From a popular Reddit thread to the substantiated Mercatus Center’s “Snapshots of State Regulations” report, California is the most regulated state in the U.S., with 420,000 regulations and counting. (New York comes in second at 300,000, and Idaho is the least litigious with only 31,000 regulations on the books.)
Reasons for California’s top regulatory ranking range from its large population and complex economy to its progressive political environment. But regardless, if you’re an employer in California, it’s a lot to stay on top of.
KPA monitors developments affecting the automotive industry daily, if not hourly. Today, we’re tackling California’s new Battery-Embedded Product (BEP) recycling fee under SB 1215 , which took effect January 1, 2026.
We examined the statutory language (yes, we’re into that) and can offer you additional clarity regarding motor vehicle parts.
What’s SB 1215?
SB 1215 is a California law, now in effect, that requires retailers to collect a recycling fee on certain “covered battery-embedded products (CBEPs)” — items that contain batteries that consumers can’t easily remove. The fee must be listed separately on the invoice and is remitted to the California Department of Tax and Fee Administration (CDTFA) to support safe recycling of these products.
Key clarification: Motor vehicle parts are exempt. However, SB 1215 specifically excludes the following “electronic device(s):” “…any component part of a motor vehicle… including replacement parts for use in a motor vehicle.”
Based on this language, KPA interprets that: Products that are part of a vehicle or sold as replacement parts for a vehicle are NOT subject to California’s recycling fee, even if they contain embedded batteries.
What does this mean for dealerships?
All of these types of electronic vehicle systems meet the regulation’s exemption criteria:
- Tire Pressure Monitoring System (TPMS) sensors
- Vehicle batteries (including auxiliary batteries in EVs/hybrids, where applicable under this framework)
- Electronic control modules (ECMs, BCMs, etc.)
- Infotainment system components (built-in head units, displays)
- Backup cameras and integrated camera systems
- Parking sensors and ADAS sensors (radar, ultrasonic, etc.)
- Telematics modules (OnStar, connected vehicle hardware)
- Remote start systems (when installed as part of the vehicle)
- Dash-integrated navigation systems
- Factory-installed or vehicle-specific alarm systems
- Integrated dash cams (if designed as part of the vehicle system)
- Electronic mirror assemblies (with embedded tech like auto-dimming or sensors)
- Other vehicle-installed electronic components
- Replacement parts intended for use in a vehicle
Even though some of these products contain non-removable batteries, they are STILL considered “motor vehicle components” and are therefore excluded from the fee.
What is subject to the fee?
The exemption DOES NOT extend to general consumer electronic products sold by dealerships.
Examples where the fee would apply:
- Portable Bluetooth speakers
- Standalone GPS units
- Other electronic accessories not intended as vehicle components
If these products contain non-removable batteries and are sold to consumers, the recycling fee must be collected.
KPA continues to engage with regulators on this and other matters and will provide updates as additional guidance becomes available.
What should you do now?
We recommend that dealerships:
- Distinguish between vehicle components and consumer electronic accessories in your inventory
- Configure systems to apply the fee, but only to applicable products
Need help?
KPA has hundreds of real-life safety and compliance experts who can visit your locations IN PERSON to identify the risks your business faces before they result in citations, injuries, or malfeasance. If you’d like help reviewing if specific products at your dealership are subject to California’s battery-embedded recycling fee, we’re happy to assist. Plus, we can help you spot so much more to protect your business and your employees!
Get in touch with the KPA team today.
