A new generation of rechargeable batteries is entering the market to provide power for energy-intensive automotive, communications, utility, manual labor and manufacturing applications. These new batteries also are creating environmental and safety challenges because they are designed, used and discarded in a linear process with limited material recovery, rather than recycled in a safe closed-loop, circular manner. This stands in contrast to lead-acid batteries, which are 99 per cent recycled because the materials can be economically recycled for use in new batteries. U.S. regulations governing lead-acid batteries, however, are not applied comparably to other battery chemistries made with lithium, nickel and various rare earth, causing waste disposal issues. In addition, U.S. regulations are not reflected in other countries. This results in a “race to the bottom” in which many spent batteries (including lead-acid) are exported to poorly regulated recyclers outside the U.S. To evaluate potential closed-loop solutions to issues posed by inconsistent regulation, the current state of law governing hazardous waste disposal (including the “Universal Waste“ rule) is critically examined in this paper. An analytical tool is proposed that would enable equitable comparisons among the full range of battery chemistries (lead-acid, lithium, etc.) on a levelized basis by taking into account internal manufacture costs that are recovered in a retail battery price and external disposal costs that are not. This levelized cost model will help in the analysis of various approaches to circular materials management.