplies are cabinets of them, and servers and storage arrays hide small backup cells on their boards. Unlike most e-waste, batteries do not merely lose value when mishandled. They create hazard — to your facility, to the carrier's truck, and to the people at the recycler's line. That is why they are also the most regulated object in disposition, and why the rest of this guide is mostly about rules.
Batteries are the one component of a retired IT fleet that can start a fire, and the waste system's own data says they do — hundreds of times. Everything downstream of that fact — the waste rules, the transport rules, the handling practices — exists to keep physical damage from turning into thermal runaway.
What thermal runaway actually is
A lithium-ion cell stores energy by keeping two reactive electrodes a fraction of a millimeter apart. Thermal runaway is what happens when that separation fails.
Inside every cell, a thin porous separator keeps the anode and cathode from touching while letting lithium ions pass through a flammable liquid electrolyte. If the separator is breached — by a puncture, a crush, manufacturing defect, or internal degradation — the electrodes short internally. The short generates heat; heat accelerates the chemical reactions and breaks down the electrolyte into gas; gas and heat degrade more of the separator; and the reaction feeds itself. Past a threshold, the cell vents, ignites, or ruptures, and the heat it releases can push its neighbors past the same threshold. That cascade is thermal runaway, and it is why a single damaged cell in a box of healthy ones is a different hazard from a single damaged cell alone.
Three properties of the failure shape every rule in this guide. It is triggered by damage, which is why transport regulations obsess over cushioning, short-circuit protection, and separating cells from each other. It is self-sustaining, burning with its own oxidizer rather than drawing on the air, which is why a battery fire in a shredder or a truck is so hard to put out. And it is energy-dependent: a cell holding more charge has more energy to release, which is the logic behind state-of-charge limits for air transport and behind the general safety preference for storing and moving cells at partial charge.
The swollen battery
A battery that has puffed up — a laptop whose trackpad has lifted, a phone whose screen has separated from its frame — is a cell that has already begun breaking down its electrolyte into gas. It has not entered thermal runaway, but it is signaling that the internal chemistry is degraded and the risk of an internal short is elevated. Regulators treat it accordingly: damaged and defective cells are a separate, more restrictive transport category (Section 05). The practical rules are simple and non-negotiable: do not charge it, do not puncture it, do not stack it with other batteries, isolate it in a non-combustible container, and get it into a certified stream quickly.
Most enterprise battery incidents do not begin at the recycler. They begin in a drawer of retired laptops nobody has looked at in two years, several of which have quietly swelled. The single most effective control an IT team has is a rule that retired devices leave the building on a schedule.
Which batteries you actually have
Before the rules can be applied, the fleet has to be sorted by chemistry and form — because the two dominant chemistries in an enterprise follow different regulatory paths.
| Where it lives | Chemistry & form | Disposition considerations |
|---|---|---|
| Laptops, tablets, phones | Lithium-ion packs, typically 20–100 Wh in laptops; smaller in handhelds; often not user-removable in modern designs | The largest stream by count. Devices are data-bearing, so battery handling sits inside the data-destruction chain of custody. Swollen units are common in aged fleets. |
| UPS systems | Most installed units: valve-regulated lead-acid (VRLA). Newer units: lithium-ion (often lithium iron phosphate) | Two different streams with different waste and transport rules. Identify the chemistry from the unit label or spec sheet before decommissioning (Section 07). |
| Servers, storage arrays, RAID controllers | Small lithium coin cells (CMOS) and battery backup units on controllers | Easy to miss during rack decommissioning; should be removed and segregated during dismantling, not shredded with the chassis. |
| Peripherals & accessories | Lithium-ion in wireless headsets, keyboards, mice, scanners; alkaline and lithium primary cells in remotes and sensors | Small, numerous, and frequently tossed in general waste. Primary lithium cells are also regulated for transport (UN3090/UN3091). |
| Mobile power & tools | Power banks, cordless tool packs, rugged-device spares | Often higher capacity than laptop packs; power banks shipped alone are UN3480 and subject to the strictest air rules. |
Two categories deserve emphasis. First, batteries inside data-bearing devices create a sequencing question: the device must go through certified data destruction, and its battery must be removed and handled as a hazardous stream, and the order and custody of those steps should be documented. Certified processors dismantle the battery out before any mechanical processing of the device precisely to avoid the separator-piercing failure EPA describes. Second, UPS chemistry is the fork in the road for facilities teams: a lead-acid cabinet and a lithium-ion cabinet look similar on a data-center floor and are governed by different rules from the moment they are disconnected.
The waste rules: EPA and the universal waste program
The first regulatory layer is federal hazardous-waste law — the Resource Conservation and Recovery Act — and EPA's position on lithium-ion batteries under it is clearer than most organizations assume.
In a memorandum dated May 24, 2023, and in the FAQ that accompanies it, EPA states that most spent lithium-ion batteries are likely to be hazardous waste when discarded, because they exhibit the characteristics of ignitability (waste code D001) and reactivity (D003). Rather than leave that determination to each generator, EPA recommends that businesses consider managing all of their used lithium batteries as hazardous waste — and specifically that they use the streamlined universal waste rules at 40 CFR Part 273, which were built for common hazardous wastes that are widely generated and destined for recycling or proper disposal. Both rechargeable lithium-ion and single-use lithium primary batteries can be managed as universal waste.
What universal waste handling requires
Universal waste is a relief from the full hazardous-waste manifest-and-permit regime, not an exemption from responsibility. Handlers must label containers as universal waste batteries, contain the batteries so that they cannot short-circuit or leak — which for lithium-ion in practice means taping terminals or bagging cells individually and using appropriate containers — observe the program's one-year accumulation limit, and ship only to another handler or to a destination facility: a permitted hazardous-waste facility or a hazardous-waste recycler. Handler obligations scale with quantity; the program distinguishes small and large quantity handlers at a 5,000-kilogram on-site threshold, with additional notification requirements above it. And the transport of universal waste remains subject to the Department of Transportation rules in Section 05.
State rules can be stricter
RCRA sets a floor, and states administer their own programs on top of it. Several states regulate battery disposal more strictly than the federal baseline — California, which treats batteries broadly as universal waste and bars them from the trash, is the prominent example — and state electronics-recycling laws layer their own requirements on the devices the batteries came out of. For the state-by-state landscape, see the Multi-State ITAD Compliance Field Guide; for any specific obligation, verify with the state agency or counsel.
Federal position: spent lithium-ion batteries are likely hazardous waste; manage them as universal waste — labeled, contained, moved within a year, sent to a permitted recycler. The general trash and the general e-waste bin are both the wrong answer.
The transport rules: 49 CFR 173.185
The second regulatory layer applies the moment a battery moves. Lithium cells and batteries are Class 9 hazardous materials under the Department of Transportation's Hazardous Materials Regulations, and the governing section is 49 CFR 173.185.
The four UN numbers
Lithium-ion cells and batteries shipped alone travel as UN3480; shipped packed with or contained in equipment — a battery inside a laptop, or boxed alongside one — as UN3481. Lithium metal (primary, non-rechargeable) cells follow the same split as UN3090 and UN3091. The distinction matters because the strictest rules attach to batteries shipped alone.
The baseline requirements
Every lithium cell or battery offered for transport must be of a design type tested to UN Manual of Tests and Criteria, Part III, sub-section 38.3, with the manufacturer holding test records; must incorporate safety venting or be designed to preclude violent rupture; must be protected against external short circuit; and, for lithium-ion batteries, must be marked with the watt-hour rating on the case. Cells and batteries are packed in inner packagings that completely enclose them, inside a strong rigid outer package, with the lithium battery mark and, above the size thresholds, full Class 9 hazmat labeling and documentation.
The size-based exceptions
Paragraph (c) of the rule provides relief for small cells and batteries: lithium-ion cells of no more than 20 Wh and batteries of no more than 100 Wh (for lithium metal, 1 g and 2 g of lithium) may be shipped under reduced requirements when properly packaged and marked — the reason a single laptop in a box does not need a hazmat-trained shipper. For highway and rail only, the thresholds rise to 60 Wh per cell and 300 Wh per battery.
Batteries shipped for recycling or disposal
Paragraph (d) is the one that matters for disposition programs. Lithium cells and batteries transported by motor vehicle to a permitted storage, disposal, or recycling facility are relieved of the design-test recordkeeping and of the UN performance-packaging requirements — and, when they meet the size and packaging conditions of the small-battery exception, of most of the hazard communication rules in Part 172 as well. The relief is conditional: it applies to highway movement to an appropriate facility, with the batteries still protected against short circuit and packed to prevent damage. It is why a certified recycler can consolidate a customer's retired battery stream onto a truck with a manageable compliance burden — and why that burden is theirs to manage, not the customer's to improvise.
Damaged, defective, or recalled batteries
Paragraph (f) is the hard rule. Cells or batteries that are damaged, defective, or recalled — the swollen laptop pack, the phone with a separated screen, the unit identified in a manufacturer recall — may be transported by highway, rail, or vessel only. Air transport is prohibited. Each cell or battery must be individually enclosed in non-metallic inner packaging, surrounded by cushioning that is non-combustible, electrically non-conductive, and absorbent, inside outer packaging meeting Packing Group I performance standards, and the outer package must be marked to indicate that it contains a damaged/defective lithium ion battery. None of the recycling relief in paragraph (d) reaches this category. This is the rule that turns a swollen battery from a nuisance into a project, and it is the strongest argument for identifying damaged cells at collection rather than discovering them at the dock.
You are almost certainly not a trained hazmat shipper, and 49 CFR 173.185 assumes the person packing the box is. The compliant path for most enterprises is a certified recycler or ITAD partner that packages, marks, documents, and moves the stream under its own program — and a collection process that flags damaged cells before they are boxed.
Air, state of charge, and the 2026 change
Air transport is where the lithium rules are strictest, because a battery fire in a cargo hold is an aviation emergency. Enterprises rarely ship retired batteries by air deliberately — but they ship devices, and devices contain batteries.
Under the international rules that U.S. regulations harmonize with — the ICAO Technical Instructions and the IATA Dangerous Goods Regulations — lithium-ion cells and batteries shipped alone (UN3480) have for several years been limited to a state of charge of no more than 30% of rated capacity, and are restricted to cargo aircraft rather than passenger aircraft. Damaged, defective, or recalled batteries are prohibited from air transport entirely, consistent with the domestic rule.
The 2026 change extends the charge limit toward the shipments enterprises actually make. Effective January 1, 2026, lithium-ion batteries packed with equipment (UN3481) with a watt-hour rating above 2.7 Wh must also be offered for air transport at a state of charge not exceeding 30% of rated design capacity, or an indicated capacity not exceeding 25%, absent specific approval. The practical consequence for a disposition program is that a "ship the old laptops back by air with the spare battery in the box" workflow now carries a charge-state obligation that a mail-back or courier process has to account for — another reason the certified recycler, not the end user, should be specifying the packaging and mode.
State of charge also matters outside aviation as a safety practice. Because the energy a cell can release scales with its charge, industry safety guidance generally favors partial charge for storage and ground transport as well; the 30% air figure has become the de facto benchmark. It is a practice, not a domestic ground-transport rule — but it is a good one, and it costs nothing to run a laptop down before it goes in the retirement bin.
By air: 30% state of charge for batteries alone and, since January 2026, for most batteries packed with equipment; cargo aircraft only for batteries alone; damaged cells never. On the ground: partial charge is not required, but it is the safer default.
Lead-acid UPS batteries: the other stream
Most uninterruptible power supplies installed today still run on valve-regulated lead-acid batteries. They are heavy, they contain lead and sulfuric acid, and they follow a set of rules that predates the lithium era by decades.
Lead-acid is the recycling success story of the battery world: a mature, high-recovery-rate reclamation industry exists specifically because lead is valuable and toxic in equal measure, and used lead-acid batteries have long been routed back into new ones. Regulatorily, spent lead-acid batteries destined for reclamation are handled under their own RCRA provisions (40 CFR Part 266, Subpart G) or, at the generator's election, under the universal waste program — and in transport, sealed VRLA units that meet the non-spillable criteria are typically shipped as UN2800, Batteries, wet, non-spillable, with their own packaging and marking requirements rather than the lithium rules. Terminals still need short-circuit protection; the cases still need to be intact; the batteries still need to reach a permitted reclaimer.
The disposition risk with lead-acid UPS is less about fire and more about weight, handling, and misidentification. UPS battery strings for a data-center row can run to hundreds of kilograms, which makes them a rigging-and-transport job, not a box-and-ship job. Cracked cases leak acid. And because lead-acid and lithium-ion UPS cabinets look alike from across a room, a decommissioning crew that assumes one chemistry and finds the other has a compliance problem on the dock. Confirm the chemistry from the unit label or the manufacturer's specification before the first cable is pulled.
Lithium-ion UPS systems — increasingly common in new deployments, frequently using lithium iron phosphate chemistry — follow everything in Sections 04 through 06, at a scale that makes the size exceptions irrelevant: these are large batteries shipped under full Class 9 requirements, by a shipper who knows how. Plan their eventual retirement when they are installed; the removal path for a lithium UPS string is a hazmat logistics exercise that should not be designed the week the replacement arrives.
Downstream: where batteries go, and why it became strategic
A retired battery that reaches a certified recycler does not disappear. It becomes feedstock — and in 2026, feedstock with a national-security designation attached.
At a battery recycler, discharged lithium-ion cells are shredded under controlled conditions and mechanically separated. The casings, copper, and aluminum foils come off as commodity streams; what remains is black mass — the dark powder of cathode and anode material, rich in lithium, cobalt, nickel, manganese, and graphite. Black mass then goes to refining, typically by hydrometallurgy: chemical leaching and separation that returns battery-grade lithium, cobalt, and nickel salts to the supply chain. For years, much of North America's black mass was exported for that refining step.
That is the stream Washington acted on. The July 30, 2026 Presidential Determination under Section 101 of the Defense Production Act named black mass, alongside end-of-life rare-earth magnets and scrap containing critical minerals, a recoverable critical material essential to national defense. The BIS allocation order published August 6 and effective August 27, 2026 requires U.S. sellers of black mass to allocate 100% of monthly sales to U.S. persons — effectively keeping it in the domestic refining chain, with reporting obligations and an exception process at BIS. The retired laptop and UPS batteries in an enterprise fleet are the upstream of exactly that regulated material. For the full policy context — the export-control timeline, the chokepoints, the urban-mining math — the Critical Minerals Recovery Field Guide is the companion reference; the news brief tracks the rulemaking.
For the organization retiring the batteries, the strategic layer changes nothing about the handling rules and everything about the "where does it go" question. A battery stream that ends at a documented, domestic, certified recycler is now aligned with federal policy; one that ends in an export container or a landfill is exposed to it — and, per Section 01, to fire.
The BIS order is open for public comment until November 4, 2026 and is currently set to expire August 27, 2027; the rules may change. This guide reflects them as of August 2026.
The enterprise battery playbook
Everything above reduces to a set of operating practices. None requires a hazmat certification; all of them assume you will hand the regulated steps to someone who has one.
- Segregate by chemistry at collection. Lithium-ion, lithium primary, lead-acid, and alkaline are four streams with four rulebooks. Sorting them at the point of retirement is cheap; sorting them at the dock is not.
- Inspect for damage before boxing. Swelling, heat, odor, or physical damage moves a battery into the damaged/defective category (Section 05): isolate it in a non-combustible container, do not charge it, and tell your recycler before it ships. Never place damaged cells with healthy ones.
- Contain against short circuit. Tape exposed terminals or bag cells individually; use containers that keep cells from contacting each other or metal. This is the universal-waste containment requirement and the transport rule's short-circuit protection in one step.
- Prefer partial charge. Run devices down before retirement where practical. Air shipments require it; ground safety favors it.
- Don't stockpile. The universal-waste clock is one year; the fire risk clock starts sooner. A standing retirement cadence — scheduled pickups, mail-back kits for distributed sites, deployment-paired takeback — keeps batteries out of drawers.
- Plan UPS retirement at UPS installation. Record the chemistry, the string weight, and the removal path when the unit goes in. A lithium UPS string is a full Class 9 shipment; a lead-acid string is a rigging job.
- Let the recycler own the packaging and paperwork. 49 CFR 173.185 assumes trained shippers. Ask your ITAD partner how it packages, marks, and documents battery shipments, and whether it handles damaged cells — then let it.
- Ask where the black mass goes. Domestic, certified downstream with documentation. Under R2v3, batteries are a focus material requiring a vetted downstream chain; the BIS order now gives you a policy reason to want that chain domestic.
- Check the insurance layer. Fire and environmental exposure make pollution and general liability coverage relevant for battery handling in a way they are not for wiping drives. Our coverage-gap brief covers how to read a vendor's insurance.
- Document the stream. Weights by chemistry, dates, destination facility, and certificates. Universal-waste obligations, ESG reporting, and any future materials-provenance rule all draw on the same records.
Sort by chemistry, inspect for damage, contain the terminals, keep the charge down, empty the drawer on a schedule, know your UPS chemistry, and let a certified recycler run the regulated steps and prove where the material went. That is the whole program.
Frequently asked questions
Are used lithium-ion batteries hazardous waste?
Under federal rules, EPA's position is that most spent lithium-ion batteries are likely to be hazardous waste when discarded, because of ignitability and reactivity, and EPA recommends that businesses manage all of their used lithium batteries under the hazardous-waste rules. The practical path for most organizations is the universal waste program under 40 CFR Part 273, which streamlines handling for batteries destined for recycling or proper disposal but still requires labeling, containment, accumulation limits, and shipment to an appropriate destination facility. State rules can be stricter, and a battery that is damaged or swollen is a different, more restrictive case.
Can we just box up old laptop batteries and ship them to a recycler?
Not without meeting the hazardous-materials transport rules. Lithium-ion batteries are Class 9 dangerous goods under 49 CFR 173.185: they need short-circuit protection, appropriate inner and outer packaging, and lithium battery marks, and batteries shipped for recycling or disposal by highway get regulatory relief from some requirements only when they meet the size and packaging conditions in the rule. Damaged, defective, or recalled batteries are the hard case: they may move by highway, rail, or vessel only, never by air, in individually packaged, cushioned, Packing Group I outer packaging marked as damaged/defective. Most organizations should let a certified recycler manage the packaging and paperwork.
Why is a swollen laptop battery treated differently?
Because it is signaling that something inside has already gone wrong. Swelling means gas has built up in the cell, usually from electrolyte breakdown, which makes the cell more likely to short internally and enter thermal runaway. Transport rules treat damaged or defective cells as a separate, more restrictive category, and safe handling means isolating the battery in a non-combustible container away from other cells, not charging it, and getting it into a certified stream quickly. It should never be stacked in a drawer with other batteries or shipped as ordinary recycling.
Does the UPS in our server room have the same problem as laptop batteries?
It depends on the chemistry. Most installed UPS systems still use valve-regulated lead-acid batteries, which are heavy, contain lead and sulfuric acid, and are managed under long-established, high-recovery-rate lead-acid recycling channels with their own transport rules. Newer UPS systems increasingly use lithium-ion packs, which carry the thermal-runaway and Class 9 transport considerations described in this guide. Identify the chemistry before decommissioning, because the two streams are handled, packaged, and shipped differently.
How do battery rules connect to the critical-minerals policy?
Directly. When lithium-ion batteries are shredded by a recycler, the cathode and anode material becomes black mass, and the July 30, 2026 Defense Production Act determination named black mass a recoverable critical material essential to national defense. The BIS allocation order effective August 27, 2026 requires sellers of black mass to allocate 100% of monthly sales to U.S. persons. The retired batteries in an enterprise fleet are the upstream of exactly that regulated stream, which is one more reason they belong in a documented, domestic, certified recovery chain rather than a closet or a general waste bin.
Retire the batteries with the equipment — safely, legally, and documented
CyberCrunch retires data-bearing devices and their batteries in one certified chain: battery segregation and damaged-cell handling at collection, compliant packaging and transport, R2v3 focus-material downstream management to domestic recyclers, and serialized documentation for every device. Lead-acid and lithium UPS decommissioning included.
This guide is informational only and reflects publicly available sources as of August 2026, including 49 CFR 173.185 as published in the Electronic Code of Federal Regulations, EPA's lithium-ion battery recycling FAQ and May 24, 2023 memorandum, EPA's 2021 report "An Analysis of Lithium-ion Battery Fires in Waste Management and Recycling," published summaries of the 2026 ICAO/IATA state-of-charge provisions, the July 30, 2026 Presidential Determination, and the August 6, 2026 BIS allocation order. It describes federal rules at the pattern level; state hazardous-waste programs, carrier tariffs, and international rules add requirements, and all of them change. It is not legal, environmental-compliance, or hazardous-materials shipping advice. Hazardous-materials shipments must be prepared by properly trained personnel under 49 CFR Part 172; consult qualified counsel or a hazmat compliance professional before acting on anything described here.