Ontario Auto Recyclers Association
Environmental regulations for auto recyclers in Ontario — plain-language guidance based on Ontario Regulation 85/16 under the Environmental Protection Act.
The auto recycling industry plays a critical role in Ontario's circular economy. This guide summarizes the environmental compliance obligations that apply to end-of-life vehicle (ELV) waste disposal sites under O. Reg. 85/16, O. Reg. 86/16 (amending Reg. 347), and related legislation. It is intended for informational purposes — always refer to the official legislation for exact legal language.
Auto recycling in Ontario is a sophisticated, technology-driven industry. The modern recycler must realize maximum market value from every vehicle taken in while meeting the province's environmental protection requirements. As of September 30, 2016, all eligible ELV waste disposal sites are regulated under O. Reg. 85/16 and must register through the Environmental Activity and Sector Registry (EASR).
A motor vehicle or motor vehicle hulk that has been abandoned, or is being managed for recycling, reuse (other than as an operable vehicle), or disposal. ELV has replaced the former term "derelict motor vehicle."
Any location where ELVs are managed — including collecting, handling, transporting, storing, processing and disposing. If your site stores ELVs beyond 180 days or performs more than simple transfer, you likely need to register.
The MECP administers O. Reg. 85/16 and oversees the EASR. Provincial officers may inspect sites and request records at any time.
Most Ontario ELV sites must register through the Environmental Activity and Sector Registry (EASR), an online self-registration system that replaces the more complex Environmental Compliance Approval (ECA) process for eligible sites.
Do you store ELVs for more than 180 days, or do more than collect, handle, transport, store and transfer vehicles?
Do you receive more than 2 ELVs per year, or store more than 10 at any one time?
Confirm no prohibited wastes (biomedical, PCB, radioactive) are managed on the property, and no waste is disposed of without an ECA.
If waste criteria are met → register in EASR. If not → apply for an Environmental Compliance Approval.
| Equipment Type | EASR Eligible If… | Notes |
|---|---|---|
| Metal Shredder | Not Eligible | Shredders cannot be registered in EASR — an ECA is required. This does not affect waste activity registration. |
| Heat Cutting Equipment | Metal being cut is ≤ 250 mm thick | If metal exceeds 250 mm, air activities cannot be registered in EASR. |
| Crusher / Shearer | One of three conditions met (see below) | Option A: >250 m from nearest noise receptor. Option B: Acoustic barrier (≥20 kg/m²) breaks line of sight. Option C: Operated ≤50 days per calendar year. |
Before any ELV may be sheared, crushed, or shredded, the following materials must be removed. These requirements have been in force since September 30, 2017.
| Material to Remove | Special Handling | Max Storage Time |
|---|---|---|
| Batteries | Store covered to prevent precipitation contact and short-circuiting | 24 months |
| Battery Cable Connectors (lead) | Sealed, labelled container stored above ground | |
| Electrical Switches (mercury) | Sealed, labelled container; closed when not in active use | |
| All Fluids | Must be removed on an impermeable surface under a covered structure; stored in sealed, labelled containers above ground | |
| Tires | See tire storage limits (below) | |
| Tire Weights (lead) | Sealed, labelled container stored above ground | |
| Asbestos Waste (from vehicle) | Handle per O. Reg. 490/09, O. Reg. 278/05, and OHSA requirements | — |
| Refrigerants / Halocarbons | Removal by certified person per O. Reg. 463/10; affixed notice required | — |
Unless an ECA provides otherwise: fewer than 5,000 tire units on site, and total pile volume must not exceed 300 cubic metres.
Engines, transmissions, radiators, and other "wet components" must be stored on an impermeable pad and protected from precipitation — either under cover or in suitable sealed containers.
Once all Table 1 materials have been removed from an ELV, a certificate must be issued. It must include your EASR number (or ECA number), contact info, and a signed declaration that items have been removed. Retain for 2 years.
| Requirement | Details | Status |
|---|---|---|
| Crushing/Shearing Hours | All equipment used to shear or crush waste may only operate between 7:00 a.m. and 7:00 p.m. | Required |
| Site Attendant | Access to the site is only permitted when a trained attendant is on duty | Required |
| Equipment Maintenance | All shearing, crushing, and fluid-removal equipment must be operated and maintained per manufacturer recommendations | Required |
| Spill Containment | Fluid removal must occur on an impermeable surface with a spill containment system, under a covered structure. Shearing/crushing equipment must either be in an area with a spill containment system, or the equipment itself must have one. | Required |
| Spill Prevention Plan | A written spill prevention and management plan must be developed and implemented, covering: clean-up procedures, drain locations, materials for sealing drains, notification contacts, and inspection schedule | Required |
| Employee Training | All employees and contractors who handle ELV materials must be trained on: relevant legislation, environmental and occupational health concerns, safe equipment use, emergency procedures, and spill response | Required |
| Weekly Inspections | Storage areas and containers must be inspected for spills and leaks at least once per week by a trained person | Required |
| Complaint Notification | If a complaint about the site relates to the natural environment, the MECP district manager must be notified within 2 business days | Triggered |
| Air Emissions Program | Sites with registered air activities must implement programs to minimize visible emissions and dust beyond the property boundary; metal cutting must not produce visible off-site air emissions | Required |
| Hazardous Waste Registration | If your site generates hazardous or liquid industrial waste, you must register through the RPRA Hazardous Waste Program Registry | Required |
All records must be retained for a minimum of 2 years and made available for inspection by a provincial officer upon request.
| Record Type | What Must Be Captured |
|---|---|
| Equipment Inspections, Maintenance & Repairs | Date; summary including deficiencies identified; name of person performing inspection; employer name if external contractor. Plus: copies of all related documents. |
| Storage Area & Container Inspections | Date; summary of inspection and any unsatisfactory conditions observed; corrective steps taken; inspector's name and employer (if external). Plus: copies of related documents. |
| Environmental Complaints | Date and time received; copy of written complaint or written summary; description of measures taken to address the complaint. |
| Employee Training | Name of every trained person; date(s) of training or refresher; copies of all training materials used. |
| Spills from Containers or Containment Systems | Date, time, location, duration; identity and quantity of pollutant; cause and circumstances; containment and clean-up details; success assessment; adverse effects observed; disposal site of affected material. |
| Vehicle Identification (VIN) Log | Manufacturer Vehicle Identification Number (VIN) for every ELV managed at the site. |
| Crushing & Shredding Log | Dates and times of all shearing, crushing and shredding activities at the site. |
No — O. Reg. 85/16 does not apply to sites where the only activity is removing parts for reuse and the collection, handling, transportation, storage and transfer of ELVs, provided the site never has more than 10 ELVs on site at any one time and does not receive more than 2 ELVs per year. If those thresholds are met, neither EASR registration nor an ECA is required.
Not necessarily. If the only activity at your site is the collection, handling, transportation, storage and transfer of ELVs (no processing or dismantling), and no ELV is stored for more than 180 days, you are not required to register in the EASR.
However, if any vehicle stays beyond 180 days — or if you remove parts for other than reuse — you must assess whether EASR registration applies.
Only asbestos-containing components removed from an ELV on your site may be managed at an ELV waste disposal site. For example, aftermarket asbestos brake pads found in an ELV must be removed before any crushing, shearing, or shredding, and managed per the Environmental Protection Act, the Occupational Health and Safety Act, and related regulations (O. Reg. 490/09, O. Reg. 278/05, Regulation 833).
You cannot accept asbestos waste that was generated off-site — that would disqualify your site from EASR eligibility.
You have three options to meet the air criteria for a crusher or shearer:
Option A: The equipment is more than 250 metres from the property boundary of the nearest noise receptor (measured horizontally, from edge of equipment to edge of receptor's property line).
Option B: Install an acoustic barrier that breaks the line of sight between the equipment and the receptor, with a density of at least 20 kg/m². The barrier must be structurally sound, free of gaps, and capable of withstanding wind and snow load.
Option C: Operate the crusher or shearer for 50 days per calendar year or fewer.
If none of these can be met, you will need an ECA for air activities (your waste activities can still be registered in EASR).
Once your site's prescribed activities are registered, you are generally exempt from re-registering for changes or modifications to the site or equipment — as long as the site continues to meet all requirements of O. Reg. 85/16. However, you must update your EASR registration information within 30 days of any change to the registration information itself.
If changes would cause the site to no longer meet the waste or air criteria, the activities may need an ECA instead.
If a complaint relates to the natural environment, you must notify the MECP district manager of the incident and the events leading up to it within 2 business days of receiving the complaint. You must also record the date and time of the complaint, a copy or summary of the complaint, and the measures taken to address it — and retain that record for 2 years.
Yes, if your site generates subject waste (hazardous or liquid industrial waste), you must register separately through the Resource Productivity and Recovery Authority (RPRA) Hazardous Waste Program Registry. The EASR registration does not cover hazardous waste generator obligations. The MECP provides a "Registration Guidance Manual for Generators of Liquid Industrial and Hazardous Waste" to help you determine your waste types.