White Paper Summarizing Existing Labeling and Voluntary Programs


xvEPA

White Paper Summarizing Existing Labeling and

Voluntary Programs

U.S. Environmental Protection Agency
Office of Resource Conservation and Recovery

January 2025
EPA 530-R-25-003

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Contents

1	Introduction	4

2	Labeling Examples for Recycling and Composting	5

3	EPA Labeling and Voluntary Programs	7

3.1	ENERGY STAR	7

3.2	WaterSense	8

3.3	Safer Choice	9

3.4	RCRA Hazardous Waste Labels	9

3.5	National Vehicle Mercury Switch Recovery Program	10

3.6	U.S. Fuel Economy Labels	10

4	Other Federal Labeling Programs	11

4.1	EPEAT	11

4.2	Food Nutrition Labels	12

4.3	Pesticide Labels	12

4.4	OSHA Hazard Communication Labels	13

5	Labeling Program Challenges and Recommendations	13

6	Next Steps	14

References	15

2

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Abbreviations

BIL

Bipartisan Infrastructure Law

BPI

Biodegradable Products Institute

CFR

Code of Federal Regulations

DOE

U.S. Department of Energy

DOT

U.S. Department of Transportation

ELVS

End of Life Vehicle Solutions Corporation

EOL

end-of-life

EPA

U.S. Environmental Protection Agency

EPR

extended producer responsibility

EU

European Union

FTC

U.S. Federal Trade Commission

NVMSR

National Vehicle Mercury Switch Recovery Program

OSHA

Occupational Safety and Health Administration

QR

quick response

RCRA

Resource Conservation and Recovery Act

3

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1 Introduction

A clean energy transformation is underway. As the United States rapidly transitions away from fossil fuels,
renewable energy sources are seeing unprecedented growth. Batteries are playing a central role in this
transformation. They power everything from cars and trucks to electric bikes (e-bikes) and consumer electronics.
They are also used in many industrial applications, from powering construction and agricultural equipment to
providing backup power for critical infrastructure and storing energy for renewable power generation. As
battery use increases globally, so does the demand for critical materials needed to manufacture single-use and
rechargeable batteries. To reduce global reliance on the mining of virgin raw materials, including cobalt and
lithium, the United States will need to increase the recovery of these critical materials from end-of-life (EOL)
batteries. However, increasing these recovery rates will require overcoming the current technological,
economic, regulatory, and social barriers to the safe collection and recycling of batteries. Today, many batteries
are disposed of in municipal solid waste or recycling because consumers lack information on how or where to
properly manage them. Products containing embedded batteries are often disposed of in municipal solid waste
because consumers are unaware of the presence of a battery.

Sections 70401 and 40207 of the Bipartisan Infrastructure Law (BIL) direct the U.S. Environmental Protection
Agency (EPA) to address these challenges along the battery life cycle through the development of voluntary
battery labeling guidelines, battery collection best practices, consumer education materials, and a national
extended producer responsibility (EPR) framework for batteries drafted in close coordination with the U.S.
Department of Energy (DOE).1 Together, these efforts will help state, local, and Tribal governments establish and
improve battery collection programs and help consumers more easily participate in proper battery EOL
management, reducing the frequency of safety incidents from improper battery disposal (e.g., fires at waste
management facilities).

By developing new voluntary battery labeling guidelines, EPA seeks to increase consumer awareness of the
presence of batteries in products and to empower consumers to properly dispose of them, depending on their
local collection programs. Additionally, EPA aims to increase the proper identification and handling of batteries
in battery collection, sorting, and processing facilities, which should improve the safety of facility staff and also
increase the recovery of critical materials within the developing U.S. battery recycling infrastructure. These
activities are essential to advancing the circular economy for batteries and strengthening the U.S. supply chain
for critical materials.

This white paper reviews existing labeling guidelines and labeling programs to highlight program successes and
challenges that may inform the process to develop and implement EPA's voluntary battery labeling guidelines
and consumer education materials. EPA researched existing labeling guidelines and programs for recycling and
composting; energy and water conservation; food nutrition; pesticides; fuel economy; hazard communication;
and household hazardous waste.

This white paper is not a policy declaration by EPA, nor does it set forth any voluntary or required labeling
standards, recommendations, or guidelines. Inclusion of any standard in this paper does not constitute an
endorsement from EPA. This white paper is intended as a reference material only and serves as foundational
research to inform the development of the forthcoming voluntary battery labeling guidelines as mandated by
BIL Section 70401(c).

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2 Labeling Examples for Recycling and Composting

Recycling and reuse labels are used to communicate to consumers how to effectively manage a product at the
end of its useful life. However, consumers do not always understand which products can be recycled due to a
lack of standardized or easily understood labels and due also to variability in the range of products accepted by
municipal recycling programs across the United States.

Additionally, in recent years, the plastics recycling industry has come under scrutiny for truth in labeling, with
critics stating that the use of the "chasing arrows" symbol on some plastic products is deceptive. The U.S.

Federal Trade Commission (FTC) Green Guides set restrictions on what can be claimed as recyclable. For a
product or package to be considered recyclable, it should be recoverable from the waste stream through an
established recycling program and 60 percent of communities where the product is sold must have access to
recycling facilities that can recycle that product.2

Like recycling labels, composting labels require coordination among industry organizations to ensure consistent
product messaging to consumers. The goals of labeling for composting are to reduce contamination within
waste streams, facilitate composting programs, and decrease landfill methane production through diversion of
organic wastes. For example, the Biodegradable Products Institute (BPI) compostable certification label indicates
to consumers, composters, and others that a product or packaging is compostable.3 Composters work with BPI
to create standards that must be met before a product receives the BPI certification label.

Despite coordination efforts among organizations, data on the effectiveness of recycling, composting, and reuse
labels for EOL management are limited. Specifically, there is limited information indicating whether recycling
label policies have changed the recycling rates in areas where the policies have been implemented. Research
from the Auckland School of Technology indicates that consumers' willingness to spend more for more
sustainable options depends on their knowledge and attitudes about sustainability.4 The research also found
that it is beneficial to pair labeling policies with other governmental regulations and business actions that
promote sustainable attitudes.4 Recycling and reuse labels are also more successful when they are created with
the specific requirements of recyclers and composters in mind.3 When labels are designed in this way, they can
help improve the efficiency of recycling and reuse operations, rather than create additional burdens for
operators.

Table 1 presents examples of recycling and composting labels.

Table 1: Examples of Recycling and Composting Labels

Name

Description

Symbol

ISO

Environmental
Labels and
Declarations5

ISO 14021 provides guidance to a
variety of organizations on how to
make self-declared environmental
claims.6 ISO 7000 provides guidance
on the use of the Mobius loop (i.e.,
chasing arrows symbol) as the general
symbol of recovery and recyclability.7

* %



Although the chasing arrows symbol is
widely recognized, it is not
standardized and may lead to



5

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Name

Description

confusion.6 The symbol is sometimes
accompanied by disposal instructions
and/or a recycled content claim.6
Placement is determined by the
product or package manufacturer.

Symbol

France Triman

French law requires that all recyclable
products covered by an EPR scheme
must be distinguished by a common
label.8 The Triman logo is one
example of a singular, country-specific
label that is standardized to
communicate recyclability.

How2Recycle®

How2Recycle's four recycling labels
use standardized terms and symbols
to indicate how to recycle or dispose
of products. The chasing arrows label
with a diagonal line through the
middle indicates the product is not
recyclable.9 The chasing arrows label
with "check locally" text indicates that
the consumer much check if the
product can be recycled in their
location.9 The chasing arrows label
with no additional text indicates that
the product is widely recyclable (that
is, accepted by at least 60 percent of
U.S. recycling facilities).9 The chasing
arrows label with "store drop-off" text
indicates that the product is not
accepted in most curbside bins or
drop-off programs, but is accepted at
participating retailers. Products may
contain one or more of these labels to
indicate recyclability of multiple
packaging components.





~W Store \
V Drop-off ~

-J

O

s

ro

-i

(D



O
•<
o







3



o

*Not recycled in
all communities

How2Compost

The How2Compost label appears on
packaging or products that the BPI
certifies as compostable in an
industrial composting facility. The
label uses a symbol with supporting
text that clearly indicates that the
product or packaging should not be
placed in backyard compost.
Additionally, the label includes the
URL for a website where consumers
can look up if the product or

CONTAINER

*Not in backyard;
Composting
programs for this
container may not
exist in your area.

6

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Name

Description

packaging is accepted at a facility in
their area.10

Symbol

Australasian
Recycling Label

Similar to the How2Recycle label, this
label identifies specific parts of a
package (lid, cup, sleeve, etc.) and
identifies the proper way to dispose
of them.11

Lid

RECYCLABLE

This can be
placed In your
kerbside
recycling as it is.

CONDITIONALLY
RECYCLABLE
Can be recycled
If the
instructions
below the
symbol are
followed.

This cannot be
placed in
kerbside
recycling. Please
dispose in your
rubbish bin.

PACKAGE
COMPONENT

This refers to an

individual
component of the
packaging.

]

1 PLASTIC IN PRODUCT |

European
Union (EU)
Single-Use
Plastic Label

The EU Directive on single-use plastics
has labeling requirements for
products commonly found on
Europe's beaches. The labels inform
consumers about the plastic content
in products, disposal options that are
to be avoided, and harm to the
environment that can result from
improper disposal.12

3 EPA Labeling and Voluntary Programs

Beyond the recycling and composting sectors, EPA operates several labeling programs that could serve as
examples for EPA's forthcoming guidelines. This section summarizes information about the development and
effectiveness of four existing labeling programs and describes effective implementation strategies for each
program.

3.1 ENERGY STAR

EPA and DOE developed the ENERGY STAR voluntary certification and symbol with the idea that a government-
sponsored program could simultaneously support economic growth and environmental protection. EPA
suspected that placing an easily identifiable label on energy-efficient goods would sway consumer purchasing
habits towards products that reduce greenhouse gas emissions and pollutants and save consumers money on
energy bills. Since 1992, consumers have saved over 5 trillion kilowatt-hours of electricity, saved more than $500
billion in energy costs, and prevented 4 billion tons of emissions through purchasing ENERGY STAR products. In
that time, ENERGY STAR has become "the international standard for energy efficiency and one of the most
successful voluntary U.S. government programs in history."13

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The ENERGY STAR program has partners in the public and private sectors,
including utility companies; manufacturers and retailers; state and local
governments; real estate developers; and nonprofits. Through these
partnerships, EPA has provided the support and stability homeowners,
businesses, and organizations need to advance their energy efficiency.13
Successful outreach and partnership efforts have led to 12 percent of U.S.
homes achieving the ENERGY STAR certification. ENERGY STAR program
success is also evident in the fact that 90 percent of American households
recognize and understand the ENERGY STAR icon (see Figure l).13

To earn the ENERGY STAR certification, a product must meet the energy efficiency standards set by EPA. When
developing energy efficiency requirements, EPA considers the product's overall impact on nationwide energy
savings; performance and features desired by consumers; cost savings compared to less energy-efficient
counterparts; market availability through use of non-proprietary technologies; verification of energy
consumption and performance through testing; and visible differentiation through labeling.

Third-party certification is required for products, residential buildings, and commercial buildings to earn the
ENERGY STAR label.15 Revisions to the energy efficiency requirements occur based on changes to federal
regulations, energy-saving technologies, product availability, consumer energy-saving data, product
performance, and product testing.14 Understanding how ENERGY STAR adjusts it requirements may lead to
useful insights when considering different approaches to updating EPA's voluntary labeling guidelines so they
keep pace with the evolving battery landscape.

3.2 WaterSense

The EPA's WaterSense voluntary partnership and labeling program helps consumers identify water-efficient
products and save money on utility bills. EPA considers a product to be water efficient if it uses 20 percent less
water than conventional counterparts. Today, more than 25,000 products, ranging from irrigation technology to
faucets, carry the WaterSense label. WaterSense relies on third-party certifying bodies to test the efficiency and
performance of products that bear the WaterSense label (see Figure 2). Since the program's launch in 2006, EPA
reports that WaterSense products have saved Americans 8.7 trillion gallons of water and 997 billion kilowatt-
hours of electricity. As a consequence, American consumers have saved over $207 billion on water and energy
bills.16

As with ENERGY STAR, the success of the WaterSense program is partly attributable to strong partnerships
across public and private industries.16 WaterSense partners promote the program
through their participation in national outreach campaigns, annual feedback on water-
efficiency activities, and backing of WaterSense-labeled products.16 The WaterSense
website provides educational materials and programming for ambassadors and
consumers, including sector-specific water-saving ideas and facts about water use.16

The WaterSense program guidelines outline the public process for developing and
revising water-efficiency specifications.17 EPA evaluates candidates for the WaterSense
label based on each product's potential for water savings; performance compared to
conventional counterparts; market availability through use of non-proprietary
technologies; and cost-effectiveness. EPA verifies each product's water savings and

ENERGY STAR

Figure 1:

ENERGY STAR label. Source:
ENERGY STAR, n.d.14

X\erSe>\

\®S	•*£/

Figure 2:
WaterSense label.
Source: EPA, 2024.16

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performance, and there must also be assurance that the product will not have negative environmental or
economic externalities.18

3.3	Safer Choice

The EPA's voluntary Safer Choice label helps consumers and purchasers identify cleaning products—ranging
from hand soaps and fabric softeners to bathroom and dry erase board cleaners—that are safer for human
health and the environment.20 EPA rigorously reviews every chemical in a product before the product receives a
Safer Choice label (see Figure 3). To fulfill the Safer Choice Program requirements, manufacturers must use
chemicals that are less hazardous than the conventional ingredients.19 Safer
Choice products must also comply with EPA's standards for pH, packaging,
volatile organic compounds, and performance.21

In August 2024, EPA released its latest edition of the Safer Choice and Design for
the Environment Standard, its first update since 2015.20 The updated standard
strengthens the program's requirements and clarifies its language to further
protect ecosystems and the health of all people, especially those who work with
cleaning products. EPA also updated the Standard's packaging criteria, setting
stronger requirements for recycling, energy efficiency, and reduction of
hazardous chemicals.20

The Safer Choice webpage offers resources to support manufacturers and
consumers. These include step-by-step documents and flowcharts to assist
manufacturers through the certification process; a media kit; the latest edition of
the Safer Choice and Design for the Environment Standard and Safer Chemical
Ingredients list; and databases to help manufacturers and consumers explore
Safer Choice-approved chemicals.

EPA conducts annual audits to ensure that companies continue to comply with the updated Safer Choice and
Design for the Environment Standard in light of new toxicology research and regulations.22 EPA also hosts an
annual awards ceremony to honor companies that avoid using hazardous chemicals in their products or product
lines and support EPA's mission. Through a transparent materials certification and requirement process, the
Safer Choice label helps EPA increase the number of safe and sustainable products on the market.23

3.4	RCRA Hazardous Waste Labels

Under the Resource Conservation and Recovery Act (RCRA) (40 CFR part 262.32), EPA has the authority to
control hazardous waste labeling requirements.

SAFER
CHOICE

Meets U.S. EPA
Safer Product
Standards™

epa.gov/saferchoice

Figure 3:

Safer Choice label.
Source: EPA, 2024,19

9

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When accumulating hazardous waste, a generator of waste must label containers with the words "Hazardous
Waste" as well as the date the waste started to accumulate. When a generator is preparing hazardous waste for
shipment, 40 CFR part 262.32(b)(1) specifies that the label must include the following language: "HAZARDOUS
WASTE—Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority
or the U.S. Environmental Protection Agency." The label must also indicate
the generator's name, address, and EPA identification number. In addition,
hazardous material labels must indicate dangers such as flammability,
explosiveness, and danger to the environment, in accordance with the DOT's

regulations on hazardous materials found in 49 CFR part 172. Figure 4 shows	_____

the Class 9 Lithium Battery label required by the DOT on the exterior

shipment packaging for lithium batteries.24	"If™* //

.llllk

NX 9

The RCRA hazardous waste guidelines have helped create a comprehensive
hazardous waste management system across the United States.25 However,
the regulation depends on EPA and the states to monitor new chemicals,	Figure 4:

develop and maintain a workforce that can identify and treat hazardous	Class 9 Lithium Battery label,

chemicals, and engage in long-term stewardship plans. While the RCRA	Source: DOT, 2023.24

hazardous waste label effectively communicates the presence of a dangerous substance, states and EPA must
ensure that resources are in place to treat, research, and monitor the waste throughout the country.25

3.5	National Vehicle Mercury Switch Recovery Program

The National Vehicle Mercury Switch Recovery Program (NVMSRP) is a voluntary, shared responsibility program
between EPA, vehicle manufacturers, and the environmental, steel, and recycling industries. NVMSRP began in
2006 with the aim of recovering 80 to 90 percent of mercury switches from scrap vehicles.26,27 Prior to 2003,
vehicle manufacturers made switches for anti-lock brake systems and convenience lighting using mercury, a
neurotoxin. During the vehicle dismantling process, mercury from these switches may be released into the
atmosphere. From there, it can make its way into waterways where it can contaminate wildlife and food webs
and pose a health risk to people.28 Through partnerships with over 10,000 recyclers and dismantlers, NVMSRP
has safely recycled more than 6.8 million mercury switches and prevented the release of 7.6 tons of mercury
into the atmosphere.29

NVMSRP has found success through strong collaboration and shared responsibility with dismantlers,
steelmakers, and environmental groups. The End of Life Vehicle Solutions Corporation (ELVS), an organization
created by the automotive industry, provides vehicle dismantlers nationwide with free mercury switch collection
buckets, transportation, and disposal. ELVS is responsible for data collection, performing educational outreach,
developing best practices for mercury disposal, and contracting with environmental service companies for
mercury switch removal. The ELVS website also provides educational materials for partners, such as tutorials for
dismantlers on how to remove mercury switches.30

3.6	U.S. Fuel Economy Labels

EPA and the DOT's National Highway Traffic Safety Administration first developed U.S. fuel economy labels in
1974, and the labels were updated most recently in 2013 with the goal of providing consumers with more robust
information on fuel efficiency and environmental performance.31,32 As shown in Figure 5, the 2013 fuel economy
labels indicate fuel economy, fuel costs, and environmental impacts for new vehicles.32 Each label includes a

10

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greenhouse gas emission rating, a smog rating, and a quick response (Q.R) code that directs consumers to
additional information regarding environmental sustainability.32 Labels are physically affixed to cars being sold
and are also available online for consumers to research.32 All passenger cars and trucks (model year 2013 or
newer) sold by dealers must bear the improved fuel economy label.33 The improvement of the fuel economy
label demonstrates the importance of creating adaptable labels that can evolve with new technologies.

Fuel Economy and Environment

Gasoline Vehicle

Fuel Economy

(—l ^^ MPfS Small SUVs range from 16 to 32 MPG. YO U OC1VC
[¦ji The best vehicle rates 99 MPGe.

Z622 32 $1'850

n 'n fue' costs

combined city/hwy city highway *-

over 5 years

O O compared to the
O .O sailor* per 100 miles average new veh|c|e

Annual fuel COS*t

$2,150

^ a

Fuel Economy & Greenhouse Gas Rating tailpipe only) Smog Rating Ctailpif

fl ID a v d

Best

This vehicle emits 347 grams CO, per mile. The best emits 0 grams per mile (tailpipe only*. Producing and
^distributing fuel also create emissions, learn more at fueleconomy.gov.

Actual results will vary for many reasons, including driving conditions and how you drive and maintain your
vahicle. The average new vehicle gets 22 MPG and costs $12,600 to fuel over 5 years. Cost estimates are
based on 15,000 miles per year at S3.70 per gallon. MPGa is miles par gasoline gallon equivalent. Vehicla
emissions ara a significant cause of climate change and smog.

fueleconomy.gov

^Calculate personalized estimates and compare vehicles

Smart phone
QR Code"

lilVBSflil

Figure 5: Fuel economy label for gasoline vehicle. Source: DOE, n.d.3

4 Other Federal Labeling Programs
4.1 EPEAT

EPEAT is an ecolabel managed by the Global Electronics Council that helps purchasers identify more sustainable
technological products and holds manufacturers accountable for selling products with transparent supply
chains.35 In addition to the EPEAT ecolabel, the program offers a product registry and a benefits calculator that
help point consumers toward sustainable electronics.36 All products on the EPEAT registry must meet EPEAT
criteria and be independently audited by a conformity assurance body before receiving an EPEAT label. The
EPEAT criteria cover core sustainability areas, including climate change, circularity, and environmental social
governance, across the electronic supply chain.

Status markers and public acknowledgement help EPEAT incentivize participating brands to continue to meet
the required criteria. EPEAT has expanded its core EPEAT+ ecolabel to include "EPEAT Ciimate+" and "EPEAT
Climate+ Champions," presenting manufacturers with the opportunity to become industry leaders in making
environmentally and socially sustainable products.36 Additionally, the program created three certification tiers-
bronze, silver, and gold—with each tier representing products that meet a specific set of criteria.36 EPEAT also
hosts an annual awards ceremony to honor organizations that are using EPEAT-registered technological
products and have an active organizational sustainable purchasing policy.37

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EPEAT develops its criteria through a voluntary consensus process that involves a range of company
representatives from across the electronics life cycle. As sustainability research advances and new products and
categories enter the market, EPEAT makes updates to the criteria. EPEAT provides transparency through public
reports on the annual monitoring of active EPEAT registry products.36

4.2	Food Nutrition Labels

Food nutrition labels can be voluntary or mandatory. As a result, food product labels can bear a wide range of
claims and information. The Nutrition Labeling and Education Act of 1990 requires food manufacturers to place
a Nutrition Facts Label on their products. Developed by the U.S. Food and Drug Administration, the label
presents science-based dietary information and is designed to help consumers make better informed food
choices.38 However, manufacturers can also include voluntary labels on their products that describe the
products' characteristics with the intention of influencing a consumer's purchasing habits. These voluntary
labels include "raised without antibiotics," "low-fat," and "organic."38 A 2018 article published in the American
Journal of Preventative Medicine investigated the influence of food and beverage labeling on consumer
behaviors, industry behaviors, and health outcomes.39 The article synthesized and analyzed the results of 60
intervention studies performed across 11 countries between 1990 and 2014. The study concluded that food
labeling can positively impact human health by influencing industries to reduce levels of sodium and artificial
trans fats in their products, leading to higher rates of consumer vegetable consumption.39

A 2019 study highlighted the importance of consumer education in the United States to complement labeling.40
The study noted that "consumers who have higher levels of education and nutrition knowledge are typically able
to comprehend label information and compare foods using labels easier than others."40 The study also
highlighted a 1996 research paper that uncovered the importance of education in contributing to Americans'
understanding of nutrition labels.41

4.3	Pesticide Labels

Due to the potential impacts of pesticide use on health and the environment, EPA requires all pesticide products
to include a label, as directed by 40 CFR part 156. Studies on the effectiveness of pesticide labeling have typically
focused on how to improve labeling effectiveness, rather than on determining whether labels are more effective
than no labels. A 2024 study, "Pesticide Labels Do Not Effectively Communicate Toxicity Risks," evaluated the
effectiveness of existing pesticide labels in terms of their format and language and found that eye-catching
pictorial labels are significantly more effective than signal words.42 The study tested two label display formats-
one that used traffic light colors, and one that used a skull symbol—and found that "consumers' correct
assessment of toxicity level dramatically improves from 56 percent under the existing signal word label to 88
percent under the traffic light and 87 percent under the skull intensity labels."42

A 2021 study, "Bridging Safety Language Disparities in Orchards: A Pesticide Label Mobile App," looked at the
effectiveness of a mobile application (app) that displays pesticide label information in Spanish and English.43 This
tool was developed to address the safety disparities among orchard workers resulting from language barriers.
The results determined that the app improved Latinx worker safety. The study emphasized that "the
overwhelming majority of Pacific Northwest agricultural workforce is Spanish-speaking despite critical pesticide
safety information being provided on lengthy product label documents in technical English."43

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4.4 OSHA Hazard Communication Labels

OSHA's Hazard Communication Standard
ensures chemical safety in the workplace. It
requires that employers provide workers with
written identification and safety information
(i.e., labels and safety data sheets) about the
chemicals in their workplace, as well as
worker training.45 OSHA's hazard
communication labels align with the United
Nations' Globally Harmonized System of
Classification and Labelling of Chemicals. The
labels and pictograms used to identify
hazardous chemicals could serve as a model
for consumer education about the potential
risks of improper handling or disposal of
batteries. As shown in Figure 6, labels must
include: employer name, address, and telephone number; product identifier; signal word (e.g., "Danger" or
"Warning"); hazard statement(s); precautionary statement(s); and pictogram(s).44

In 2012, OSHA updated its hazard communication label, featured in Figure 6, to more closely align with the
revision of the Globally Harmonized System of Classification and Labelling of Chemicals.46 OSHA reports that
these changes have helped workers avoid dangerous chemicals and increase productivity. The changes have also
decreased barriers to comprehension by simplifying the label contents.18 These improvements demonstrate the
importance of using icons to simplify messaging.

5 Labeling Program Challenges and Recommendations

To achieve their successes, the labeling programs featured in Sections 3 and 4 have had to overcome significant
challenges. Developing a voluntary program on a national scale requires buy-in from consumers, brands,
retailers, manufacturers, and processors across the product's life cycle.

Box 1 outlines some of the common challenges faced by labeling programs.

Box 1: Challenges Faced by Labeling Programs

Voluntary

• Challenge: Because these labeling programs are voluntary, manufacturers and retailers are not
required to participate, which can limit each label's reach.

• Recommendation: Voluntary labeling programs must work to incentivize participation among
battery manufacturers and retailers by understanding and catering to the needs of different
audiences.

Lack of standardization among required markings and labels

• Challenge: Products, including electronics, are required to include many labels for compliance with
international laws and some of these labels may conflict or cause confusion to consumers. For

0X1252

(disodiumflammy)

.CAS #: 111-11-11xxy^

4
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Box 1: Challenges Faced by Labeling Programs

example, labels indicating recyclability may include the Mobius loop/chasing arrows symbol (e.g.,
How2Recycle) or the French Triman, which are not internationally standardized.

• Recommendation: The use of labels should be harmonized to ensure consistent messaging.
Reducing the number of labels required for compliance, especially if multiple labels or markings are
used to indicate the same message and may cause confusion, could reduce the burden to
manufacturers to add multiple labels on products.

Consumer education

• Challenge: For labels to be effective and lead to action, consumers must understand the symbols
used on the labels. For example, although consumers are familiar with the Mobius loop/chasing
arrows symbol, the symbol itself is not standardized and sometimes leads to confusion.6

• Recommendation: Labeling programs should ensure that their educational programs are robust and
provide clear guidance, with symbols that have consistent uses and meanings.

Lack of call to action

• Challenge: Symbols or images on a label may mislead consumers by not including specific
instructions on the proper disposal or recycling of a battery or battery-containing product.

• Recommendation: Labels need to direct consumers on what to do with the product at the end of its
life. This can be done through text that accompanies symbols to provide clearer guidance to the
consumer.

6 Next Steps

Moving forward, EPA will continue engaging with parties across the battery life cycle to develop the voluntary
battery labeling guidelines as required by the BIL. Specifically, in 2025, EPA will host working sessions on mid-
format and large format batteries in partnership with other federal agencies, battery manufacturers, retailers,
industry leaders, and state, local, and Tribal governments. The goal of these sessions is to build on feedback
received on effective label content and design considerations from the small format battery engagement
sessions. EPA will assess this feedback to inform the development and implementation of the guidelines. The
guidelines will focus on standardizing necessary information for different audiences to identify batteries and
battery-containing products and increase proper EOL management.

To bolster adoption of the voluntary battery labeling guidelines and increase their effectiveness, EPA will
conduct additional research on consumer education and messaging based on feedback gathered from working
session participants. EPA will develop and test messaging to ensure that the labeling guidelines resonate and
meet the needs of priority audiences, including municipalities, consumers, and recyclers. Additionally, EPA will
create a collection best practices toolkit to accompany the voluntary guidelines, which will help to improve EOL
battery management by increasing access to collection sites. EPA will also, in coordination with DOE, develop a
battery EPR framework that addresses battery recycling goals, cost structures for mandatory recycling, reporting
requirements, product design, collection models, and transportation of collected materials.

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References

1. Infrastructure Investment and Jobs Act, Pub. L. No. 117-58, 135 Stat. 429 (2021).

https://www.govinfo.gov/content/pkg/PLAW-117publ58/pdf/PLAW-117publ58.pdf

2. Federal Trade Commission, (n.d.). Green guides. Retrieved February 28, 2024, from

https://www.ftc.gov/news-events/topics/truth-advertising/green-guides

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