from the Saskatchewan Automotive Recyclers Association (SARA)
The Saskatchewan Automotive Recyclers Association (SARA) appreciates the opportunity to provide input into the renewal of Saskatchewan’s Solid Waste Management Strategy. SARA members represent the professional automotive recycling industry in Saskatchewan and play a critical role in environmental protection, material recovery, and circular-economy outcomes through the responsible management of end-of-life vehicles (ELVs).
SARA members collaborate regularly with provincial peers across Canada through the Automotive Recyclers of Canada (ARC), ensuring that Saskatchewan’s perspectives are aligned with national best practices and policy discussions.
We also acknowledge and appreciate the Ministry of Environment’s recent engagement with the automotive recycling sector, including facility tours conducted in Saskatchewan. Direct observation of real-world operations is an important step toward informed, practical policy development.
Existing Compliance and Oversight Frameworks
All SARA members are CAREC (Canadian Auto Recyclers’ Environmental Code) audited as a mandatory condition of membership. CAREC provides a nationally recognized, third-party verified framework for environmental, safety, and operational compliance specific to automotive recyclers.
CAREC originated in 2008 as the National Code of Practice for Automotive Recyclers, developed in cooperation with the Government of Canada to support the delivery of the National Vehicle Recycling Program – Retire Your Ride. The Code was created to ensure that hazardous materials contained in end-of-life vehicles were managed responsibly and did not contaminate land, water, or air during the recycling process.
Following the conclusion of the federal Retire Your Ride program in 2011, and in recognition of the Code’s effectiveness and widespread industry adoption, the framework was retained, renamed the Canadian Auto Recyclers’ Environmental Code (CAREC), and expanded to apply to all end-of-life vehicles processed by ARC Members, not solely those targeted under the incentive program.
While CAREC is mandatory for all ARC Members, the Code and associated audits are available to any automotive recycler, regardless of ARC membership. This ensures CAREC functions as an open, nationally accessible environmental standard, rather than a membership-restricted requirement, and allows governments to recognize CAREC-audited facilities without compelling business affiliation.
CAREC has been updated over time to remain aligned with evolving regulations, policies, and industry best practices. Today, it serves as an invaluable national standard for the environmentally sound management of ELVs and demonstrates a proactive, industry-led commitment to environmental stewardship originally developed in partnership with the federal government.
SARA has encouraged the Ministry to recognize CAREC audit documentation as a credible and effective compliance mechanism and to focus regulatory and enforcement resources on non-compliant operators and non-members, rather than duplicating oversight for facilities that already demonstrate adherence to established national standards.
Extended Producer Responsibility (EPR) – Electric Vehicle Batteries
SARA recognizes that Extended Producer Responsibility (EPR) has been an effective policy tool in Saskatchewan for certain material streams.
However, with respect to electric vehicle (EV) traction batteries, SARA’s position aligns with the current national consensus within the automotive recycling sector: EPR for EV batteries is not supported at this time.
A voluntary EV battery recovery and management program is already in place and operating nationally, providing a practical framework for safe handling and recovery while EV volumes remain relatively low.
(Reference: EV Battery Recovery Program – https://recuperationdesbatteriesve.ca/en/ev-battery-recovery-home/)
At this stage, this voluntary approach is serving the needs of recyclers, manufacturers, and public safety more effectively than a premature regulatory framework.
SARA recommends that Saskatchewan:
• allow the voluntary EV battery program to continue and mature;
• monitor measurable outcomes such as safe handling, collection coverage, recycler access, and downstream processing capacity; and
• identify clear, performance-based “trigger conditions” that would justify future consideration of EPR only if the voluntary system no longer meets environmental, safety, or operational objectives.
Introducing EPR requirements for EV batteries prematurely risks disrupting existing recovery pathways, increasing costs without demonstrated benefit, and limiting recycler participation at a time when EV adoption remains in its early stages.
Material-Specific Timelines and Expansion of EPR
SARA has concerns regarding the proposal to establish material-specific timelines to expand EPR legislation to a broader range of waste streams, including those generated by the industrial, commercial, and institutional sectors, with priority materials identified as including EV batteries.
Automotive recyclers manage complex products that are already part of a well-established reuse and recycling ecosystem. Any future expansion of EPR must recognize these existing systems and involve early, direct consultation with affected sectors to avoid unintended consequences.
In this context, SARA also encourages Saskatchewan to prioritize the improvement—or establishment, where gaps exist—of a consistent, province-wide recovery system for automotive tires. Inconsistent tire pickups and related operational challenges experienced by recyclers undermine environmental outcomes and create unnecessary operational risk.
Other provinces operate functional tire recovery programs, and ARC has direct experience and expertise across multiple jurisdictions. This knowledge can be leveraged to provide Saskatchewan with practical input on program design, governance, and performance expectations.
Tracking and Monitoring of Unregulated Waste Streams
SARA notes the proposal to track, monitor, and report on unregulated waste streams to inform future waste management efforts.
While data-driven policy is important, SARA cautions against approaches that could inadvertently re-classify end-of-life vehicles as “waste” or reintroduce licensing or regulatory frameworks that were previously eliminated. ELVs are not simply waste; they are complex products that deliver significant environmental benefits through parts reuse, metals recycling, and the proper handling of fluids and hazardous components.
Any tracking or reporting initiatives should:
• clearly distinguish ELVs from unmanaged waste streams;
• recognize the environmental value delivered by professional automotive recyclers; and
• avoid policy mechanisms that could create regulatory uncertainty for compliant businesses.
Closing
SARA supports a balanced, evidence-based renewal of Saskatchewan’s Solid Waste Management Strategy. Continued collaboration, recognition of mandatory CAREC auditing developed in cooperation with the federal government, openness of the CAREC framework to all recyclers, and alignment with national best practices through ARC will help ensure Saskatchewan’s policies achieve strong environmental outcomes without undermining effective existing systems.
SARA welcomes continued dialogue with the Ministry and would be pleased to provide further information or participate in follow-up discussions as the strategy renewal progresses.
Respectfully submitted,
Saskatchewan Automotive Recyclers Association (SARA)