California’s New Battery Law Ends Your Weight-Based Exemption

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On September 20, 2026, Governor Gavin Newsom signed Senate Bill 501, now Chapter 414, Statutes of 2026, amending the Responsible Battery Recycling Act of 2022 (AB 2440). Chapter 414 takes effect January 1, 2027. It reaches every manufacturer, brand owner, importer, and California distributor of a product that contains a rechargeable or nonrechargeable battery. And it lands hardest on companies headquartered outside California that built their compliance programs around the weight and energy thresholds Chapter 414 just eliminated.

What Changed

Under the prior law, a battery escaped the "covered battery" definition, and the stewardship obligations that come with it, only if it exceeded weight and watt-hour thresholds set for large-format batteries such as electric-vehicle and industrial packs. Yet a small consumer battery, well under those thresholds, was covered from AB 2440's inception. Chapter 414 repeals that exclusion structure and replaces it with two new classifications under Public Resources Code section 42420.1.

A small-format battery is a rechargeable battery weighing no more than 11 pounds and rated no more than 300 watt-hours, or a nonrechargeable battery weighing no more than 4.4 pounds. A medium-format battery is a rechargeable battery weighing more than 11 pounds but no more than 25 pounds, or rated above 300 but below 2,000 watt-hours, or a nonrechargeable battery weighing between 4.4 and 25 pounds. Every battery within either the small- or medium-format category is now a covered battery under Chapter 414, regardless of how the prior exclusion would have treated it.

Why This Matters for Your Products

A battery your compliance team classified as excluded under the old AB 2440 thresholds may now fall squarely within the small-format or medium-format definition. That reclassification is not academic. Chapter 414 sets different stewardship-plan obligations for each category. A small-format battery, for instance, requires collection at a minimum of 10 sites per county, or one site per 15,000 residents, whichever is greater, and it triggers a mandatory retailer take-back obligation: any retailer with five or more California locations selling a small-format battery must serve as a permanent collection site for it. By comparison, a medium-format battery carries a lighter collection standard, five sites per county or one per 30,000 residents, and no equivalent retailer mandate.

Any company that sells a small, removable rechargeable pack, an accessory battery, or a spare cell, and assumed it sat outside AB 2440 because of the battery's weight or energy rating, needs to run that product through the new definition before the year ends. The same is true for a nonrechargeable battery near the 4.4-pound line, since that figure now marks the boundary between the small- and medium-format categories rather than an exclusion cutoff.

Chapter 414 does not touch SB 1215, the separate program governing covered products with embedded batteries that are not user-removable. A product cleared under SB 1215 still needs its own AB 2440 analysis if it ships with, or alongside, a removable battery.

What to Do Before January 1, 2027

1. Rebuild the battery inventory. For every product sold or distributed in California, identify the battery's chemistry, weight, and watt-hour rating, and classify it as small format, medium format, or outside both categories under the amended section 42420.1.
2. Confirm producer status and registration. Where a battery newly qualifies as covered, determine who sits at the top of the statutory producer hierarchy for that product, and confirm that the entity's stewardship-plan participation, whether individual or through a stewardship organization, correctly designates the battery's format.
3. Flag small-format products for the retailer take-back obligation. Distributors and retail partners selling a small-format battery need advance notice that a retailer with five or more California stores must serve as a collection site once Chapter 414 takes effect.
4. Calendar January 1, 2027, as the operative date, and build in time before it to complete the reclassification, since stewardship-plan and producer designations should be correct as of Chapter 414's effective date rather than corrected after it.

Bottom Line

Chapter 414 does not create a new program. It redraws the boundary of an existing one, and any company that relied on the old weight and watt-hour exclusion needs to confirm its products still fall outside AB 2440 before January 1, 2027. Companies that have not reassessed their battery portfolio against the new definitions for small format and medium format should do so now.

For help evaluating how Chapter 414 may affect your products, battery classification, and producer obligations prior to the effective date, please contact the author or any member of FBT Gibbons' Environmental Practice Group.