Quebec's EV Battery Recovery Program Goes Nationwide

On June 26 2025, the Electric Vehicle Battery Recovery Program (the "EV Battery Program"), originally an industry-led Quebec initiative, announced that it has now expanded across Canada. The EV Battery Program was first piloted in Quebec two years ago as a collaborative initiative between electronic vehicle ("EV") manufacturers, Call2Recycle Canada Inc. ("Call2Recycle"), a national consumer battery recycling organization, and the Province of Quebec to ensure responsible recovery of EV batteries at their end-of-life consistent with the principles of extended producer responsibility ("EPR").¹

The EV Battery Program comes at a time where there is growing awareness of the need for proper systems to manage EV batteries at their end-of-life as well as the increasing expansion of consumer battery EPR programs within Canada. The timing for this program also coincides with the newly published rules under the EU Battery Regulation (2023/1542) introduced in the European Union ("EU") that applies to all new batteries placed on the market or put into service within the EU and all economic operators in the supply chain, including manufacturers, importers, distributors and retailers.

Taken together, the EV Battery Program and the existing and developing EPR regulations in Canada and beyond reflect the growing trend towards greater scrutiny around management of batteries at their end-of-life as well as an increased focus on creating a more circular economy. This bulletin provides an overview of the EV Battery Program and its national expansion.

The EV Battery Program

In 2021, the Province of Quebec announced plans to impose recycling regulations on companies who produce EV batteries² by designating EVs as a product category under its existing EPR regulation.³ In response, the Canadian Vehicle Manufacturers' Association, the Global Automakers of Canada and the Government of Quebec collaborated to develop and adopt the Program as an alternative to provincially-imposed recycling requirements.⁴ While the majority of EV manufacturers already had mechanisms for recovery and management of EV batteries covered by warranty or recalled or returned through official distribution channels, the Program aimed to recover batteries that were out of reach for manufacturers.

Battery holders who meet the qualifying criteria can contact designated service providers for collection of their EV batteries at no cost. Eligible participants include automative dismantlers and recyclers, automative shredders, independent repair garages, vehicle dealerships and fleet operators – common service providers for vehicles in need of repair or at their end-of-life.⁵ For most of the participating vehicle manufacturers, Call2Recycle coordinates the logistics of the collection and transportation of the recovered batteries.

The EV Battery Program is currently supported by sixteen participating auto manufacturers and remains focused on responsible recovery of damaged or defective EV batteries at their end-of-life in order to mitigate potential health and environmental risks associated with their disposal and encourage sustainable usage for spent batteries.⁶ This is done by diverting EV batteries from landfills, which are instead:

• remanufactured for reuse in vehicles;
• repurposed for an alternate use;
• recycled back to original metals for use in new products; or
• sent to vehicle manufacturer research and development centres for analysis.

Nationwide Expansion & Implications for Businesses

Two years after the program's implementation in Quebec, the Program is now expanding nationwide. The expansion will provide greater accessibility to eligible EV battery holders throughout Canada and streamline the national EPR approach to EV battery management.⁷ This also represents the ongoing commitment of participating vehicle manufacturers to the EV Battery Program. To find out if your business qualifies for the program or to access further details you can visit the EV Battery Recovery homepage.

The expansion of the EV Battery Program can be attributed to both the buy-in by vehicle manufacturers to develop an EPR program that aligns with industry realities as well as government acceptance of an alternative to a regulated EPR program where its objectives are being achieved. While jurisdictions such as British Columbia have announced their aspirations to expand their regulated EPR programs to include hybrid and EV batteries, aiming to implement the first EPR program for EPR EV batteries, these jurisdictions may be reconsidering their approach given the voluntary program now in place.

With this industry-led EPR model in full view and the ever-increasing regulation of environmental matters impacting businesses, other industries should consider opportunities to develop their own recycling or waste management programs. Such programs allow industries to have direct input into their design that takes into account the practicalities and costs specific to their day-to-day operations, potentially avoids or limits regulatory oversight, and showcases their proactive EPR approach to investors and the public.

We will continue to monitor the progress of the EV Battery Program and other Canadian regulatory developments with respect to EPR, recycling and other waste management that may affect Canadian businesses and others doing business in Canada.

Footnotes

1. EV Battery Recovery, Program Details (accessed on August 5, 2025).

2. Le gouvernement du Québec, Vers une société zéro déchet – Québec s'attaque au recyclage de nouveaux produits, dont les batteries de véhicules électriques (14 October 2021).

3. Ibid. See also, , Recyc-Québec, Québec favorise l'économie circulaire en assujettissant de nouveaux produits à la responsabilité élargie des producteurs (REP) (21 June 2022).

4. Association des Véhicules Électriques du Québec, Le Québec et les partenaires de l'industrie lancent un programme de recuperation de batteries des véhicules électriques (31 July 2023).

5. Supra note 1.

6. Call2Recycle, Déploiement National du programme dirigé par l'industrie de récupération des batteries de Véhicules Electriques (VE) ( June 2025).

7. Ibid.