Used batteries and e-waste at a junkshop: DENR rules explained

A summary, not legal advice. Checked October 7, 2026.

Used lead-acid batteries and most e-waste are hazardous waste under RA 6969 and DENR Administrative Order 2013-22. Those rules expect hazardous waste to be registered with the DENR Environmental Management Bureau (EMB), stored safely, moved by registered transporters and handed only to registered treatment or recycling facilities. Your city can add its own conditions, and in Bacolod it closed a junkshop over stored batteries.

This guide covers the environmental side. Stolen goods, proof of ownership, the Anti-Fencing Law (PD 1612) and city record books are covered in our guide "Junkshop permit requirements and record books in the Philippines".

Are used car batteries hazardous waste?

Yes. RA 6969, the Toxic Substances and Hazardous and Nuclear Wastes Control Act, was approved on October 26, 1990. Its definition of hazardous wastes starts with waste shipped into the country for dumping, but a second paragraph extends it to by-products, process residues, contaminated equipment and "consumer discards of manufacture products". The law makes the DENR its implementing agency, with the power to inspect any establishment where chemicals are stored and to confiscate or impound them.

RA 9003, the Ecological Solid Waste Management Act, lists household batteries, lead-acid batteries and consumer electronics among special wastes. Its Section 28 says toxic materials in the waste stream should be collected separately and sent to hazardous waste treatment and disposal plants, consistent with RA 6969.

DAO 2013-22, the DENR's revised procedures for hazardous waste, carries the same idea into its classification. It lists special wastes, including lead-acid batteries and busted lamps, and it lists waste electrical and electronic equipment that contains lead, cadmium, mercury, hexavalent chromium or certain brominated flame retardants, including peripherals such as ink cartridges and toners.

What does DAO 2013-22 ask of a waste generator?

The order was issued in December 2013 to implement RA 6969, revising the earlier procedural manual (DAO 2004-36). It covers generators, transporters, treatment, storage and disposal (TSD) facilities, storage and labeling, the transport manifest, contingency plans, training and penalties. For a hazardous waste generator, Chapter 3 requires the following:

• Register online with the EMB regional office that covers your location, pay the fee, and receive a DENR ID number.
• Designate a full-time Pollution Control Officer.
• Report the type and quantity of hazardous waste generated and sent offsite.
• Store waste to the standards in Chapter 6. The maximum accumulation time is one year.
• Use only transporters and TSD facilities registered by the EMB, with permits valid while your waste is moved and treated.
• Use the online hazardous waste manifest whenever waste leaves your premises.
• Get the Certificate of Treatment, which the TSD facility issues within 45 days of receiving the waste, and keep the original.
• Stay responsible for the waste until a registered treater or recycler certifies it has been treated, recycled or disposed of.
• Prepare a contingency and spill response plan, and train the people who handle the waste.

Does a junkshop count as a generator? The order defines a waste generator as a person who generates or produces hazardous wastes "through any institutional, commercial, industrial or trade activities". It does not mention junkshops by name, and a shop that buys and resells batteries does not fit the definition neatly. Before you stock batteries in any number, ask your EMB regional office in writing which registration, if any, applies to you, and keep the reply.

Who may haul and recycle used batteries?

Under DAO 2013-22, hazardous waste transporters register with the EMB. Among the requirements are a business permit and SEC registration, photos and proof of ownership of each vehicle, LTO registration with an emission test, a garage, a certification from the transport department that the vehicles are fit to carry hazardous materials, and the names of drivers and crew.

Recyclers register as TSD facilities. One category covers facilities that recover valuable materials such as used oil, solvents, acids and metals. An approved facility gets a TSD Registration ID number and is added to the list of registered TSD facilities on the EMB website. A regular registration certificate is valid for a maximum of one year, so ask to see a current one.

The penalties are real. DAO 2013-22 sets administrative fines of ₱50,000 for violations such as moving hazardous waste without the manifest, labels or placards, or doing the work of a TSD facility without a TSD permit. RA 6969 itself lets the DENR Secretary impose administrative fines of ₱10,000 to ₱50,000. Its criminal provisions go much higher: causing or facilitating the storage of hazardous and nuclear wastes is punished with 12 years and one day to 20 years in prison. That section is written mainly with imported waste in mind, but it is one more reason not to stockpile.

Illegal smelting is what the regulators are chasing. In September 2024, the Federation of Philippine Industries asked the DENR to make battery makers and importers collect used batteries and send them to accredited recyclers, and named illegal lead smelters in San Simon, Pampanga, Valenzuela, Tarlac and Cavite (GMA News). A junkshop that sells to a backyard smelter is feeding exactly that problem.

What happened to the Bacolod junkshop?

On June 29, 2023, Bacolod police seized telco batteries from the storage facility of DLC Junkshop/ILC Surplus on Mabini Street, Barangay 25: 136 telco battery units valued at about ₱13.2 million and 15 twelve-volt units valued at ₱1.5 million. Anti-Fencing Law charges were filed on July 4 against the owner, the co-owner, the manager and one other person, with a Globe representative as complainant. On July 6, the city issued a notice revoking the business permit and closing the shop.

When the family asked Mayor Alfredo Abelardo Benitez on July 19 to lift the closure, SunStar Bacolod reported that he answered: "But for us, whether you buy contraband or illegal batteries, the mere fact that there were batteries recovered in the junk shop is already a violation." He said the city would set penalties the business could pay to reopen, separate from the criminal case, and that he would propose an ordinance covering purchases of hazardous items, with the city environment and legal offices in charge.

Two lessons for any owner. First, the city acted through the business permit, on its own track, while the criminal case went on separately. Second, in Bacolod's view, holding batteries at all was the problem, whether or not they were stolen. Other cities may see it the same way.

What about e-waste?

Appliances, computers and phones bring in copper, aluminum and steel, and many junkshops buy them. The hazardous parts are the ones DAO 2013-22 names: components with lead, cadmium or mercury, batteries, busted lamps, ink cartridges and toners. RA 9003 also bans the open burning of solid waste, which rules out burning insulation off wire.

Dedicated e-waste rules were still unfinished at last public word. In a 2024 presentation, the chief of the hazardous waste section of EMB Region VII reported that the draft guidelines on the environmentally sound management of waste electrical and electronic equipment had been returned to the EMB Central Office to consolidate comments. The same presentation listed proposed amendments to DAO 2013-22, including a longer storage time limit, registrations of up to three years for TSD facilities and transporters, and a ban on exporting used lead-acid batteries. Until new rules are issued, DAO 2013-22 is the order to follow. Ask your EMB regional office whether anything has changed.

How should you handle batteries in the yard?

DAO 2013-22 sets minimum standards for hazardous waste storage: accessible for emergencies and inspection, enclosed but ventilated, with floors that resist chemicals and hold spills, secured against unauthorized people, and with incompatible wastes such as strong acids and strong bases kept apart. Practical habits that follow from it:

• Keep batteries apart from other kalakal, on a sealed floor that can contain a leak, under a roof, and behind a lock.
• Never crack open a battery case or drain the acid in your yard.
• Keep stock moving. Do not let batteries pile up while you wait for a better price.
• Sell only to an EMB-registered TSD facility. Ask for its registration certificate, check that it is current, and ask whether the truck that collects is a registered hazardous waste transporter.
• Keep the papers: the buyer's registration, delivery receipts, any manifest or certificate of treatment, and your record of who sold you each battery.
• Treat big industrial batteries, such as cell site or backup power units, as a warning sign. Ask who owns them before you weigh anything.
• Ask your city's environment office and business permits office whether your junkshop permit covers storing batteries at all.

ScrapTrack, the junkshop system from Orvyn Solutions, can carry batteries and e-waste as their own materials, with stock in kilos and pesos per yard location, an audit trail of every change, and deliveries that show what each trading company accepted and still owes. That gives you a clean record of what came in and where it went. It does not file anything with the DENR, the police or city hall, has no seller ID field yet, and does not decide whether your records satisfy any rule. A demo is available.

Sources

• Republic Act No. 6969, Toxic Substances and Hazardous and Nuclear Wastes Control Act of 1990, on Lawphil (lawphil.net). Checked October 7, 2026.
• DENR Administrative Order No. 2013-22, Revised Procedures and Standards for the Management of Hazardous Wastes, cover order on the DENR site (denr.gov.ph) and full procedural manual on the WTO Import Licensing site (importlicensing.wto.org). Checked October 7, 2026.
• Republic Act No. 9003, Ecological Solid Waste Management Act of 2000, on Lawphil (lawphil.net). Checked October 7, 2026.
• "Challenges and good practices for the implementation of the PIC procedure", EMB Region VII, Asian Network Workshop 2024, on the Ministry of the Environment, Japan site (env.go.jp). Checked October 7, 2026.
• "Raps filed vs junk shop owner, 3 others", July 6, 2023, SunStar Bacolod (sunstar.com.ph). Checked October 7, 2026.
• "DLC Junkshop appeals to lift closure order", Merlinda A. Pedrosa, July 22, 2023, SunStar Bacolod (sunstar.com.ph). Checked October 7, 2026.
• "FPI seeks to mandate makers, importers of vehicle batteries to recycle toxic wastes", Ted Cordero, September 12, 2024, GMA News (gmanetwork.com). Checked October 7, 2026.