How Is Canada Managing The End-of-life For EV Batteries?

Right now, it's a work in progress.

For other consumer products—from paint to electronics—Canada has relatively comprehensive end-of-life ("EOL") regulatory frameworks. These stewardship and extended producer responsibility ("EPR") systems seek to ensure that producers fund and manage the collection, reuse, and recycling of their products. However, when it comes to electric vehicle ("EV") batteries, the road to responsible EOL disposal is still under construction. Unlike existing EPR systems, EV batteries lack a cohesive regulatory framework, leaving industry-led initiatives to fill the gap. Without this clarity, stakeholders face uncertainty around compliance, liability, and long-term investment, making it harder to garner the confidence and support needed for a truly circular economy.

With an estimated 93,000 batteries needing recycling by 2040 and nearly 500,000 by 2045, early planning and coordinated action are essential to build a practical, circular system.¹ Meeting this challenge presents an opportunity to build a robust, circular system for EV batteries. Achieving that vision will require proactive planning and strong collaboration between industry and regulators to ensure solutions that are practical, sustainable, and aligned with Canada's broader environmental goals.

The 5 R Model

EV batteries do not follow a linear path to disposal. Instead, their journey is shaped by market dynamics, technical complexity, and sustainability goals. The 5Rs—Repair, Remanufacture, Resale, Repurpose, and Recycle—captures the multiple lives an EV battery can have:²

• Repair: Minor fixes to keep the battery functioning in its original vehicle.
• Remanufacture: Replace faulty components to restore near-new performance.
• Resale: Sell usable batteries as-is, depending on chemistry and remaining capacity.
• Repurpose: Second life in stationary uses like energy storage or backup power.
• Recycle: Recover critical minerals for reuse in new products or battery components.

Each pathway presents distinct technical, economic, and regulatory challenges. For example, hydrometallurgical recycling can recover up to 95% of critical minerals but requires sorting by chemistry and generates hazardous liquid waste. Remanufacturing demands specialized software, equipment, and skilled labour, and is only viable at scale.

Unlike household batteries or electronics, EV batteries are large, complex, and require removal by trained professionals. Further, their residual value makes them more akin to industrial assets than consumer waste, posing challenges for traditional stewardship and EPR regimes, which are typically designed for simpler, single-use products.

The current state of regulation in Canada

Despite keen stakeholder interest, Canada has no federal regime specifically governing EV batteries. However, some federal frameworks do apply. For example, Transport Canada regulates EV batteries as dangerous goods under the Transportation of Dangerous Goods Regulations³ and Environment and Climate Change Canada regulates cross-border movement under the Cross-border Movement of Hazardous Waste and Hazardous Recyclable Material Regulations.⁴ Together these laws add cost and complexity to transport, especially across provincial or international borders.

Provinces are taking different paths. British Columbia signaled it would bring EV batteries into its EPR regime with a 75% recovery target, but that initiative is now paused.⁵ Ontario has no EV‑specific EOL rules. Quebec moved from an early recovery mandate proposal with second‑life limits to a 2023 voluntary, industry‑led take‑back program that has since scaled nationally (as discussed further below).⁶

This uneven engagement contributes to a lack of national coherence. The result is a fragmented landscape with no EV-specific binding obligations, limited transparency, and inconsistent definitions of what constitutes "waste" versus "resource." These definitional inconsistencies affect whether a battery is subject to hazardous waste rules, which in turn influences how it can be transported, stored, and processed. As a result, stakeholders face uncertainty around compliance, liability, and investment decisions, and this in turn risks undermining the development of a robust circular economy.

Emerging industry-led initiatives

Launched nationally in late June 2025, the EV Battery Recovery Program builds on a successful two-year pilot in Quebec. It is coordinated by Call2Recycle and supported by 16 vehicle manufacturers, offering free recovery services to eligible battery holders across Canada, including dismantlers, recyclers, dealerships, fleet operators, and independent garages.⁷

The program follows a three-step process:

1. Eligibility: Batteries must be professionally removed, unmodified, and fully owned, originally installed in a qualifying EV from a participating manufacturer.
2. Identification: Battery holders confirm key details such as vehicle origin, chemistry, serial number, and classification as EOL or damaged/defective.
3. Coordination: Holders contact the designated service provider (often Call2Recycle), which arranges packaging and transport to processing partners.⁸

Collected batteries are remanufactured, repurposed, recycled, or sent to manufacturer research and development centres. When Call2Recycle is the service provider, it manages the full logistics, whereas if the manufacturer is the provider, they oversee processing directly.

While the program demonstrates industry's ability to mobilize quickly, it remains voluntary. Industry groups have welcomed its national scope and alignment with circular economy goals, but concerns persist about accountability, data infrastructure, and equitable access. Without public, standardized reporting and mandatory participation, it is difficult to assess whether batteries are consistently diverted from landfills or long-term storage.

Policy gaps and the road ahead

While a handful of commercial EV battery recycling facilities are emerging, such as Lithion Technologies in Quebec, Electra Battery Materials in Ontario, and RecycLiCo in British Columbia, broader infrastructure remains limited. Freight costs are high, and cross-border transport is complicated by regulatory mismatches. In the absence of a clear national framework, companies may hesitate to invest. That creates a chicken‑and‑egg problem: recyclers want policy certainty before building, and policymakers look for proven capacity before regulating.

The International Energy Agency has stressed that clear, long-term regulations are "crucial for instilling confidence in investors" in the recycling sector.⁹ A robust recycling mandate would likely lower the total cost of EV manufacturing in the long run, ensuring a sustainable, closed-loop supply chain that drives both environmental goals and economic competitiveness.

Other jurisdictions, such as the European Union and China, are advancing recycled content requirements and digital traceability systems,¹⁰ which Canada could draw on in designing a system focused on lifecycle accountability.

However, given the technical demands of processes such as remanufacturing and recycling, which require specialized equipment, software, and skilled labour, it is both practical and necessary for industry to play a central role in any future regulatory regime. Involving industry directly in the design and implementation of such systems could help ensure that recovery pathways are efficient, scalable, and grounded in operational realities.

Until then, Canada's approach to EV battery EOL management remains a work in progress.

Footnotes

1. Alexandra Mae Jones, "Canada had big EV battery recycling plans, but without regulations it's the 'Wild West,' expert warns" (1 June 2025, last updated 16 June 2025), CBC News (online).

2. Canadian Vehicle Manufacturers' Association & Call2Recycle Canada, Electric Vehicle Battery Management at End-of-Vehicle Life: A Primer for Canada (2022) at 6, 22-24.

3. Transportation of Dangerous Goods Regulations, SOR/2001-286.

4. Cross-border Movement of Hazardous Waste and Hazardous Recyclable Material Regulations, SOR/2021-25.

5. British Columbia Ministry of Environment and Climate Change Strategy, Extended Producer Responsibility Five-Year Action Plan 2021-2026 (Victoria: Ministry of Environment and Climate Change Strategy, 2021) at 4 (outlining the phased inclusion and recovery rate requirement); Gowling WLG, "Canadian product stewardship and EPR 2025 summer update" (28 July 2025), online: Gowling WLG (confirming the policy timeline has since been paused).

6. The initial proposal, often criticized for discouraging battery longevity, was published by Quebec's Ministère de l'Environnement et de la Lutte contre les changements climatiques (MELCC) in 2021 (See e.g., Electric Mobility Canada, "Extended Producer Responsibility regulation proposal by the government of Québec). (Recommendations, 2 November 2021), online: EMC (criticizing the 10-year lifespan assumption and recovery mandate)). The current program that replaced it was officially launched in June 2023.

7. Call2Recycle Canada, Inc., "National Expansion of the Innovative Industry-led Electrified Vehicle (EV) Battery Recovery Program" (Press Release, 26 June 2025), online: Call2Recycle Canada; EV Battery Recovery TM, "Program Details" (2025), online: EV Battery Recovery.

8. Call2Recycle Canada, "National Expansion" (2025).; EV Battery Recovery TM, "Program Details" (2025).

9. International Energy Agency. The Role of Critical Minerals in Clean Energy Transitions. World Energy Outlook Special Report, May 2021. The IEA repeatedly emphasizes that long-term policy signals are necessary to de-risk investment in recycling infrastructure.

10. For a detailed discussion of international developments, see Gowling WLG's article "Global traceability: Unpacking a rapidly evolving part of the Canadian battery system."

Read the original article on GowlingWLG.com

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