Are spent lead acid batteries exported for reclamation subject to the exporting requirements?
Exporters sending spent lead acid batteries for reclamation under Part 266, Subpart G, are not subject to the export requirements. Under Part 266, shipments of spent lead acid batteries do not require a manifest. However, lead acid batteries managed as universal waste under Part 273 are subject to exporting requirements. Q: Are characteristic by-products subject to exporting requirements? A: If characteristic by-products are exported for reclamation, they are not solid wastes and not subject to exporting requirements ( ยง261.2). Generators exporting characteristic by-products for reclamation must document that the material is not a solid waste (Monthly Hotline Report Question; September 1986). If exporters send these materials for disposal, they are subject to the export regulations. Q: Are primary exporters of hazardous recyclable materials containing precious metals subject to export regulations? A: Yes, generators of (hazardous) recyclable materials exported for precious metals recov
