EPR for EV batteries feasible in Quebec

MONTREAL – A new study suggests that existing Extended Producer Responsibility (EPR) systems in Quebec could be adapted for EV batteries.

With estimates suggesting 70 percent of vehicles in North America will be electric by 2050, there is a potential for significant impact on the value chain in the transportation electrification industry, including for EV battery management.

The study, “Extended Producer Responsibility for Electric Vehicle Lithium-Ion Batteries in Quebec“, was prepared by EY for Propulsion Québec. It identifies the main hurdles to and advantages of implementing EPR in the province.

A solution for recycling end-of-life batteries

The study indicates that EPR is already in use in Quebec for other products and could work for EV batteries, provided the mechanism is sufficiently flexible.

It found that the current legal framework in North America does not present a challenge for implementing EPR as a mechanism for recycling lithium-ion batteries. In fact, it would complement other regulations, including those governing recycling of end-of-life vehicles, cells, and batteries and transportation of hazardous materials.

EPR would address challenges faced by key market players, especially in terms of ensuring safe and environmentally friendly end-of-life battery management.

The study suggests that Quebec could position itself as a North American leader in EV battery EPR. Deploying EPR for EV batteries would consolidate the province’s extensive expertise in transportation electrification and position it as a leader in North America.

“In our view, Quebec has the leadership needed to plan the collection and management of end-of-life EV batteries and EPR has emerged as a viable solution for current and future challenges,” said Sarah Houde, CEO of Propulsion Québec.

“Now is the time to start developing concrete solutions for end-of-life EV battery management.”

According to the study’s initial financial estimates, the costs of EPR would not put the brakes on the EV market. Contrary to popular belief, EPR is not the source of the recycling costs that are inherent in a battery’s life cycle.

Analysis of regulations, issues raised by stakeholders, private and public practices in other jurisdictions, and the scenario under consideration shows that EPR would meet current and future challenges.

“This study identifies the key issues at play and outlines potential deployment scenarios based on input from key market players in the research and analysis phase,” Houde said.

Propulsion Québec’s recommendations

Should the Quebec government move forward with regulatory changes to end-of-life EV battery management, the study suggests the following:

  1. Consult relevant stakeholders to establish the main parameters for EPR, including realistic targets, the dynamics in different markets, and intellectual property protection issues.
  2. Distinguish between the various types and chemical compositions of end-of-life batteries as these may affect EPR parameters and collection and processing logistics.
  3. Gradually implement EPR within a realistic timeframe and harmonize it as much as possible with other jurisdictions in North America that are considering similar mechanisms. Quebec is well positioned to become a North American leader and has the potential to exert a positive influence on other jurisdictions. In order to do so, it will need to leverage existing consultation mechanisms, especially in northeastern North America.
  4. Establish a flexible regulatory framework that can be reviewed periodically to ensure it’s in step with the availability of end-of-life EV batteries and the technical and financial viability of automakers and recyclers.
  5. Carry out a rigorous, in-depth quantitative analysis to better estimate EPR costs and their effects on transportation electrification, since the quantitative analysis carried out by EY must be interpreted with caution due to a lack of reliable data for Quebec and the use of assumptions based on the European market.

This study received financial support from Ministère de l’Énergie et des Ressources naturelles, Ministère de l’Environnement et de la Lutte contre les Changements Climatiques, RECYC-QUÉBEC, Call2Recycle Canada, the Association of Auto Parts Recyclers, Hydro-Québec, Lithion Recycling, Nemaska Lithium, Nouveau Monde Graphite, and Mason Graphite.