Many campus activities generate hundreds, if not thousands, of used batteries per year. Batteries are used to power everything from the largest piece of construction equipment to the smallest smart phone. Despite the myriad types and sizes of batteries, they all have some things in common. Batteries all work through an electrochemical reaction of an electrolyte with a heavy metal. Among the heavy metals in batteries can be cadmium, lead, lithium, mercury and silver. All can harm human health and the environment and all have the potential to be hazardous wastes. Some of the material in batteries such as silver, cadmium, nickel and lead that may be hazardous if released into the environment are also valuable metals that can be recovered for reuse.

Batteries are defined in NR 673.09(1): “Battery” means a device consisting of one or more electrically connected electrochemical cells which is designed to receive, store and deliver electric energy. An electrochemical cell is a system consisting of an anode, cathode and an electrolyte, plus connections (electrical and mechanical) as may be needed to allow the cell to deliver or receive electrical energy. The term battery also includes an intact, unbroken battery from which the electrolyte has been removed.

Used batteries may be managed as universal wastes both federally and in the State of Wisconsin.

General Regulatory Citations

Batteries managed as universal waste in Wisconsin are regulated under Chapter NR 673, Universal Waste Management Standards.

Spent lead-acid batteries may be managed in Wisconsin under subchapter G of Chapter NR 666, Spent Lead−Acid Batteries Being Reclaimed. Batteries in charger

Training Requirements

NR 673.16 Employee training. A small quantity handler of universal waste shall inform all employees who handle or have responsibility for managing universal waste. The information shall describe proper handling and emergency procedures appropriate to the types of universal waste handled at the facility.

Storage Requirements

Used batteries managed as universal waste may be stored no longer than one year. You must be able to demonstrate the length of time that the batteries have been accumulated from the date it becomes a waste (e.g., label each item with the date it became a waste or was received or label container with the earliest date a waste was added to the container.). For further information, see NR 673.15.

Used batteries must be stored in a way that prevents releases. Storage containers must be closed, structurally sound and compatible with the contents. Storage containers must be labeled Universal waste — batteries, Waste batteries or Used batteries.

Battery types

Alkaline Batteries

Options are increasing for recycling alkaline batteries. The batteries are separated and steel, other metals and paper/plastic can be recovered and re-used.

Alkaline batteries may also be safely disposed with normal solid waste. Due to concerns about mercury in the municipal solid waste stream, battery manufacturers eliminated all of the added mercury from alkaline batteries since the early 1990s. Alkaline batteries are composed primarily of common metals — steel, zinc and manganese — and do not pose a health or environmental risk during normal use or disposal.

It is important not to dispose of large amounts of alkaline batteries in a group. Used batteries are often not completely “dead.” Grouping used batteries together can bring these “live” batteries into contact with one another, creating safety risks.

Lead Acid Batteries

It is illegal to landfill lead acid batteries or dispose of them in an incinerator. Up to 97% of a lead acid battery is recyclable. The average weight of a used lead acid battery is 20 pounds. Always recycle your used lead acid batteries to avoid the hazardous waste generator label.

For campuses that purchase lead acid batteries from local retail stores or have them installed at local shops, batteries can be left at the store or shop at no cost. If dropping off a battery without purchasing a new one, the retailer is allowed to charge up to $3. This method should only be used when doing business with a reputable, well-run business. It is a good policy to ask where their used batteries are stored and which recycler they use.

Due to cost considerations, UW System does not recommend using the state agency hazardous waste contract to dispose of lead acid batteries. If your campus chooses to accumulate batteries for recycling, please follow the management tips and storage guidelines found here.

Button batteries, silver oxide, primary lithium

Although they contain lower levels of hazardous materials than in the past, button batteries may still contain small amounts of mercury and are becoming increasingly energetic per unit volume. Residual energy presents a fire hazard, especially through short circuiting when terminals are allowed to contact each other. The batteries should be recycled through the state’s hazardous waste disposal or lamp and ballast recycling contractor. To safely store and ship the batteries, button batteries should be placed between two layers of clear duct tape. The clear tape will allow the state’s contractor to sort the batteries and will keep them from touching each other.

Taped lithium batteries


call2recycle logo




Call2Recycle is a national non-profit, public service organization created to collect and recycle rechargeable batteries. Call2Recycle’s national recycling program was originally funded through financial support from rechargeable battery manufacturers and retailers. Beginning April 1, 2017, Call2Recycle’s previously free battery-recycling program will transition to a fee-based program for all battery disposal services (including fees for packaging and/or freight).

Campuses may use the state, mandatory universal waste contract with Lamp Recycler’s, Inc. for most batteries that require handling as universal waste. The contract includes an elective component for rechargeable and non-rechargeable battery disposal, including the packing, marking, labeling, pickup, transportation and storage of these battery types. The contract can be found on VendorNet at: https://vendornet.wi.gov/Contract.aspx?Id=f06af5ba-0f2a-e611-8964-40a8f0ad9999

Alternatively, some local vendors may take certain batteries for recycling at no cost, such as lead acid, lithium ion and non-liquid Ni-cad batteries. Additional resources are provided below:

ORM Universal Waste page

WDNR “Recycling Batteries” page

USEPA Batteries page

Batteries Plus Recycling Process

Due diligence/Insurance

If you choose to manage batteries other than by using the state contract, you are responsible for vetting brokers/sites, including ensuring they have adequate insurance. Insurance requirements are in the Risk Management Manual. Use the High Risk Service Vendors provisions for Refuse Transportation and Disposal.


This publication was prepared for Environment, Health and Safety staff at University of Wisconsin System campuses, to assist in finding resources and information for regulatory compliance. It is not intended to render legal advice. (Click here to read full legal disclaimer.)



This publication was prepared for environmental, health and safety staff at University of Wisconsin System campuses, to assist in finding resources and information for regulatory compliance. It is not intended to render legal advice.

Read full legal disclaimer