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ARC National Position on EV Battery Recycling and EPR

Balancing Progress with Practical Needs in Canada’s Expanding Circular Economy

The Automotive Recyclers of Canada (ARC) welcomes the national expansion of the industry-led EV Battery Recovery Program, spearheaded by Call2Recycle Canada in partnership with participating vehicle manufacturers. This expansion represents a significant milestone toward a more circular and sustainable future for electrified vehicle (EV) batteries in Canada.

However, while this program is a step in the right direction, ARC urges all stakeholders to ensure that this new voluntary system addresses the on-the-ground realities faced by auto recyclers—especially in rural, remote, and high-volume salvage operations.

 The Balanced View: Whats Promising, Whats Missing

 What ARC Applauds:

  1. National Scope: For the first time, a coast-to-coast solution exists for managing EV batteries outside OEM-led warranty or recall programs.
  2. Streamlined Access: Battery holders, including dismantlers, now have access to a common portal (EVBatteryRecovery.ca) to submit pickup requests and track compliance.
  3. Recognition of Circular Economy Goals: The program recognizes the role of repurposing, remanufacturing, and recycling, rather than defaulting to disposal.

 What Still Needs to Be Addressed:

  1. No-Cost Commitment Must Be Clear & Binding
    While the program promises increased access, it does not explicitly guaranteefree and timely pickup of zero- or negative-value batteries. Many ARC members hold such batteries without warranty, incurring storage and safety liabilities.
  2. Geographic Equity is Still Unproven
    The rollout must serve all provinces, not just metro regions. ARC will closely monitor whether dismantlers in Atlantic Canada, Northern Ontario, the Prairies, and Northern BCreceive equitable support.
  3. Recyclers Still Left Out of the Dialogue
    Despite language around “increased dialogue,” the program is OEM- and platform-led, with limited input from dismantlers, who are typically the first to remove and safely store EV batteries. That must change.
  4. Voluntary Status Limits Accountability
    This is a voluntary, not regulatory, program. ARC has long maintained that unless every battery is covered, and all players participate, Canada risks repeating the mistakes of other underperforming EPR schemes.
  5. Data & Safety Infrastructure Still Developing
    The commitment to improved data is welcome—but without mandatory VIN-level tracking, training support, and safe containment infrastructure, dismantlers remain exposed to fire and liability risks.

 ARC’s Evolving Position in Light of the Program

“We commend the national scope of this voluntary EV Battery Recovery Program as an encouraging first step — but only if it serves all ARC members by ensuring no-costtimely pickup of all EV batteries, regardless of value or location. Without this guarantee, the risk of stranded, unsafe batteries remains real.”
— Wally Dingman, Executive Director, ARC

To that end, ARC proposes the following:

 Recommendations for Strengthening the Program

  1. Establish a No-Cost Pickup Guarantee
    Explicitly confirm that all eligible batteries — including those from collision write-offsauction buys, and non-OEM resale channels— will be accepted at no cost to certified recyclers.
  2. Formalize Recycler Representation in Governance
    Include dismantlers and ARC representatives in ongoing program oversight and advisory functions, ensuring on-the-ground insight shapes operations.
  3. Expand Training & Liability Support for Recyclers
    Provide certified training programs and liability protection for dismantlers participating in the program, as has been done in Europe and California.
  4. Align Federal & Provincial Policy with Program
    Use this program as a foundation for formal policy development, ensuring all provinces adopt common standards, enforceability, and safety protocols.
  5. Track Battery Flows Transparently
    Publish annual reports on volumes collected, reuse/recycling destinations, and service gaps by region—so shortcomings can be addressed early.

 Final Summary

ARC supports this national program as long as it evolves to become:

  1. Truly inclusiveof all dismantlers and provinces
  2. Fully accountablethrough clear no-cost, no-gap service guarantees
  3. Integrated into public policyover time

We remain committed to collaboration and ready to support this expansion—but we will continue to advocate for reliable, safe, and cost-free recovery pathways that serve the entire auto recycling sector, not just select channels.