What to do with lithium batteries at the end of their useful life: the protocol Mexico still does not have

The regulatory gap that becomes a crisis

Mexico has no mandatory federal protocol for the final disposal of lithium-ion batteries at the end of their useful life. What exists is a scattered regulatory framework that partially covers the chain: the General Law for the Prevention and Integrated Management of Waste (Ley General para la Prevención y Gestión Integral de los Residuos, LGPGIR) classifies batteries as hazardous waste by flammability characteristic, but the specific treatment for lithium batteries comes from extensions by analogy with lead-acid batteries and from air/sea transport regulation under NOM-053-SCT-2 and NOM-018-STPS-2015. In practice, this means that the decision of what to do with a 4,000 kg battery bank coming out of a UPS at a Mexican data center depends on the service provider the operator chooses, not on a unified national protocol.

The number that sizes the problem

The Mexican battery recycling market reached USD 269.4 million in 2025 according to IMARC Group, with a projection of USD 476.6 million by 2034, a CAGR of 6.35%. The figure includes all battery categories: automotive lead-acid, electric vehicle lithium-ion, industrial batteries, infrastructure backup batteries. Electric vehicle sales in Mexico grew 41.1% year-over-year at the close of 2024, with 12,147 units sold in November of that year alone. 100% electric units rose 80% versus the prior year, totaling approximately 15,000 new units in 2024.

By 2030, the cumulative volume of lithium-ion batteries reaching end of useful life in Mexico — adding EV, stationary storage infrastructure, and UPS banks — will be in the range of tens of thousands of tons per year. Mexican regulation advances more slowly than the problem.

What does exist and what does not

The current regulatory framework for used batteries in Mexico includes:

• LGPGIR and its Reglamento. Establish the general framework for hazardous waste management. Used batteries are listed as hazardous waste in Article 31 of the Reglamento, but the lists do not differentiate between lead-acid and lithium chemistry.
• NOM-052-SEMARNAT-2005. Defines the CRETI characteristics (corrosivity, reactivity, explosivity, toxicity, flammability) for hazardous waste classification. A lithium-ion cell in normal condition meets no CRETI characteristic; a damaged cell, in short circuit, or with active inflammation meets flammability.
• SEMARNAT Resolution 851/2022. Establishes a collection target of 37% of spent batteries and accumulators in 2022, with annual increments of 1% through 2030. It is the most specific provision on batteries, but it focuses on automotive lead-acid batteries.
• NOM-053-SCT-2. Regulates overland transport of hazardous materials, including lithium batteries as Class 9 hazardous material (UN 3480 or UN 3481 depending on whether installed in equipment or standalone).
• General Law of Circular Economy (2025). Published in the DOF, adds six months to average permit time according to sector analysis, but does not establish a federal final disposal protocol for lithium-ion batteries.

What does not exist is a national protocol that specifies: (a) technical criteria to evaluate State of Health (SOH) of a cell at the moment of withdrawal; (b) mandatory methodology to deactivate cells before transport; (c) hierarchy of preference among reuse, repurposing, material recycling, or final disposal; (d) mandatory certification for lithium-ion recycling service providers.

The real options at end of useful life

For a lithium-ion battery bank coming out of a data center UPS, the technical options available are:

1. Repurposing (second life). Batteries that retain 70-80% of their original capacity can be reused in less demanding applications such as lower energy density stationary storage. The Mexican second-life storage market is forming; European and Asian operators already have mature programs.
2. Hydrometallurgical recycling. Chemical dissolution to recover lithium, cobalt, nickel, manganese. Allows high-purity recovery but requires significant plant investment and effluent management. In Mexico there are few plants with this capacity; most material is exported to Asia or Europe for processing.
3. Pyrometallurgical recycling. High-temperature smelting. Recovers mainly base metals (nickel, cobalt, copper); lithium is lost in the slag. Operationally simpler but less efficient.
4. Direct recycling. Preserves the cathode structure, allows higher recovery rates with lower energy consumption. The technology is emerging; there are still no commercial-scale plants in Mexico.
5. Controlled final disposal. If the battery bank is damaged, the cells present thermal runaway risk, or no recycling option is available, disposal in a safety cell with thermal monitoring is the last line.

The decision among these options depends on: state of health of the bank, distance to the nearest recycling plant, logistics cost, and service provider certifications.

SEMARNAT’s bottleneck

Sector analysis identifies a significant regulatory bottleneck: SEMARNAT has a backlog of 45 permit applications for battery recycling plants, with an average resolution time of 21 months. The 30% vacancy in technical review positions aggravates the delay. On average, a permit now requires 14 separate environmental impact assessments under the 2025 General Law of Circular Economy.

The result is concrete: projects announced as a USD 200 million hydrometallurgical plant in Sonora (Northvolt) and a USD 300 million cathode precursor plant in Nuevo León (Redwood Materials) have seen their timelines extended by the permit delays. A Mexican private capital fund (Fondo MX) deferred USD 150 million in domestic recycling projects.

The Mexican regulatory timeline (21 months) compares unfavorably with the U.S. EPA’s (12 months) and the EU’s revised Industrial Emissions Directive (18 months with simplification). The gap is causing Mexico to lose competitiveness as a destination for recycling investment.

What happens when the battery bank is withdrawn without a protocol

A scenario that has already occurred at Mexican operators and will repeat more frequently:

1. The operator contracts a hazardous waste management service provider with SEMARNAT authorization for “hazardous waste in general”.
2. The provider removes the battery bank, transports it as Class 9 hazardous material under NOM-053, and delivers it to a recycling plant.
3. The recycling plant, if it is a lead-acid plant, has no technical capacity to process lithium-ion. If it is general-purpose, it has no specific authorization for lithium-ion.
4. The bank ends up in temporary storage or in disposal that does not recover materials.

The regulatory risk for the original generator (the data center operator) is that the documentary traceability does not hold up under audit. The environmental risk is that cells stored improperly initiate thermal events.

What the data center operator can do today

For a lithium-ion battery bank that will come out of operation in the next 12 to 24 months, the concrete actions that make sense regardless of the Mexican regulatory framework:

• Document State of Health (SOH) per bank at the moment of the withdrawal decision. That converts the technical decision into auditable data.
• Verify the service provider’s authorization specifically for lithium-ion batteries, not only “hazardous waste in general”.
• Ask the provider for documented destination (recycler, repurposing, disposal) and require copies of NOM-053 transport manifests.
• Consider export to a certified program if the Mexican market does not have adequate local capacity. European and Asian plants hold R2v3, e-Stewards, or equivalent certifications that provide complete traceability.
• Include end-of-life disposal cost in the battery bank TCO from purchase, not as a surprise at the end of the lifecycle.

What will change

The National Waste Reduction Strategy whose completion was expected for December 2025 should introduce Extended Producer Responsibility (EPR) guidelines for batteries, with mandatory recycled content in new battery packs. That changes the model: the manufacturer will be financially responsible for end of life, which in practice will force local recycling infrastructure to operate.

What will not change in the short term is the absence of a mandatory federal technical protocol. As long as that does not exist, the decision of what to do with a lithium battery bank at the end of its useful life in Mexico depends on the diligence of the data center operator, not on the regulator.

Sources

1. IMARC Group (2026). Mexico Battery Recycling Market Size, Share, Trends and Forecast 2026-2034. https://imarcgroup.com/mexico-battery-recycling-market
2. Energy Solutions (2026). Mexico Battery Recycling Permitting Delays Intelligence. https://energy-solutions.co/supply-chain/risk-index/mexico-battery-recycling-permitting-delays-dc55
3. SEMARNAT. Resolución 851/2022 — Objetivos de recolección de baterías y acumuladores. https://www.dof.gob.mx/nota_detalle.php?codigo=5676869
4. Diario Oficial de la Federación. Ley General de Economía Circular (2025). https://www.diputados.gob.mx/LeyesBiblio/pdf/LGEC.pdf
5. Morgan Reed Insights (2025). Mexico Transportation Battery Recycling Market. https://morganreedinsights.com/mexico-transportation-battery-recycling-market