California Air Resources Board

Senate Bill 615 (SB 615), Vehicle Traction Batteries (Chapter 351, Statutes of 2026), establishes requirements for vehicle traction battery registration, labeling, and associated fees. As California’s use of electric vehicles continues to grow, more traction batteries will eventually reach the end of their useful lives. Clear battery identification and accessible information can help support the safe handling, reuse, repair, remanufacturing, repurposing, and recycling of these batteries.

The law requires the California Air Resources Board (CARB) to establish a registration process for battery suppliers and remanufacturers, implement battery labeling requirements, and develop regulations to implement and enforce the law. These requirements are intended to improve battery identification and provide information that supports appropriate battery management throughout the battery life cycle.

Who Is Required to Register?

SB 615 requires battery suppliers and remanufacturers to register with CARB.

Battery suppliers mean all of the following:

1. The vehicle manufacturer of the vehicle containing the vehicle traction battery, unless the vehicle traction battery is an aftermarket part. If a vehicle’s vehicle traction battery is replaced with an original equipment manufacturer’s vehicle traction battery, the battery supplier is the vehicle manufacturer. 
2. If a replacement vehicle traction battery is not an original equipment manufacturer’s vehicle traction battery for the vehicle but instead an aftermarket vehicle traction battery, the entity that owns or licenses the trademark of the replacement vehicle traction battery is the battery supplier, if that entity is in the state. 
3. If there is no person in the state who is the battery supplier for purposes of paragraph (1) or (2), the battery supplier is the importer, distributor, retailer, dealer, or wholesaler who sells, offers for sale, distributes, deals, leases, or offers for lease the aftermarket vehicle traction battery in or into the state. 

Remanufacturer means a person, other than the battery supplier regarding its own batteries, who engages in remanufacturing of vehicle traction batteries. A person is a remanufacturer even if the person never makes modifications to the battery or the person’s modifications to the battery are unsuccessful. 

Initial Registration Requirements

Each battery supplier and remanufacturer must register with CARB no later than 90 days after SB 615 was chaptered on September 20, 2026.

As part of the initial registration, entities must provide:

• Contact information
  • Entity name, physical address, mailing address, email address, and telephone number.
• Battery information
  • A list of the types and brands of vehicle traction batteries the entity sells, distributes for sale, imports for sale, or offers for sale in or into California.

CARB’s online registration portal is scheduled to begin on November 4, 2026. Covered entities must submit their registration information by December 19, 2026, in accordance with the statutory deadline.

Registration Updates

Following initial registration, battery suppliers and remanufacturers must update their registration information and battery type and brand lists on or before July 1 of each year. They must also provide updated information upon CARB’s request.

Entities that have already registered with CARB and provided the required information are considered to have satisfied the initial registration requirement.

Labeling Requirements Beginning July 1, 2028

Beginning July 1, 2028, new vehicle traction batteries sold in California must have a permanent label applied by the battery supplier. The label must include:

• The battery supplier’s name.
• The battery’s date of manufacture.
• Battery chemistry, including cathode and anode types.
• Rated capacity or energy
• Hazardous substances contained in the battery.
• Product safety and recall information.
• Safe disposal information.

The label must be attached to the exterior of the battery pack in a location that remains visible and accessible when the battery is removed according to the manufacturer’s recommended procedures. It must remain legible, adhered, and intact under expected environmental and vehicle life-cycle conditions.

A quick response (QR) code may be used to provide access to certain required information through an online data repository. Specifically, the QR code may link to information about battery chemistry, rated capacity or energy, hazardous substances, product safety and recalls, and safe disposal. The label must still include the other required information directly.

Remanufacturers must rebrand and relabel remanufactured traction batteries with their own brand. If the original label remains, the new label must be placed adjacent to it, and the original label must be clearly identified as obsolete. If remanufacturing changes the battery’s composition or chemistry, the label or linked online information must be updated accordingly.

CARB Fees Beginning July 1, 2029

Beginning July 1, 2029, and annually thereafter, battery suppliers must pay CARB a fee to cover the agency’s full personnel, administrative, regulatory, and loan and interest costs associated with implementing and enforcing SB 615.

CARB must establish a tiered fee schedule designed to generate sufficient revenue to cover these costs. The schedule must be based on each battery supplier’s share of total California vehicle registrations with traction batteries from 10 years before the fee schedule is established, using state registration data and excluding test vehicles that do not enter commerce.

CARB must evaluate annually whether the fee schedule needs to be updated and provide a public process allowing comments on the proposed schedule and any changes. Fee revenue will be deposited into the Vehicle Traction Battery Recovery Fund and, upon legislative appropriation, used for activities authorized under SB 615.

Future Regulations and Implementation

SB 615 requires CARB to adopt regulations to implement and enforce the law, with an effective date no later than July 1, 2031. These regulations may establish additional or different battery labeling requirements.

CARB must also determine the most cost-effective way to accept required electronic submissions from battery suppliers and remanufacturers. If the federal government establishes battery labeling requirements, CARB must review and compare those requirements with California’s requirements and revise its regulations, if necessary, to promote consistency, efficiency, and feasibility.

CARB’s duties to implement and enforce SB 615 are contingent upon legislative appropriation for those purposes.