A National Approach to the Environmental Management of End-of-life Vehicles in Canada

The Automotive Recyclers of Canada is the national voice of the vehicle recycling industry representing, through its provincial affiliates, approximately 400 end-of-live vehicle (ELV) recyclers and dismantlers throughout Canada.

ELV processing represents one of the largest recycling sectors in Canada with about 1.2 million retired recycled each year. With a 94% ELV recovery and return rate, ELV waste diversion rates are higher than those for most provincial waste diversion programs. While ELV processors are subject to a number of provincial and federal requirements, ELV management practices are highly variable. The practice of processing ELVs throughout the country is not subject to consistent or comprehensive regulated standards. The lack of common processing standards for ELVs is significant. While used parts and scrap metal values are driving high recycling rates, ELVs also include a number of substances of concerns that incur costs when properly removed. It is common for many ELVs processors to reduce costs by ignoring environmental standards with respect to these materials. This creates an uneven playing field in the sector. While a number of vehicle recyclers operate to high environmental standards, with attendant high rates of reuse, recycling and minimal environmental discharges, the majority operate to no standard at all.

Increasingly this sector is becoming subject to a number of government waste management requirements. Different provincial and federal waste management initiatives create obligations with respect to how vehicles and vehicle components are managed. British Columbia has a requirement for ELV processors to establish waste management plans. Ontario has discussed designating ELVs for waste diversion in its mid-term plans. Quebec is expanding its extended producer responsibility (EPR) programs and will likely consider adding ELVs. The federal government has proposed implementing EPR rules related to the management of ozone depleting substances (ODS) including how those substances in vehicles are managed.

To date government initiatives to address vehicle components through waste diversion programs have not effectively addressed the serious environmental problems associated with ELV processing. The creation of EPR type waste management obligations with respect to ELVs, in the absence of a common and enforceable environmental standard for ELV processing, is likely to be counterproductive.

With respect to vehicle manufacturers, a national sector is threatened with a patchwork of various waste management requirements and obligations that are unlikely to generate actual improvements in ELV recycling. With respect to automotive recyclers, responsible businesses may be burdened with additional obligations, while their competitors continue to operate outside of provincial and federal waste management programs.

For the above reasons, the Automotive Recyclers of Canada (ARC) believes that it is timely to consider a national standard with respect to ELV processing. One of the core objectives of such an approach is to implement and enforce a common environmental processing standard for ELVs. This would address the single most significant problem associated with ELV recycling in Canada today. In Ontario, where the base of Canada's automotive manufacturing sector operates, the Ontario Automotive Recyclers Association (OARA), an ARC affiliate, has been working in collaboration with the Canadian Vehicle Manufacturer’s Association (CVMA) to create a licensing regime for vehicle recyclers in Ontario. The CVMA and ARC believe that the core elements of that proposal represent objectives that are readily achievable throughout Canada.

These include:

1) Codifying the National Code of Practice for Automotive Recyclers developed under the National Vehicle Scrappage Program (“Retire your Ride”) in provincially set regulation;
2) Licensing or registering businesses engaged in ELV processing to ensure sector-wide compliance with that common environmental processing standard; and
3) Auditing and monitoring processors and reporting annually on ELV recycling activity;

While the cross jurisdictional nature of environmental policy raises issues related to a national conception of ELV processing, both the ARC and CVMA believe that coordinating government policy in this area is an essential component to enhancing vehicle manufacturing competitiveness and generating positive environmental outcomes with respect to ELV waste management.

To download the discussion paper - A National Approach to the Environmental Management of End-of-life Vehicles in Canada