Ontario Battery Regulation
From Complexity to Clarity — Simplified.Measured.Harmonized.
O. Reg. 556/24 (effective January 1, 2025) extends targets and adds audit burden without improving outcomes. BC's approved-program model under B.C. Reg. 449/2004 shows what's possible — higher collection rates, lower costs, national harmonization.
batteries collected since inception
collection locations nationwide
of Canadians within 15 km
Ontario's Battery Amendments: More Complexity, No Better Outcomes
Ontario's O. Reg. 30/20 established a workable battery stewardship framework. But O. Reg. 556/24 — enacted January 1, 2025 — extends the 50% management target to 2030 and adds new audit and reporting requirements on producer responsibility organizations (PROs) without addressing the root cause: collection infrastructure gaps in rural and underserved communities.
These amendments increase compliance costs for producers and PROs, add auditing obligations that consume resources better spent on actual recycling, and create regulatory complexity not seen in other provinces. British Columbia, operating under B.C. Reg. 449/2004, achieves comparable collection rates with a simpler approved-program model that places accountability at the program level — not buried in audit process.
The question for the Ministry is not whether to regulate — it is whether this regulatory design delivers the best outcomes per dollar of compliance burden. The evidence points clearly toward harmonizing with BC's approach.
BC already has the model Ontario needs.
Regulatory Timeline
O. Reg. 30/20 (Batteries)
Ontario establishes battery stewardship under the Resource Recovery and Circular Economy Act, 2016. PRO model with 50% management targets.
O. Reg. 556/24 — Enacted
Amendments add new audit requirements, extend 50% target to 2030, increase PRO reporting burden — without new collection infrastructure investment.
B.C. Reg. 449/2004
BC's Recycling Regulation approved-program model. Call2Recycle BC Program Plan 2025-2029 delivers results at lower administrative cost.
EU Battery Regulation 2023/1542
EU framework in force. Clear producer responsibility tiers, proportionate compliance requirements, harmonized across 27 member states.
BC Has Already Solved This
Call2Recycle's BC Program Plan 2025-2029 demonstrates what an evidence-based, outcomes-focused battery stewardship program looks like. Ontario producers, municipalities, and taxpayers deserve the same.
Who Bears the Cost of O. Reg. 556/24
Battery Producers
Pain
New PRO registration and reporting obligations under O. Reg. 556/24 add direct compliance costs passed to consumers.
Solution
BC's approved-program model requires program-level accountability — simpler, lower-cost, same outcomes.
Value
Reduce per-unit compliance overhead. Redirect investment toward actual collection infrastructure.
Producer responsibility
Retailers & Distributors
Pain
Compliance obligations flow downstream — retailers face reporting requirements and collection obligations.
Solution
Simplified PRO framework reduces downstream burden without reducing collection network.
Value
Fewer compliance touchpoints. Clear obligations. No surprises from regulatory churn.
Supply chain compliance
Municipalities
Pain
Municipalities absorb infrastructure costs for battery collection while PRO audit requirements consume shared program funds.
Solution
BC model routes funding directly to collection infrastructure, not administration.
Value
Higher net investment in collection sites per dollar of compliance spend.
Municipal services
Producer Responsibility Organizations
Pain
Call2Recycle and other PROs face increased audit burden under O. Reg. 556/24 — resources diverted from program delivery.
Solution
Program-plan-based accountability (BC model) focuses on outcomes, not process audits.
Value
Free up operational capacity. Run better programs. Demonstrate outcomes, not paperwork.
PRO operations
Consumers & Taxpayers
Pain
All compliance costs flow through to consumers via product pricing and municipal tax bases.
Solution
Simpler regulation means lower per-unit cost of compliance — savings that stay in the system.
Value
Lower battery prices. Better-funded collection networks. Taxpayer money on recycling, not audits.
Public benefit
Certified Recyclers
Pain
Regulatory uncertainty from ongoing amendments disrupts long-term capacity investment decisions.
Solution
Stable, BC-style framework gives recyclers the certainty to invest in processing infrastructure.
Value
Investment certainty. Longer planning horizons. Reliable volume commitments.
Materials recovery
The Environment
Pain
When compliance burden crowds out actual recycling investment, collection rates stagnate — and batteries end up in landfill.
Solution
Every dollar redirected from audit overhead to collection infrastructure improves diversion rates.
Value
More batteries recycled per dollar of program spend. Better outcomes for air, water, and soil.
Environmental stewardship
The Regulatory Comparison
O. Reg. 30/20
Original framework established workable PRO model. 50% management target, clear collection obligations, reasonable reporting structure.
O. Reg. 556/24 Burden
New audit requirements, extended 50% target to 2030, increased PRO reporting. No new collection infrastructure investment. Compliance cost increase with no collection rate improvement mechanism.
B.C. Reg. 449/2004
Approved-program model places accountability at program level. Call2Recycle BC Program Plan 2025-2029 demonstrates outcomes-based stewardship: streamlined approval, lower admin overhead, comparable or better collection rates.
Adopt BC-Equivalent Approach
Harmonize Ontario's framework with BC's approved-program model. Reduce audit burden. Redirect compliance spending to collection infrastructure. Enable national program harmonization for multi-province producers.
International Benchmarks
British Columbia
Approved-Program Model
B.C. Reg. 449/2004 approved-program framework. Call2Recycle BC Program Plan 2025-2029 — outcomes-based, lower administrative overhead, national benchmark.
European Union
EU Battery Regulation 2023/1542
In force February 18, 2024. Clear producer responsibility tiers, proportionate compliance requirements. Harmonized across 27 member states — simpler for multi-jurisdiction producers.
Germany
Batteriegesetz (BattG)
Germany's Batteriegesetz framework achieves high collection rates through clear producer obligations and streamlined registration. Minimal audit overhead relative to outcomes.
United States
State-by-State EPR Lessons
US patchwork of state EPR programs demonstrates the cost of regulatory fragmentation. Multi-province producers in Canada face the same compounding complexity when provinces diverge.
Call2Recycle Canada: 60M+ kg collected, 400+ members, 15,000+ locations
Three Reasons to Adopt the BC Approach
Ontario's battery stewardship goals are sound. The mechanism — not the goal — is where O. Reg. 556/24 falls short. BC's model achieves the same objectives with less friction.
Taxpayer Value
Compliance overhead under O. Reg. 556/24 consumes funds that should flow to collection infrastructure. BC's program-plan model redirects resources to outcomes.
Environmental Outcomes
Collection rates improve when programs are well-funded and access points are abundant — not when PROs spend more time on audits. Simpler regulation means more recycling per dollar.
National Harmonization
Producers operating across multiple provinces face compounding compliance costs when frameworks diverge. Aligning Ontario with BC reduces per-unit burden and enables national program efficiency.
Cost Comparison
Ontario O. Reg. 556/24 Costs
BC Approved-Program Savings
Potential: significant per-producer cost reduction
Stacking strategy
100% redirectable to collection infrastructure
Maximum eligible assistance
Adopt an Approach That Works
Ontario's battery stewardship goals are achievable with less complexity and lower cost. Aligning with BC's approved-program model delivers better outcomes for producers, municipalities, taxpayers, and the environment — and positions Ontario for national harmonization.