Statement from the Registrar: Fourth update on the inspection of battery producer compliance under the Batteries Regulation

RPRA’s inspection of the Used Battery Collection System operated by Call2Recycle, a producer responsibility organization (PRO) operating a battery collection and recycling system in Ontario on behalf of their producer clients, has determined that producers can currently rely on Call2Recycle’s collection system to meet their regulatory requirements to establish and operate a public collection system under O. Reg. 30/20 (Batteries Regulation) issued under the Resource Recovery and Circular Economy Act, 2016 (RRCEA).

The inspection was announced on April 14, 2022, following a significant reduction in the number of used battery collection sites as a result of a contractual dispute between Call2Recycle and Raw Materials Company Inc., an Ontario-based battery processor that also operates a battery collection system.

The initial results of the inspection, which were announced on September 9, 2022, found the Used Battery Collection System operated by Call2Recycle on behalf of their producer clients was out of compliance. A notice of compliance requirement was issued to all battery producers using Call2Recycle as their registered PRO requiring immediate action to comply with the Batteries Regulation.

Subsequently, RPRA’s Compliance and Enforcement Team reviewed Call2Recycle’s amended list of collection sites, including confirming individual site locations and site compliance through random sampling, and is satisfied that Call2Recycle’s collection system currently meets the Collection Site Accessibility requirement. Additionally, RPRA’s Compliance and Enforcement Team examined the action plans submitted by Call2Recycle related to the ongoing compliance of the collection system and noted quality assurance controls that enable the operation of the system as required.

RPRA’s Compliance and Enforcement Team will continue to monitor all collection systems for compliance with the requirements outlined in Part III (Collection of Batteries) of the Batteries Regulation.

In addition to the inspection of the Used Battery Collection System, RPRA’s Compliance and Enforcement Team is in the process of inspecting battery producers’ compliance with Part IV (Management of Batteries) of the Batteries Regulation as outlined in the October 27, 2022, notice of compliance requirement. The outcome of this inspection will be shared when the inspection is concluded.

In the interim, producers, or PROs on their behalf, can rely on the following battery processors registered with RPRA to meet their management requirements in 2023:

  1. Canadian New Energy Materials Corporation
  2. Evergreen Battery Recycling, LLC
  3. Li-Cycle Corp.
  4. Laurentide Re-Sources Inc.
  5. Raw Materials Company Inc.
  6. Retriev Technologies Ltd.

This list is subject to change. The current list can be found here on RPRA’s website.