An e-bike battery at the end of its riding life has three realistic destinations: a free industry take-back bin, a specialist recycler that reclaims the metals, or a carefully diagnosed second life in stationary storage. Which one applies depends almost entirely on whether the pack is healthy or damaged, because a damaged lithium pack is a different regulatory object with its own shipping rules, its own paperwork, and no air transport at all. Manufacturers, shops, and riders each face a different version of the same comparison. A rider wants to know where to drop the pack and what it costs; a shop wants to know what it can legally accept and ship; a manufacturer wants to know which recycling contracts and stewardship laws it is about to be billed for.
Table of Contents
- Where a dead pack can actually go
- Why a damaged pack cannot fly
- The laws moving the cost onto sellers
- What second life is worth, and where it stops
- What each role should compare
- Frequently Asked Questions
Where a dead pack can actually go
The default US pathway is the industry take-back run by Call2Recycle and endorsed by PeopleForBikes. It is funded by manufacturers under extended producer responsibility — the brands pay, so the drop-off is free to the person handing over the battery. Bicycle Retailer and Industry News reported that the program had collected 85,000 pounds of batteries through more than 2,100 retail drop-off points by July 2024. The consumer-facing side of that program is Hungry for Batteries, which works with more than 50 bicycle-industry companies and lists participating shops at hungryforbatteries.org.
It accepts damaged packs as well as healthy ones, which matters: the battery most people want rid of is the one that swelled, got crushed in a crash, or stopped charging. Shops that want to join can reach the program at [email protected]. Fleets and manufacturers have a second route. Redwood Materials runs medium-format micromobility take-back with Lime, Lyft, Rad Power Bikes and Specialized, and states that its process recovers more than 95% of critical elements including lithium, cobalt, nickel and copper. That figure is the reason "recycling" and "landfill diversion" are not the same claim — a pack sent to a hydrometallurgical recycler comes back as cathode feedstock, not as inert waste.
Why a damaged pack cannot fly
This is the single rule that most often surprises a shop. Under 49 CFR 173.185(f), damaged, defective or recalled lithium batteries are forbidden on all aircraft with no exception. They move by ground only, and the outer packaging must be marked "Damaged/defective lithium ion battery" in characters at least 12 mm (0.47 in) high. The reasoning is physical, not bureaucratic.
PHMSA — the US Pipeline and Hazardous Materials Safety Administration, which writes the transport rules — states that damaged, defective or recalled cells have a greater tendency than normal batteries to short-circuit, release heat or ignite. That is why these shipments face restrictions beyond those for new or undamaged used packs, and why carriers commonly require a DOT Special Permit before they will take one. For a bike shop, the practical consequence is a sorting decision at the counter, not a shipping decision later: Quoting a customer a mail-back option for a swollen battery is the classic error. The label may print; the shipment is still not lawful by air.
- A healthy retired pack: standard take-back bin, normal collection logistics.
- A swollen, dented, leaking, heat-damaged or crash-impacted pack: ground only, separate packaging, the 12 mm marking, and the carrier's damaged-cell process.
- A recalled pack: treated the same as damaged under the rule, even if it looks and behaves normally.
- Any pack you cannot classify with confidence: handle it as damaged and ask the take-back program before it goes in a box.
The laws moving the cost onto sellers
The voluntary program is being overtaken by statute, and the new laws target the class of battery e-bikes actually use. Illinois SB 3686, effective January 2026, is the first US law to cover rechargeable "medium-format" batteries — the size class that includes e-bike packs, sitting between a power-tool battery and a car pack. Anyone selling or distributing batteries in the state must join an approved battery stewardship plan. Vermont's 2026 law extends its 2014 primary-battery program to portable and medium-format rechargeables.
Sellers must operate a recycling program covering e-bike and e-scooter packs, with new collection points required statewide by the end of 2028. For a small brand or a direct-to-consumer importer, joining an existing stewardship plan is usually the only realistic route to compliance. Europe sets the numbers everyone else is measured against. EU Regulation 2023/1542, applicable since February 2024, sets binding lithium recovery rates of 50% by end-2027 and 80% by end-2031, plus separate collection targets for light-means-of-transport batteries — the e-bike category — of 51% by end-2028 and 61% by end-2031. A brand selling on both continents is already designing to the stricter of the two.
What second life is worth, and where it stops
Second life means retiring a pack from the bike and redeploying the cells in a less demanding job, typically stationary storage. Peer-reviewed work in Frontiers in Chemistry places retirement from primary use at roughly 70–80% capacity retention, while second-life stationary duty can run down to about 40% state of health. The same work argues that a fixed end-of-life threshold is over-conservative, and that safe reuse depends on accurate per-pack diagnosis of both state of health and state of safety. That caveat does most of the work. A pack's remaining capacity is a fleet-level average; a pack's safety is an individual property, determined by its cell history, its thermal exposure, and whether it was ever crashed or submerged.
Second life is a viable business at fleet scale, where hundreds of packs share a known duty cycle and telemetry. It is a much weaker proposition for one used pack of unknown provenance. Certification sets the harder limit. UL Standards & Engagement reports that NYC lithium-ion battery deaths fell to one in 2025 — with 292 fires and 51 injuries — two years after Local Law 39 required UL 2849 certification for e-bikes sold in the city. Opening a sealed manufacturer pack voids that certification, and can brick the battery management system in the process. The safest second-life play for a shop is therefore the authorised one: manufacturer BMS diagnostics and whole-pack swaps, not cell harvesting on the workbench.
What each role should compare
The same facts point in three different directions depending on who is asking. One warning cuts across all three: never put an e-bike battery in curbside recycling or household waste. The cells that PHMSA describes as prone to short-circuit and ignite do exactly that inside a compactor truck, where nobody can reach them.
- **Cyclists:** find a participating shop through hungryforbatteries.org before buying anything to replace the pack, and confirm the shop takes damaged batteries if yours is swollen or crash-affected. The drop-off itself is free because the manufacturer already paid for it.
- **Shops:** decide your damaged-versus-healthy sorting rule now, in writing, and keep the 12 mm marking and ground-only requirement where staff can see it. Enrolling in the take-back program is also what gives you a legitimate answer to the customer standing at the counter with a failed pack.
- **Manufacturers and importers:** check whether you sell into Illinois or Vermont, since both now require a stewardship plan rather than a goodwill gesture, and compare a take-back contract's recovery rate against the EU's 80%-by-2031 lithium target rather than against landfill.
Frequently Asked Questions
How do I tell whether my battery counts as "damaged or defective"?
Treat swelling, case cracks, dents, leakage, unusual heat, a burning or sweet chemical smell, water immersion, or any impact from a crash as damaging. A recall notice also puts the pack in that category under 49 CFR 173.185(f), even when it still charges and runs normally. When in doubt, store it outside on a non-combustible surface, away from anything flammable, and call the drop-off point before moving it.
Can a shop refurbish a customer's pack by replacing individual cells?
Opening a sealed manufacturer pack voids its UL 2849 certification, which is the standard New York City wrote into law, and can disable the battery management system permanently. Authorised BMS diagnostics and a full pack swap keep the certification intact and leave the liability where it belongs.
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