CEC Secretariat releases final independent report investigating environmental and health 

hazards of spent lead-acid battery trade in North America

Report recommends specific policy actions to North American governments on how to handle this 

common and potentially hazardous waste. Visit www.cec.org/slabs. 

Montreal, 15 April 2013—On Monday, the Commission for Environmental Cooperation Secretariat 

released its final independent report: Hazardous Trade? An Examination of US-generated Spent Leadacid Battery Exports and Secondary Lead Recycling in Mexico, the United States and Canada. The 

report analyzes the reported cross-border trade in lead-acid batteries and presents recommendations on 

how to better monitor their handling to the CEC Council, composed of Canada’s Environment Minister, 

Mexico's Secretary of the Environment, and the US Environmental Protection Agency Administrator. 

To download the report, visit www.cec.org/slabs.

Spent lead-acid batteries (SLABs) from cars and trucks are one of the world’s most-recycled consumer 

products because the lead they contain is valuable and can be processed for reuse. The CEC initiated 

this report in response to concerns that US companies were shipping batteries to Mexico and other 

countries to avoid the cost imposed by stricter environmental laws.

“If not handled properly, lead presents a grave health risk to workers and also to the young children and 

community members who live near smelting facilities. All of us who own a car ‘own’ this problem, and 

need to feel confident that the hazardous waste we bring in for recycling is being disposed of properly, 

no matter where it is sent for processing,” said Irasema Coronado, CEC executive director.

Findings include:

The regulatory frameworks covering secondary lead smelters in the United States, Canada and 

Mexico do not provide equivalent levels of environmental and health protection. Currently, the 

United States has the most stringent overall framework, while Mexico, with significant gaps in 

its existing regulatory framework, is the furthest from US standards in terms of certain emission 

controls and requirements. 

According to estimates, between 2004 and 2011, US net exports to Mexico increased by 

between 449 and 525 percent.

A review of USEPA and US Census Bureau data indicated that 47,352,382 kg of SLABs were 

exported to Mexico in 2011 without applying the proper harmonized tariff code.

Recommendations include:

The governments in Canada and Mexico should commit to achieving levels of environmental 

and health protections in the secondary lead industry that are functionally equivalent to those in 

the US.

The US should require the use of manifests for each international shipment of SLABs, and 

require exporters to obtain a certificate of recovery from recycling facilities.

Mexico needs to establish a comprehensive monitoring system to measure lead air emissions 

from every secondary lead smelter in operation in the country.

The report draws on statistics detailing the legal trade in SLABs from Environment Canada, the US 

Environmental Protection Agency, US Census Bureau, and the Mexican government. 
In reaction to the report’s development, Mexico’s environmental enforcement agency Profepa ramped 

up investigations and operations. The implementation of a special program to target this issue has led to 

the inspection of 20 facilities and more than 256 tons of SLABs seized in different enforcement actions 

across the country. 

“Mexico is already taking action, which bodes well for this issue in the future, and the CEC will 

continue to support Mexico in its efforts. The handling of SLABs presents an opportunity for North 

American environmental agencies to cooperate and raise the bar on enforcement and compliance,” said 

Irasema Coronado. 

Article 13 of the North American Agreement on Environmental Cooperation (NAAEC) states that the 

CEC Secretariat may prepare independent reports for the CEC Council. Hazardous Trade? An 

Examination of US-generated Spent Lead-acid Battery Exports and Secondary Lead Recycling in 

Mexico, the United States and Canada was released in draft form in December 2012 and posted to the 

CEC website for public comments. 

The CEC received several comments from industry, NGOs and government (available on the CEC 

website) and, on 5 February 2013, the Secretariat resubmitted a final version to the CEC Council. 

According to procedure in Article 13, the Council then normally has 60 days to vote on whether to 

make the report publicly available.

About the CEC

The Commission for Environmental Cooperation (CEC) is an intergovernmental organization that 

supports the cooperative environmental agenda of Canada, Mexico and the United States to green 

North America’s economy, address climate change by promoting a low-carbon economy, and protect its 

environment and the health of its citizens. The CEC is composed of three bodies: a Council, 

representing the governments of the three member countries, a Joint Public Advisory Committee 

(JPAC) that advises the Council and serves as a liaison with the public, and a Secretariat that supports 

the Council and JPAC and prepares independent reports. The CEC brings together governments, civil 

society, and businesses to develop innovative North American solutions to global environmental 

challenges. Find out more at: www.cec.org.

CEC initiatives are undertaken with the financial support of the Government of Canada, through the 

Federal Department of Environment, the Government of the United States of America, through the 

Environmental Protection Agency, and the Government of the United States of Mexico, through 

the Secretaría de Medio Ambiente y Recursos Naturales.