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Mexico City
Posted on : Feb 12, 2013

The Commission for Environmental Cooperation (CEC) has published a report which has recommended a number of measures to ensure that spent lead acid batteries (SLABs) exported from the U.S. to Mexico are recycled in an environmentally sound fashion.

The CEC said that the independent report, written under the authority of North American Agreement on Environmental Cooperation (NAAEC) Article 13, was initiated in 2012 in response to concerns that a surge in SLAB exports to Mexico was an effort to avoid the costs of stricter U.S. environmental and health protection laws.

The report found that between 2004 and 2011, U.S. net exports of SLABs to Mexico increased by 449% and 525%, and by 221% to Canada, and that the regulatory frameworks covering secondary lead smelters in the three countries do not provide equivalent levels of environmental and health protection.

Co-operation and tracking

All three countries are members of the Organisation for Economic Co­operation and Development (OECD). However, the U.S. does not follow OECD decisions that require the use of manifests to accompany hazardous waste shipments, including SLABs, and that require facilities recycling waste to provide notice of receipt of waste and issue a 'certificate of recovery' upon completion of recycling.

Instead the U.S. operates a notice and consent system via bilateral agreements with Canada and Mexico which addresses the trade in hazardous waste, including SLABs. In 2012 the environmental agencies of the three countries began to electronically share these consent documents.

One of the reports key recommendations was that the U.S. should require the use of manifests for each international shipment of spent lead acid batteries (SLABs), and it should require exporters to obtain a certificate of recovery from the recycling facility.

“The CEC’s scathing report indicts the battery export industry and singles out American and Mexican regulators as unwitting accomplices for failing to control the movement of hazardous battery waste,” commented Diane L. Cullo, director at SLAB Watchdog – an NGO dedicated to eliminating the environmental danger and community health issues caused by the foreign recycling of SLABs.

Raising the bar

According to the report although certain new smelters in Mexico have features and management practices common to high performing facilities, few smelters appear to have the types of controls, processes and technologies necessary to receive a permit in the U.S. or Canada today.

The report found that while environmental regulations are in place in Mexico, the country lacks the adequate regulations on lead emissions from stacks and stormwater discharges, and has not finalised regulations that would address outstanding hazardous waste management plans in the industry.

However, Evan Lloyd, executive director, CEC Secretariat said: "Moving forward, we respectfully submit that, to the extent that we raise the bar across North America to equivalent levels of environmental and health protection, we can, in this instance, avoid development that may seek to exploit lower environmental standards."

"To the contrary, with continent-wide high standards and enforcement, trade and economic development can play an important role in protecting human health and the environment in North America," he added.


The report made six key recommendations:

  • Raise the Bar - The appropriate government entities in Canada and Mexico should commit to achieving levels of environmental and health protections in the secondary lead industry functionally equivalent to those in the U.S.

  • Improve Trade Compliance - Efforts in Canada, Mexico and the U.S. should streamline and improve the flow of notice and consent information and the tracking of SLABs

  • Close Information and Performance Gaps - Mexico should establish a regulatory framework that covers the entire industry and provides public health and environmental protections equivalent to those in the U.S.

  • Ensure Accurate and Comparable Information on Lead Emissions - Performance and emissions data should be collected and made publically available

  • Support Best Practices - The governments of Canada, Mexico and the U.S. should work together with the North American secondary lead smelting industry to develop strategies to support the adoption of best practices throughout the region

  • Foster Regional Cooperation and Technical Assistance - The North American governments through the CEC or other appropriate venues.

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