United States · federal and state
There is no federal battery-passport requirement in the US. Obligations come from state extended producer responsibility laws, federal waste and hazardous-materials rules, and import controls on forced labour.
All regulations · Last reviewed: 2 October 2026
At federal level, end-of-life batteries are governed by EPA’s Resource Conservation and Recovery Act (RCRA) rules, including the universal waste rule; EPA has placed a rulemaking to create a dedicated universal-waste category for lithium batteries on its regulatory agenda. Transport of lithium batteries is regulated by PHMSA hazardous-materials rules.
Supply-chain traceability pressure comes mainly from the Uyghur Forced Labor Prevention Act, under which goods made wholly or partly in Xinjiang are presumed to be made with forced labour unless importers prove otherwise. The clean-vehicle tax credit (§30D), whose critical-mineral and battery-component sourcing rules drove much traceability work, was terminated for vehicles acquired after 30 September 2025 by the 2025 budget law (“One Big Beautiful Bill Act”).
States are filling the gap. New Jersey enacted the first EV-battery EPR law in January 2024, and Colorado’s SB26-003 (signed June 2026) creates an EV-battery stewardship programme with minimum recovery rates for nickel, cobalt and lithium and a duty to provide state-of-health information for model-year 2028 and later vehicles.
Scope
Register with the state agency, join or fund a stewardship programme, report on collection and end-of-life management.
Must be able to trace supply chains to rebut the UFLPA presumption if shipments are detained.
Manage waste batteries under RCRA (universal waste) and ship them under hazardous-materials rules.
US manufacturers supplying cells or vehicles abroad must meet those markets’ passport and data obligations.
Obligations
Ordered roughly by when they apply. Status reflects the position on the review date.
Proposed rule on the regulatory agenda
EPA plans to create a lithium-battery-specific universal-waste category with fire-safety standards. Until finalised, existing universal-waste battery rules apply.
Enforced since 21 Jun 2022
Rebuttable presumption that goods linked to Xinjiang or listed entities are made with forced labour. Batteries and battery materials are among enforcement priority sectors; traceability documentation is the main defence.
Registration 8 Jan 2025; annual reports from 8 Jan 2026
Producers of EV and hybrid propulsion batteries register with NJDEP and report annually on batteries sold or distributed in the state, as part of an EPR scheme for collection and recycling.
Registration 1 Jul 2027; plans 1 Apr 2028; participation 1 Aug 2028
Providers register with CDPHE, finance an approved stewardship organisation, retrieve unwanted batteries within 60 days of notice, provide state-of-health information for MY2028+ vehicles and report annually from 1 June 2030. Sets minimum recovery rates for nickel, cobalt and lithium.
Various; e.g. Washington retail restriction from 1 Jul 2027
States such as Washington (SB 5144, 2023), California and others run stewardship schemes for consumer and medium-format batteries. These generally exclude EV propulsion batteries.
Terminated after 30 Sep 2025
Credits for new (§30D) and used (§25E) clean vehicles ended for vehicles acquired after 30 September 2025, along with their critical-mineral and battery-component sourcing tests.
Data
The information an operator needs to hold, publish or report, grouped by audience.
EVstring
An honest mapping from obligation to product capability. EVstring supports compliance work; it does not make an operator compliant on its own.
| Obligation / need | EVstring capability | Status |
|---|---|---|
| Per-battery records of sale, transfer and end-of-life outcome | Lifecycle state machine with ownership transfers and tamper-evident history | Available |
| State-of-health information | Telemetry with anchored Merkle roots; SoH trend on the passport | Available |
| Supply-chain evidence for customs | Restricted due-diligence documents with on-chain hashes for integrity | Available |
| State EPR reports | Report exports by producer and state from regulator analytics | Roadmap |
Full requirement-by-requirement view: compliance mapping.
Sources
Primary texts and regulator pages used for this guide. Last reviewed: 2 October 2026.