If an automobile manufacturer receives finished car batteries and places these batteries into the cars they sell, must the automobile manufacturer report the lead which is incorporated in the battery?
If the car battery is completely sealed while present at the facility, it would be considered an article, and thus would be exempt from EPCRA Section 313 reporting. If lead is released from the batteries under normal processing at the facility, as might occur during maintenance of the battery, the release would negate the article exemption. If the exemption is negated, the amount of lead and any other toxic chemical in these non-article batteries would be applied toward the processing threshold to determine if the facility must report. Additional guidance regarding the article exemption can be found in Directive #1 of the Revised 1998 EPCRA Section 313 Questions and Answers Document.