Secretariat of the Commission for Environmental Cooperation

Hazardous

Trade? An Examination of US-generated 

Spent Lead-acid Battery Exports 

and Secondary Lead Recycling in 

Canada, Mexico, and the United States 
Disclaimer

This independent report was prepared by the CEC Secretariat of the 

Commission for Environmental Cooperation (CEC) pursuant to Article 13 of 

the North American Agreement on Environmental Cooperation (NAAEC). 

The content and recommendations of this report do not necessarily reflect 

the opinions of the CEC or the governments of Canada, Mexico, or the 

United States of America.

Reproduction of this document in whole or in part and in any form 

for educational or non-profit purposes may be made without special 

permission from the CEC Secretariat, provided acknowledgment of 

the source is made. 

Except where otherwise noted, this work is protected under a Creative 

Commons Attribution-Noncommercial-No Derivative Works License.

Commission for Environmental Cooperation, 2013

Publication Details

Publication type: Independent Secretariat Report (Article 13)

Publication date: April 2013

Original language: English

ISBN 978-2-89700-024-0 (print), 978-2-89700-025-7 (electronic)

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978-2-89700-027-1 (versión electrónica)

Disponible en français: 978-2-89700-028-8 (version imprimée), 

978-2-89700-029-5 (version électronique) 

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Legal deposit—Library and Archives Canada, 2013

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info@cec.org / www.cec.org
 Hazardous Trade? i

Commission for Environmental Cooperation

Comisión para la Cooperación Ambiental

Commission de Coopération Environnementale

Hazardous

Trade? An Examination of US-generated 

Spent Lead-acid Battery Exports 

and Secondary Lead Recycling in 

Canada, Mexico, and the United States

azardous 

Trade?

Introduction 1

Lead-Acid Batteries and the Recycling 

of SLABs 2

The SLAB Recycling Industry in 1 North America 5

Table of Contents

The North American Trade in SLABs 21

Trade Data 21

What Is Driving US Exports to Mexico? 28 3

Preface v

Acknowledgments vii

Executive Summary ix

International Framework for 

Managing the Trade in SLABs 17

International Agreements 17

Import and Export Controls 18

Transporting SLABs 18

Improving the North American 

Framework for Managing 

the Trade in SLABs 19

2

Pollution Control and Occupational 

Standards across North America 31

Facility Permitting 32

Air Standards 32

Other Pollution and 

Management Standards 35

Occupational Health and Safety 36

The Environmental Disincentives 

of Lower Standards 37

4

Environmental Performance of the 

Secondary Lead Smelting Industry 39

Impacts of SLAB Recycling on People 

Living Near Smelters 39

Examples of Lead Poisoning 

and Pollution 40

Evaluating Lead Air Emissions 41

Analyzing Pollution Release Information 

Across North America 44

Observing Pollution Control Features 45

5

Key Findings and Recommendations 47

Key Findings 47

Recommendations 50 6
Appendix 1. 

Inspection and Oversight of the Transboundary 

Movement of Spent Lead-acid Batteries in Mexico 52

Appendix 2. 

Sources of US SLAB Export Data 62

Appendix 3. 

Status and Membership of Mexico’s Secondary Lead

Recyclers in the Programa Nacional de Auditoría 

Ambintal (Industria Limpia) 64

List of Tables

Table 1-1. Spent Lead-acid Battery Processing 

Facilities in North America, including 

Pollution Release Information as 

Reported for 2007–2010 7

Table 3-1. Facilities in Mexico Receiving Spent 

Lead-acid Batteries from the United States 

in 2011 25

Table 3-2. Facilities in Canada Receiving Spent 

Lead-acid Batteries from the United States 

in 2011 27

Table 4-1. Overview of Standards Mandated for 

Secondary Lead Smelters: United States, 

Mexico and Canada (Ontario and Quebec) 31

Table 4-2. Select Lead Standards: United States, 

Mexico and Canada (Ontario and Quebec) 32

Table of Contents

List of Figures

Map 1-1a. Facilities Processing Spent Lead-acid 

Batteries (SLABs) in Canada and the 

United States 11

Map 1-1b. Facilities Processing Spent Lead-acid 

Batteries (SLABs) in Mexico 12

Figure 3-1. US Exports of SLABs to Canada, Mexico 

and All Other Destinations, 2002–2011 22

Figure 3-2. Canada: Trade in SLABs to and from 

the United States, 2002–2011 22

Figure 3-3. US Exports of SLABs, by Destination, 

2011 (USEPA) 23

Figure 3-4. US Exports of SLABs, by Destination, 

2011 (US Census Bureau) 23

Map 3-1. North American Imports and Exports of 

Spent Lead-acid Batteries (SLABs), 2011 26

Figure 5-1. Estimated Annual Lead (Pb) Emissions at 

US Secondary Smelters for 2006–2010 42

Figure 5-2. Mean of Three-month Rolling Average 

Lead Concentrations near Secondary 

Lead Smelting Facilities, 2008–2010 43

Figure 5-3. Average Outlet Concentration, by 

Control Technology 43

Figure 5-4. SLAB Processing Facilities Reporting 

Air Emissions of Lead 

(and/or Its Compounds), 2010 44

Figure 5-5. Lead Air Emissions from Recycling 

Facilities Reporting to RETC (Mexico), 

NPRI (Canada), and TRI (US), 2010 45
 Hazardous Trade? v

The last seven years have seen a large increase in exports of spent lead-acid batteries 

(SLABs) from the United States to Mexico, where the lead in these batteries is recycled 

to produce refined lead for use in new batteries. Today, 30–60 percent of all batteries 

recycled in Mexico come from the United States. In Mexico, SLAB recycling occurs 

in a regulatory environment with less stringent controls on lead pollution and the 

protection of workers and public health than in the United States, and in which recycling facilities demonstrate a wide range of environmental practices, processes and 

control technologies.

This report is an independent assessment by the Secretariat of the Commission 

for Environmental Cooperation (CEC) on the environmental hazards associated with 

the increase in SLAB exports to Mexico, as well as the more general environmental 

management of the battery recycling sector in Mexico. It considers the implications of this trade relative to the environmental principles and provisions of both 

the North American Free Trade Agreement (NAFTA) and its affiliated North American 

Agreement on Environmental Cooperation (NAAEC). 

This report speaks to two such principles. The first principle—embodied in 

NAAEC, the agreement that established the CEC and that provides for such Secretariat 

reports—is that, in pursuit of continent-wide trade and investment as enabled by 

NAFTA, comparative advantage should not be sought on the basis of lower environmental standards or lax enforcement. In response to a general concern that NAFTA 

might trigger “downward harmonization” or a race to the bottom and the creation 

of so-called pollution havens, NAAEC set out ambitious goals to protect the environment and to enhance compliance with and the enforcement of environmental laws 

throughout the region, thereby obliging the governments of Canada, Mexico and the 

United States (the Parties to the CEC) to ensure that their laws and regulations provide 

for high levels of environmental protection. 

The second principle is that Canada, Mexico and the United States should 

cooperate in the protection and enhancement of North America’s environment. Thus 

NAAEC obliges the CEC Parties to cooperate on the continuing improvement of those 

laws and regulations and to develop greater comparability of environmental technical 

regulations and standards. 

In the spirit of NAAEC, our recommendations underline the opportunity for 

cooperation. Specifically, the Parties to NAAEC, the North American battery and 

secondary lead industry, and public stakeholders have an opportunity to continue 

to improve the relevant laws and regulations and their enforcement and to share the 

human health and positive environmental outcomes that come from ensuring that the 

highest possible standards apply to the handling and recycling of lead-acid batteries 

across all three countries. 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.

Evan Lloyd

CEC Executive Director, 2010–2012

Preface
vi
 Hazardous Trade? vii

This report was developed under the direction of Evan Lloyd, my predecessor as CEC 

Executive Director, and co-authored by Mr. Lloyd and Mr. Tim Whitehouse, president 

of the Cyan Environmental Group. In addition to their contribution, I would like to 

acknowledge the many individuals and organizations that contributed to the development of this report. The Secretariat especially appreciates the efforts of Guillermo 

Roman, an independent consultant at the Centro Interdisciplinario para Prevención 

de la Contaminación, A.C., who led the research efforts in Mexico for the report. Ana 

Teresa Alvarado, Wesley Engers and Tayyaba Waqar also assisted in the development 

of this report.

We are particularly grateful to the following companies for explaining to us the 

processes, control technologies and protocols used in their facilities, as well as issues 

specific to their industry: Dian Procesos Metalurgicos, East Penn Manufacturing, 

Exide Technologies, Industrial Mondelo, Johnson Controls Inc. (JCI) and its staff in the 

United States and its subsidiary Enertec in Mexico, La Batería Verde, M3 Corporation, 

Newalta, Recicladora Industrial de Acumuladores, RSR Corporation, Teck, Tonolli 

Canada, and Xstrata Zinc. We would also like to thank the Battery Council International 

and the American Battery Recyclers for their input into this study. A number of people 

involved in the battery collection business in Mexico also shared their insights on this 

study with us.

The following government officials were instrumental in providing us with information and data. From Environment Canada, we would like to thank Lo Cheng, Emmanuel 

Mendoza, Jean Ntimpirangeza and Robin Tremblay. From Mexico, we would like to 

thank Karla Acosta, Israel Gordoa, Sergio Herrera, Osvaldo López and Felipe Olmedo 

from the Office of the Federal Attorney for Environmental Protection (Procuraduría 

Federal de Protección al Ambiente—Profepa); Ana María Contreras, Alfonso Flores, 

Maricruz Gallegos, Eduardo González and Alberto Villa from the Secretariat of 

Environment and Natural Resources (Secretaría de Medio Ambiente y Recursos 

Naturales—Semarnat); and Frineé Cano, Leonor Cedillo, Arturo Gavilán and Leonora 

Rojas from the National Institute of Ecology and Climate Change (Instituto Nacional de 

Ecología y Cambio Climático—INECC). From the US Environmental Protection Agency, 

we would like to thank Laura Coughlan, Jana Tatum and Nathan Topham.

Several nongovernmental organizations provided valuable input into this report. 

We are grateful to Marisa Jacott and Adriana Camarena from Fronteras Comunes; Perry 

Gottesfeld and Kate Durand from Occupational Knowledge International; and Diane 

Cullo from Slabwatchdog. 

We also thank CEC staff members Marco Heredia, Eduardo Viadas, Jeff Stoub, 

Orlando Cabrera, and the editors, Sabra Ledent, Johanne David, Jacqueline Fortson, 

Douglas Kirk, and the translators who made this report readable.

Irasema Coronado

Executive Director

CEC Secretariat

Acknowledgments
viii
 Hazardous Trade? ix

The Secretariat of the Commission for Environmental Cooperation (CEC) initiated 

this study in response to concerns that some US-generated spent lead-acid batteries (SLABs) are being exported to Mexico for recycling to avoid the costs of the 

stricter environmental and health protection laws prevalent in the United States. 

Specifically, concerns have been raised that because the United States strengthened 

its ambient air standards for lead in 2008, there has been a surge of SLAB exports 

to Mexico. Some argue that this surge has increased the danger of lead exposure to 

workers and the people living near certain recycling operations in Mexico. Moreover, 

it is asserted that this practice undermines the competitiveness of the US-based lead 

recycling industry.

How SLABs are managed is an important public health, environmental and 

economic issue. A consensus now exists in the scientific community that there is no 

“safe” threshold for levels of lead in the blood. Lead can be absorbed into the human 

body and cause toxicity to the nervous system, heart, kidneys, bones and reproductive 

organs. Lead exposure can be particularly damaging to fetuses, infants and children. 

Lead is more easily absorbed into their bodies, and their tissues are more vulnerable 

to its damaging effects.

When carried out properly—as evident in the best practices of the North American 

lead recycling industry—the recycling of SLABs has been an environmental success 

story. In Canada, Mexico and the United States, SLAB recycling rates are near 100 percent—the highest rate for any product in the North American economy. In addition to 

high recycling rates, highly sophisticated pollution control technologies and management practices now provide ways for battery recycling facilities, called secondary lead 

smelters, to minimize lead emissions and protect the health of their workers. However, 

improperly managed lead recycling operations, even on a very small scale, can have 

devastating effects on the health of workers and the surrounding communities.

Industry Overview in North America

In the United States, eight companies operate 15 domestic secondary lead smelters 

that in 2011 produced an estimated 1,200,000 metric tons (t) of recycled lead, also 

called secondary lead. In Canada, three secondary smelters and two facilities that 

combine primary and secondary smelting produced 167,042 t of secondary lead in 

2010. In Mexico, the 25 authorized secondary smelters have a permitted capacity 

to recycle 1,337,171 t of SLABs. Reliable secondary lead production figures are 

not available for Mexico, but US and Mexican industry sources believe that many 

Mexican facilities are currently operating at no more than 50 percent of their permitted 

capacity. If this is indeed the case, and given that lead-acid batteries contain about 

60 percent lead alloy by weight, then Mexico may be producing some 401,151 t of 

lead annually.

In the United States and Canada, increasingly stringent environmental regulations 

have led to steady improvements in technologies and practices. The ever-stricter 

environmental performance requirements have in turn increased capital costs and 

contributed to consolidation and efficiencies of scale in the secondary smelting 

and battery recycling sectors. These changes have not occurred to the same extent 

in Mexico. 

Executive Summary

Hazardous Trade? ix
x Executive Summary

In Mexico, 15 facilities have a capacity 

of less than 30,000 t, whereas in the 

United States and Canada only one facility 

has an equal or smaller capacity. In addition, 

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 United States or Canada today.

Key Findings

The research and consultations conducted for 

this study reveal the following findings: 

Levels of Environmental and 

Public Health Protection

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 in Mexico, 

with significant gaps in its existing regulatory 

framework, certain emission controls and 

requirements are the least stringent and need 

to be augmented.

Tracking the SLAB Trade 

in North America

 The United States, unlike Canada and 

Mexico, does not require a manifest to 

accompany international shipments of 

SLABs. It also does not require exporters 

of SLABs to obtain a certificate of recovery 

from the recycling facility.

 The United States operates a notice 

and consent system via bilateral agreements with Canada and Mexico that 

addresses the trade in hazardous waste, 

including SLABs.

 In 2012, the environmental agencies in 

Canada, Mexico and the United States 

began to share electronically export 

requests and consent documents for 

hazardous waste exports, including 

SLABs, through the Notice and Consent 

Electronic Data Exchange (NCEDE) project. 

This system is replacing a paper-based 

system in which governments exchanged 

notice and consent information by mail, 

fax and cable.

 At present, the US Environmental 

Protection Agency (USEPA) manually 

enters into a database thousands of 

pieces of information from annual reports 

submitted by exporters of SLABs. 

Exports of US-generated SLABs 

Global US Exports

 According to USEPA data, in terms of the 

global volume of SLABs exported by the 

United States, Mexico is the leading destination (68 percent), followed by Canada 

(19 percent) and Korea (13 percent).

 Our review of US Census Bureau data 

indicates that US exporters are sending 

SLABs to 47 countries where USEPA has 

no record of having obtained consent from 

those countries to receive the SLABs. 

US-Mexico Trade in SLABs

 According to USEPA data, in 2011 the 

United States exported 389,539,362 kilograms (kg) of SLABs to Mexico. According 

to data from the US Census Bureau, 

in 2011 the United States exported 

342,186,978 kg of SLABs to Mexico and 

imported 191,341 kg. 
CEC – Hazardous Trade? Hazardous Trade? xi xi

 The USEPA export figure is 47,352,382 kg 

higher than the US Census Bureau figure, 

indicating that exporters of SLABs may 

not be correctly classifying that quantity 

of SLABs under the Harmonized Tariff 

Schedule (HTS) code system. 

 According to our estimates, between 2004

and 2011, US exports of SLABs to Mexico 

increased by 449–525 percent.

 Most of the increase in SLAB exports to 

Mexico is attributed to the business development and supply chain management of 

Johnson Controls Inc. (JCI), a US-based, 

globally diversified company. In 2004, 

JCI acquired Ciénega, a smelter in the 

municipality of Ciénega de Flores, Nuevo 

León, near Monterrey, Mexico, and began 

directing both US- and Mexican-generated 

SLABs to that facility for recycling. In 2011, 

JCI opened a secondary smelter, García, in 

the municipality of García in the greater 

Monterrey metropolitan area. According 

to USEPA data, in 2011 JCI’s operations 

at Ciénega accounted for 43 percent of 

all SLAB exports to Mexico, with García 

accounting for 31 percent. 

 The remaining 26 percent of the authorized exports of US-generated SLABs 

are being sent to seven facilities in three 

states in Mexico (Nuevo León, Baja 

California, and Tamaulipas). These seven 

facilities imported 100,669,466 kg of 

SLABs in 2011.

 We estimate that in 2011 between 12 and 

18 percent of all lead in US-generated 

SLABs was recycled in Mexico, and 

that between 30 and 60 percent of all 

SLABs recycled in Mexico came from the 

United States.

US-Canada Trade in SLABs

 According to Environment Canada data, in 

2011 the United States was a net exporter 

of SLABs to Canada by 86,987,630 kg. 

Between 2004 and 2011, net exports to 

Canada increased 221 percent. 

 Two secondary lead smelters, one in 

Ontario, Tonolli Canada, and one in 

Quebec, Newalta, accounted for about 

93 percent of these imports from the 

United States in 2011.

 Industry sources and regulatory 

authorities have informed the CEC 

Secretariat that they do not believe US 

Census Bureau data are a reliable indicator of the historical trade in SLABs to 

Canada prior to 2010. We concur in that 

assessment. Our review indicates that 

prior to 2010 some US exporters were 

improperly classifying SLAB exports under 

the HTS code 8548102500.

 We estimate that in 2011 US net exports 

to Canada represented about 4 percent 

of all lead in US-generated SLABs and 

about 31 percent of Canadian secondary 

lead production.

Data Reliability and Compliance 

in the United States 

 The Secretariat’s research has revealed 

data discrepancies that may indicate two 

compliance issues warranting further 

review by the appropriate US government 

agencies. The magnitude and relative 

importance of these issues were previously unknown to regulatory agencies.

• First, as noted previously, our review of 

USEPA and US Census Bureau data indicated that 47,352,382 kg of SLABs were 
xii Executive Summary

exported to Mexico in 2011 without 

having the proper HTS code applied. 

• Second, also as noted previously, our 

review of US Census Bureau data indicates that exporters are sending SLABs 

to countries from which USEPA has no 

record of having obtained SLAB export 

consent. To the extent this has occurred, 

it would be a violation of US law and 

potentially a violation of the importing 

countries’ laws. 

Data Reliability Across North America

 In addition, we note that data on the 

import and export volumes compiled 

within both the US and Mexico by different agencies—in Mexico by Semarnat 

and Profepa, and in the United States by 

the USEPA and US Census Bureau—are 

not consistent. Moreover, national crossborder accounts in all three countries 

do not accord with shipping or receiving 

volumes from either sending or receiving 

countries. Agencies responsible for such 

monitoring within and across borders need 

to work together to identify and improve 

the availability, accuracy, and comparability of data across North America. 

Permitting Secondary Lead Smelters 

in North America

 In Canada, Mexico, and the United States, 

secondary lead smelters operate under 

permits or licenses that contain conditions 

that are enforceable against the facility. 

 In Canada, the provinces issue permits, 

based on provincial law, that reflect a collaborative process between the regulator 

and the regulated entity. 

 In Mexico, the federal government issues 

operating permits for secondary lead 

smelting facilities, based on federal 

environmental statutes. These permits 

specify operational conditions, processes 

and technologies, and address issues 

such as environmental impacts, licensing 

requirements for air emissions, and the 

management of hazardous waste. 

 In the United States, state governments 

issue pollution discharge permits under 

the authority of federal environmental 

statutes. Although the federal government 

sets minimum standards, state requirements may, in most instances, exceed the 

federal requirements. 

Environmental Standards and 

Performance in Mexico for 

SLAB Recycling

 Notwithstanding Mexico’s permitting process, important gaps remain 

in its overall regulatory framework, as 

well as with respect to the prevailing 

environmental and public health standards in the United States and Canada. 

Specifically, Mexico 

• lacks regulations that establish lead 

emission limits from stacks and that 

contain requirements to control 

fugitive emissions; 

• lacks regulations that require secondary 

lead smelters to have management 

plans to address stormwater discharges 

and releases of lead to the soil;

• has not finalized regulations that would 

address outstanding hazardous waste 

management plans in the industry;

• has not issued an official standard 

(Norma Oficial Mexicana —NOM) 

addressing the construction, operation 

and closure of secondary lead smelters; 

• has yet to complete a standard for the 

characterization and remediation of 

sites contaminated with lead (and other 

pollutants); and 

• lacks a mandated protocol for the medical removal of workers whose blood 

lead levels equal or exceed a specified 

threshold. 

 The United States strengthened its 

ambient air standard for lead in 2008. 

Thus today Mexico’s ambient air standard 

is 10 times less stringent than that in the 

United States.

 Moreover, Mexico’s network of ambient air 

monitoring is incomplete. Air quality data 

for lead concentrations near all secondary 

lead smelters are unavailable, and no data 

are publicly available on stack emissions 

from secondary lead smelting facilities. 

 The requirement that companies report 

pollution release data is not applied 

and enforced consistently across the 

secondary lead smelting industry. 

Over 50 percent of the secondary lead 

smelters in Mexico have not reported 

their lead emissions to Mexico’s pollutant release and transfer register, the 

Registro de Emisiones y Transferencia de 

Contaminantes (RETC) program.
CEC – Hazardous Trade? Hazardous Trade? xiii xiii

 Finally, although some companies in 

Mexico indicate that they strive to meet 

US standards, the Secretariat is unable 

to evaluate the performance of individual 

facilities and to assess the health risks to 

workers and the general population from 

lead emissions caused by secondary lead 

smelting facilities in Mexico. This situation 

stems from the absence of publicly available performance data on lead emissions 

and the lead concentration in the ambient 

air near secondary lead smelters, and on 

the overall blood lead levels of workers in 

the industry.

Recommendations

The CEC Secretariat recommends that the 

governments of Canada, Mexico and the 

United States adopt six broad goals to 

address the findings presented in this report. 

For each of these goals, we have offered 

specific steps that governments can take to 

help realize them. These recommendations 

are designed to improve the management 

of information across North America and to 

ensure that adequate measures are in place 

to protect workers and the general public 

from the lead emitted during the recycling of 

spent lead-acid batteries in Mexico.

1 Raise the Bar

(North America) 

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 United States. Raising the bar across 

North America to equivalent levels will 

avoid the development of pollution havens 

and provide greater protection for the 

public and for the environment.

2 Improve Trade Compliance Efforts

(North America)

Canada, Mexico and the United States 

should streamline and improve the flow 

of notice and consent information and the 

tracking of SLABs. Specifically: 

 The United States should require the 

use of manifests for each international 

shipment of SLABs, and it should require 

exporters to obtain a certificate of 

recovery from the recycling facility. 

 Canada, Mexico and the United States 

should cooperate to allow the regulated community to submit export 

requests electronically. 

Photo: Profepa
xiv Executive Summary

 Finally, Canada, Mexico and the 

United States should work together to 

share the import and export data maintained by their respective environmental 

and border agencies. This information 

sharing could be used to identify trends 

that may require a policy response or that 

may raise compliance issues.

The goals of these recommendations are to 

reduce administrative burdens, improve data 

quality, make it easier to provide data to environmental enforcement and border protection 

agencies for compliance purposes, facilitate 

the adoption of emerging tracking technologies, and help the governments provide more 

timely, reliable, and coherent information on 

what crosses their national borders.

3 Close Information and 

Performance Gaps

(Mexico)

Mexico should establish a regulatory 

framework that covers the entire 

industry and provides public health and 

environmental protections equivalent to 

those in the United States. The following 

points are applicable to this framework:

 It should be based on performance data 

from the completion or establishment of 

a comprehensive monitoring system to 

measure lead air emissions from every 

secondary lead smelter. More specifically,

• performance data, including average 

stack emissions and ambient air lead 

concentrations near smelters, should be 

collected by competent environmental 

authorities and compared across the 

entire sector;

• performance data should be provided to 

environment and health authorities at 

the federal, state and municipal levels, 

as well as to the public, on a periodic 

and timely basis; and

• performance data should be compared 

against Mexico’s existing ambient air 

standard of 1.5 micrograms per cubic 

meter (μg/m3

) to identify the most 

pressing gaps in meeting this standard.

 It should establish standards for stack 

and fugitive lead emissions, functionally 

equivalent to those in the United States. 

 It should adopt an ambient air lead standard that is functionally equivalent to that 

of the United States.

 A medical removal limit (a requirement 

that workers whose blood lead levels 

equal or exceed a certain standard must 

be temporarily removed from situations 

of further exposure) should be included 

in the requirement to test the blood lead 

levels of workers in the battery recycling 

and manufacturing sectors.

 Secondary lead smelting facilities should 

be required to have stormwater management plans, and standards and criteria 

should be issued for the development of 

hazardous waste management plans. 

Photo: Profepa
CEC – Hazardous Trade? Hazardous Trade? xvxv

 Clear standards should be established for 

the construction, operation and closure of 

secondary lead smelters. 

 A standard should be established for the 

characterization and remediation of sites 

contaminated with lead. In line with this, 

a policy mechanism should be established to ensure secure funding, sound 

management, and appropriate oversight 

of remediation of contaminated sites in 

Mexico. 

 All facilities that undertake secondary lead 

smelting in Mexico should be required to 

report pollutant releases and transfers to 

the federal RETC program.

 Mexico should continue efforts to identify, 

halt and deter any SLAB recycling and 

lead recovery operations in the informal or 

clandestine sector.

 The Secretariat of Environment and 

Natural Resources (Secretaría de Medio 

Ambiente y Recursos Naturales—

Semarnat), the Office of the Federal 

Attorney for Environmental Protection 

(Procuraduría Federal de Protección al 

Ambiente—Profepa) and other federal 

agencies should have sufficient resources 

to ensure adherence to the law and protect 

public health and the environment.

4 Ensure Accurate and Comparable 

Information on Lead Emissions

(North America)

 Performance data—including facilityspecific stack emission estimates, average 

ambient lead concentrations and worker 

blood lead levels as collected by competent environmental authorities in Canada, 

Mexico and the United States—should be 

maintained in a central North American 

repository and be made available to 

the public.

 Emissions data specific to the secondary 

lead smelting sector, as reported to each 

country’s respective pollutant release 

and transfer register (PRTR), should be 

catalogued and made available to the 

public via the CEC’s North American 

PRTR initiative.

 CEC support of Mexico’s PRTR initiative, 

the RETC, should continue, to ensure that 

comprehensive, comparable and quality 

data are available on the reported releases 

and transfer of lead by Mexico’s secondary 

lead smelters.

5 Support Best Practices

(North America)

The governments of Canada, Mexico and 

the United States should work together 

with the North American secondary lead 

smelting industry and nongovernmental 

organizations to develop strategies to 

support the adoption of best practices 

throughout the region. This effort should 

include the following:

 Support Mexico in enacting legislation 

to establish a comprehensive battery 

stewardship program that requires the 1:1

exchange and recycling of batteries in only 

the highest-performing facilities. Such 

legislation would be expected to establish 

minimum deposit fees and control the 

return of used batteries to authorized 

recycling facilities throughout Mexico.

 Given the integrated nature of the SLAB 

recycling market in North America, ensure 

trilateral stakeholder input into any new 

stewardship or voluntary, market-based 

mechanisms intended to drive continuous 

improvements in the industry throughout 

North America.

6 Foster Regional Cooperation 

and Technical Assistance

(North America)

The North American governments, through 

the CEC or other appropriate venues, 

should cooperate to ensure:

 a plan of action to share information, 

technical assistance and best practices in 

order to assist Mexico in implementing the 

recommendations contained in this report;

 the highest level of comparable and 

publicly available information on the performance of the secondary lead smelting 

sector throughout North America; and

 enhanced cooperation and encouragement of cross-border support and 

intelligence-sharing on any illegal or 

unsanctioned traffic in SLABs across 

North American borders.
1
 Hazardous Trade? Hazardous Trade? 1

Introduction

The study described in this report examined the transborder 

movement and recycling of spent lead-acid batteries (SLABs)1

 in 

North America. The Secretariat of the Commission for Environmental 

Cooperation (CEC) initiated this study in response to concerns 

that some US-generated SLABs were being exported to Mexico 

for recycling to avoid the costs of the stricter environmental and 

health protection laws prevalent in the United States. 

Specifically, some argue that since the 

United States strengthened its ambient air 

standards for lead in 2008 and its lead emissions standards at battery recycling facilities 

in 2012, there has been a surge of SLAB 

exports to Mexico, increasing the danger of 

lead exposure to workers and the people 

living near certain recycling operations in 

Mexico.2

 Moreover, it is asserted that this 

practice undermines the competitiveness 

of the US-based SLAB recyclers, who must 

comply with costlier environmental regulations than their counterparts in Mexico.3

This report examines not only the trends 

in the North American trade in SLABs, but 

also the management of SLABs, whether 

domestically generated or imported, in all 

three North American countries. One goal of 

this study is to offer ideas on ways to improve 

the environmental management of SLABs in 

Mexico, no matter their origin.

As part of this study, representatives 

of the CEC Secretariat visited smelters in 

Canada, Mexico, and the United States. In 

Mexico, we spoke with numerous government 

officials and industry representatives, and 

we both observed and were informed about 

a wide range of practices, processes and 

control technologies in the industry. 

This report is organized as follows. 

Chapter 1 describes the process of recycling 

SLABs, as well as the SLAB recycling industry 

in North America and its trends. Chapter 2

looks at the North American framework for 

regulating SLABs, including the international 

agreements in place and the import and 

export controls adopted by Canada, Mexico 

and the United States. Chapter 3 considers 

the North American trade in SLABs and the 

problems inherent in the unreliability of 

data on that trade. It then seeks to answer 

the question, what is driving US exports to 

Mexico? The discussion of pollution control 

and occupational standards in Chapter 4

leads naturally into examination of the environmental performance of the SLAB recycling 

1 Spent lead-acid batteries are variously referred to as used lead-acid batteries (ULABs), cores, junks or SLABs. For the sake of 

convenience, this report has adopted the term SLABs for used, or spent, lead-acid batteries that are sent for recycling. 2 See, for example, Occupational Knowledge International and Fronteras Comunes, Exporting Hazards: US Shipments of 

Used Lead Batteries to Mexico Take Advantage of Lax Environmental and Worker Health Regulations, OKI, Garden Grove, CA, June 

2011, <http://www.okinternational.org/docs/Exporting%20Hazards_Study_100611v5.pdf>. 3 Rob Quinn, “US Battery Recycling Is Poisoning Mexico’s Kids,” Newser, 9 December 2011, <http://www.newser.com/

story/135035/us-battery-recycling-is-poisoning-mexico-kids.html>. Also see Occupational Knowledge International and 

Fronteras Comunes, Exporting Hazards, note 2. Also see Elisabeth Rosenthal, “Lead from Old US Batteries Sent to Mexico Raises 

Risks,” New York Times, 8 December 2011, <http://www.nytimes.com/2011/12/09/science/earth/recycled-battery-lead-putsmexicans-in-danger.html>.
2 Introduction

industry in Chapter 5. The concluding chapter 

of this report then presents our findings 

and recommendations.

This report comes at an opportune time 

for governments, industry and stakeholders. 

A renewed focus on secondary lead smelting 

in Mexico by public health and environmental 

advocacy groups, a willingness by industry 

leaders to address these issues, and changes 

in the economics driving the industry have 

all combined to provide an opportunity for 

stakeholders to work together to improve the 

environmental conditions and impacts of the 

lead recycling sector in Mexico and the oversight of SLAB recycling management across 

North American boundaries.

Lead-acid Batteries and

the Recycling of SLABs

How SLABs are recycled is an important economic, public health and environmental issue. 

Today, advanced secondary lead smelters 

are operating with highly sophisticated 

pollution control and management systems 

in order to minimize lead emissions and to 

protect the health of their workers and that 

of nearby communities. However, without 

rigorous environmental controls and management systems, SLAB recycling can result in 

tremendous, long-lasting harm to workers, 

communities and the environment. 

Lead and Batteries

Because lead is no longer used in many 

products, lead-acid battery manufacturing 

is now the most dominant source of lead 

consumption throughout the world.4

 Leadacid batteries are a critical source of stored 

energy in our society. They provide the 

lowest-cost energy per kilowatt-hour, use 

a simple technology, and require materials 

that are relatively abundant. They are used 

in automobiles, as well as in uninterrupted 

power supply systems,5 grid energy storage, 

off-grid household electric power systems, 

golf carts and other battery electric vehicles 

(including hybrid vehicles), and submarines.6

Most of the world’s lead-acid batteries 

4 In the United States, lead-acid batteries account for about 90 percent of lead consumption. See David E. Guberman, 2010

Minerals Yearbook, Lead (Advance Release) (Washington, DC: US Department of the Interior, US Geological Survey, January 

2012), 42.1 and table 7. See <http://minerals.usgs.gov/minerals/pubs/commodity/lead/myb1-2010-lead.pdf>. 5 Uninterrupted power supply systems are used in telephones and data and computer centers, where they provide emergency 

power when the main power source fails. 6 Lead-acid batteries power the electric motors in diesel-electric (conventional) submarines and are used on nuclear submarines. 

Photo: Profepa
 Hazardous Trade? 3

are automobile starting, lighting, ignition 

(SLI) batteries. In 2010, SLI shipments in 

North America totaled 119.6 million units, 

which included original equipment and 

replacement-type automotive batteries.7

In North America, SLAB recycling rates 

are near 100 percent,8

 the highest for any 

product in the economy. The recycling of 

SLABs provides a critical and stable supply of 

lead to the battery industry, reduces the need 

to mine for new lead, and diverts batteries 

from landfills. This high recycling rate is possible because (1) the cost of recycling lead 

from batteries is significantly less than the 

cost of mining and processing lead from ore; 

(2) lead can be recycled indefinitely without 

losing its properties; and (3) the infrastructure and economies of scale necessary for 

collecting and transporting SLABs to recycling 

facilities exist in all three countries. Because 

of the ease with which they can be recycled, 

SLABs are the primary source of new lead for 

the battery manufacturing industry.9

SLABs are recycled at secondary lead 

smelters,10where they are crushed and sorted 

into plastics, sulfuric acid and lead fractions, 

which consist of posts, plates and oxides. This 

process entails the following steps:

 Lead is recycled through a process 

involving smelting, refining and alloying. 

Smelting recovers the metallic lead; 

refining removes the lead’s metallic 

impurities; and alloying is a process that 

creates the necessary composition of the 

end product. 

 The plastics are usually recycled—

on- or off-site—into battery cases or 

other products. 

 The sulfuric acid can be reused in the 

smelting process, neutralized for disposal, 

processed in an effluent treatment plant 

(ETP) or sold. 

Smelting entails heating the lead fractions 

in a furnace. As the lead melts, the impurities, called slag, float to the top of the molten 

lead and are removed. The molten lead, not 

yet free of metallic impurities, is either cast 

into ingots or further refined and alloyed. 

The battery market, which requires soft lead 

for the active constituent, lead oxide, and 

antimonial lead for the grids, bridges and 

terminals, largely drives how smelters refine 

and alloy lead. 

Public Health Concerns

Lead-acid battery recycling is a dangerous 

activity that requires extra scrutiny from 

government regulators. The main danger 

from SLAB recycling is emissions of lead 

particles to the environment. Lead emissions 

occur as stack releases, which are exhaust 

gases released through stacks as a result of 

the smelting process,11 and as fugitive dust 

emissions, which result from the handling, 

storage, transfer or other management 

of lead-bearing materials.12 Lead can also 

escape from a secondary lead smelter in 

water discharges or in solid wastes. Improper 

occupational controls can expose workers to 

high levels of lead, who in turn can transport 

lead particles into their yards and homes via 

their clothing or vehicles, causing others to be 

exposed to high levels of lead.13 Minimizing 

lead emissions is particularly important 

because elemental lead will not decay; it will 

stick to soil particles, where it can persist for 

hundreds if not thousands of years.14

Human exposure to lead occurs via the 

inhalation of lead particles in the air and 

through contact with lead particles in dust, 

outdoor soil, food and drinking water. Human 

tissue and blood can then absorb these lead 

particles.15 Blood lead level (BLL) is used as a 

biological indicator of recent lead exposure.

7 Guberman, 2010 Minerals Yearbook, Lead, 42.1. 8 Battery Council International’s May 2012 study estimates that the recycling rate in the United States is 98.7 percent. Battery Council International, “National 

Recycling Rate Study,” May 2012. See <http://archive.batterycouncil.org/Portals/0/BCI%20Recycling%20Rate%20Study%202007%20-%202011%20FINAL%20

REPORT.pdf>. Studies conducted by the Canadian Battery Association on recycling rates in British Columbia and Manitoba found that more 

batteries were being collected for recycling than were being sold in those provinces. See <http://recyclemybattery.ca/>. Although the CEC Secretariat was unable 

to locate recent studies on SLAB recycling rates in Mexico, industry experts and government officials in Mexico believe their recycling rates are near 100 percent. 9

Guberman, 2010 Minerals Yearbook, Lead, 42.1 10 A secondary lead smelter is a facility that recycles lead-bearing scrap materials into elemental lead or lead alloys by smelting. A primary lead smelter is a facility 

engaged in the production of lead metal from lead sulfide ore concentrates through the use of pyrometallurgical or other techniques. 11 Exhaust gases come from furnaces, dryers and tapping points, and may also contain metal compounds such as lead, arsenic and cadmium, as well as inorganic 

compounds, which are caused by processes such as the incomplete combustion of coke or the addition of plastics to the furnace emissions. 12 Definitions, 40 C.F.R. sec. 63.542 (2009), <http://www.gpo.gov/fdsys/pkg/CFR-2011-title40-vol9/pdf/CFR-2011-title40-vol9-sec63-542.pdf>. 13 See note 125 below and its accompanying text. 14 Agency for Toxic Substances and Disease Registry, Toxicological Profile: Lead, August 2007, 301–304, <http://www.atsdr.cdc.gov/toxprofiles/

tp.asp?id=96&tid=22>. 15 Technology Transfer Network, Air Toxics Web Site, Lead Compounds, US Environmental Protection Agency, <http://www.epa.gov/ttnatw01/hlthef/lead.html>.

The main 

danger from 

SLAB recycling 

is emissions 

of lead 

particles to the 

environment.

’

’
4

A consensus exists in the scientific 

community today that there is no “safe” 

threshold for BLLs.16 At low levels of exposure, lead produces a range of adverse effects 

in humans, beginning with diminishment of 

IQ and a range of neurobehavioral problems 

such as attention deficit disorder, reduced 

hearing acuity and adverse effects on the 

cardiovascular, renal and immune systems. 

At high levels, lead poisoning manifests more 

overt symptoms such as anemia, chronic and 

acute lead encephalopathy, kidney damage, 

brain damage and even death.17 Fetuses, 

infants and children are more susceptible 

to lead exposure than adults. Lead is more 

easily absorbed into their bodies, and their 

tissues are more vulnerable to the damaging 

effects of lead. Children are more likely to get 

lead dust on their hands and put their fingers 

or lead-contaminated objects into their 

mouths.18 Population-wide, the effects of lead 

exposure can have significant economic and 

public health consequences.19

For adults, in the United States a BLL 

of 10 micrograms per deciliter (μg/dL) or 

greater is considered “elevated,” and the 

United States has set a goal of eliminating 

BLLs above 25 μg/dL.20 In Canada, the 

medical intervention level is 10 μg/dL.21 In 

Mexico, a BLL of 25 μg/dL in the non-occupational general population triggers medical 

intervention.22 Recent studies reveal that even 

at exposures of less than 10 μg/dL in adults, 

however, lead can cause renal, cardiovascular 

and reproductive health problems.23

For children, the US Centers for Disease 

Control and Prevention (CDC) adopted in 2012

a childhood blood lead level reference of 

5 μg/dL, based on the 97.5th percentile of the 

population BLL in children, to identify children 

and environments associated with lead exposure hazards. In adopting this reference value, 

16 The US Environmental Protection Agency (USEPA) has recognized that, based on the science, no level of lead exposure is considered safe, because some of 

these health effects, particularly changes in the levels of certain blood enzymes and in aspects of children’s neurobehavioral development, may occur at blood 

lead levels so low as to be essentially without a threshold. See USEPA, “Residual Risk Assessment for the Secondary Lead Smelting Source Category,” EPAHQ-OAR-2011-0344-0160, December 2011, <http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2011-0344-0160f>, particularly section 3.2 and Table 

3.2-3 and p. 45. This lack of a safe exposure threshold is also acknowledged in the Mexican official standard, NOM-047-SSA1-2011, issued 6 June 2012, <http://

dof.gob.mx/nota_detalle.php?codigo=5249877&fecha=06/06/2012>. See sec. 7.1. 17 Agency for Toxic Substance and Disease Registry, "Toxic Substances Portal—Lead," Public Health Statement on Lead, August 2007. The evaluation focuses on 

epidemiological evidence at blood lead levels of <10 micrograms per deciliter (μg/dL) because health effects at higher blood lead levels are well established. 

The definition of an elevated blood lead level is ≥10 μg/dL for both children and adults. See National Toxicology Program (2012), Health Effects of Low-Level Lead 

Evaluation (pre-publication copy) <http://ntp.niehs.nih.gov/?objectid=4F04B8EA-B187-9EF2-9F9413C68E76458E>. 18 Advisory Committee on Childhood Lead Poisoning Prevention, Centers for Disease Control and Prevention, “Low Level Lead Exposure Harms Children: A Renewed 

Call for Primary Prevention,” 4 January 2012, 12, <http://www.cdc.gov/nceh/lead/acclpp/final_document_010412.pdf>. 19 Agency for Toxic Substances and Disease Registry, Toxic Substances Portal—Lead, Public Health Statement on Lead. 20 US Department of Health and Human Services, Healthy People 2010, 2d ed. (Washington, DC: US Government Printing Office. November 2000), Objective 20-7. 21 Health Canada, Final Human Health State of the Science Report on Lead, July 2011, <http://www.hc-sc.gc.ca/ewh-semt/pubs/contaminants/dhhssrl-rpecscepsh/

index-eng.php>. 22 NOM-199-SSA1-2000, <http://www.salud.gob.mx/unidades/cdi/nom/199ssa10.html>. 23 US Department of Health and Human Services, NTP Monograph on Health Effects of Low-Level Lead, table 1.1. xix, <http://ntp.niehs.nih.gov/NTP/ohat/Lead/

Final/MonographHealthEffectsLowLevelLead_prepublication_508.pdf>. 

Introduction

Photo: Profepa
 Hazardous Trade? 5

the CDC cited a growing body of evidence 

that even low BLLs are associated with IQ 

deficits, attention-related behaviors and 

poor academic achievement, and can have 

negative cardiovascular, immunological and 

endocrinal effects on children.24 In Mexico, a 

BLL of 10 μg/dL is of concern for children and 

for pregnant and lactating women.25 In the 

United States, a level of 5 μg/dL is of concern 

for the latter group.26 Canada does not have a 

BLL of concern specific to children or pregnant 

and lactating women other than its medical 

intervention level of 10 μg/dL.

Lead is not the only public health and 

environmental concern presented by SLAB 

recycling. Because of the dangers posed 

by the sulfuric acid in the batteries, SLABs 

must also be properly handled during their 

collection and transportation to secondary 

lead smelters. The secondary lead smelter 

itself must have processes in place to safely 

manage solid wastes, water, plastic casings 

and sulfuric acid, and to control the emission 

of other air pollutants such as particulate 

matter, dioxins, furans and hydrocarbons.

The SLAB Recycling Industry

in North America

In North America, the battery recycling 

industry is in the process of undergoing 

significant change. Increasingly stringent environmental regulations in the 

United States and Canada have forced 

smaller, less capitalized smelters out of 

business. In addition, vertical integration and internationalization are becoming 

more common globally and throughout 

North America. These changes are occurring 

as secondary lead smelters are in fierce competition for a limited supply of SLABs. This 

is most pronounced in Mexico, where tight 

profit margins and an apparent overcapacity 

are expected to compel some of the smaller, 

unprofitable smelters to go out of business in 

the coming years.

Global Market and Price Volatility

The lead recycling industry in North America 

operates within a global market. The price 

of refined lead is set in the London Metals 

Exchange (LME) and, as a global commodity, 

is subject to ever-shifting demand and supply 

pressures. In recent years, the international 

lead market has been characterized by a 

growing demand from Chinese manufacturers, whose production of consumer 

electronics, automobiles and battery-powered 

modes of transport—notably e-bikes—has 

outstripped their domestic lead production. Notwithstanding commodity price 

fluctuations, surging Chinese demand has 

contributed to a general increase in global 

lead prices over the last 10 years.27

Secondary lead, derived principally 

from SLABs, is the principal ingredient of 

24 See “CDC Response to Advisory Committee on Childhood Lead Poisoning Prevention Recommendations in ‘Low Level Lead Exposure Harms Children: A Renewed 

Call for Primary Prevention,’” 7 June 2012, <http://www.cdc.gov/nceh/lead/acclpp/cdc_response_lead_exposure_recs.pdf>. The CDC accepted the advisory 

group’s recommendation that the term "level of concern," which had been set at 10 μg/dL, be eliminated from all future agency policies, guidance documents and 

other CDC publications. See Advisory Committee on Childhood Lead Poisoning Prevention, Centers for Disease Control and Prevention, “Low Level Lead Exposure 

Harms Children.” 25 NOM-199-SSA1-2000, <http://www.salud.gob.mx/unidades/cdi/nom/199ssa10.html>. 26 The Centers for Disease Control and Prevention recommend follow-up activities and interventions beginning at blood lead levels of ≥5 μg/dL in pregnant women. 

Centers for Disease Control and Prevention, Guidelines for the Identification and Management of Lead Exposure in Pregnant and lactating Women, Adrienne S. 

Ettinger and Anne Guthrie Wengrovitz, ed., iv, <http://www.cdc.gov/nceh/lead/publications/leadandpregnancy2010.pdf>. 27 China will account for about 45 percent of the global lead demand this year, according to Agnieszka Troszkiewicz, “Lead Shortage Looms in ’13 on Record 

Demand for Batteries,” Bloomberg News, 15 May 2012, <http://www.businessweek.com/news/2012-05-14/lead-shortage-looms-in-13-on-record-demand-forbatteries#p1>. A lead price graph can be found at <http://www.lme.com/lead_graphs.asp>.
6

refined lead. In the United States, secondary 

lead accounted for some 91 percent of the 

1.25 million metric tons (t) of refined lead 

produced in 2010.

28

Among North American lead recyclers, 

the competition for SLABs is fierce, with the 

increasing demand driving prices for used 

batteries to new highs. Industry sources 

report that in recent months there has been 

a disconnect between the price of SLABs 

and the LME price for refined lead. The price 

of SLABs on the open market has edged 

close to the price of refined lead, leading to 

margin compression in supply chains. Lead 

recyclers dealing with insufficient supplies of 

SLABs through tolling agreements,29 vertical 

integration with battery manufacturers and 

suppliers, or a captive stream from a reverse 

distribution system have found that vulnerability to the vagaries of the open market for 

increasingly expensive SLABs is constraining 

both profits and their abilities to operate 

recycling facilities at optimal volumes. 

Getting SLABs to the Smelters

In North America, several systems are in 

place for collecting and transporting SLABs 

to smelters. The most common is through a 

reverse distribution system. In this type of 

system, battery manufacturers have a sales 

agreement with automobile service centers or 

retail outlets to collect used batteries at the 

point of purchase. When the battery manufacturer delivers new batteries, it collects the 

used batteries and sends them to a secondary 

lead smelter for the recovery of lead. The 

refined lead is then returned to the battery 

manufacturer for use in the production of new 

batteries. SLABs are also collected through 

brokers or aggregators. Smaller retailers, 

service stations and scrap yards often do not 

have agreements with battery manufacturers. 

Instead, they may sell SLABs to scrap dealers, 

who then sell them to smelters. In rare cases, 

independent automobile service centers may 

sell batteries directly to nearby smelters, a 

practice that is most common in Mexico.

The strong demand for used batteries in 

North America today means price incentives 

are sufficient to ensure that almost all SLABs 

are diverted from the waste stream and collected and sent to a recycler. In most parts of 

North America, a consumer receives US$10–20

for returning a used automotive battery to 

a retail outlet.30 In Mexico, however, battery 

collectors have been known to charge a fee to 

collect industrial batteries, which are heavier 

and more difficult to recycle, if the secondary 

smelter charged them to accept these batteries. 

In the United States, a majority of states 

have enacted laws to incentivize the recycling of batteries by banning the disposal of 

lead-acid batteries in landfills; establishing 

a deposit system for new battery sales; 

requiring retailers, wholesalers and manufacturers to take back SLABs; and making it a 

violation of law to send SLABs to unlicensed 

facilities.31 These statutes help ensure that if 

the price of lead drops, a regulatory framework and incentives are in place to get SLABs 

to smelters. 

Canada, at the federal level, and Mexico do 

not have specific laws requiring the collection 

of SLABs. However, various take-back programs 

are in place in both countries; examples are 

British Columbia’s lead-acid battery stewardship program32 and JCI’s reverse distribution 

system in Mexico, which uses an extensive distribution network to collect used batteries from 

its retailers and other distribution centers.33

Secondary Lead Smelters 

in North America

Table 1-1 lists secondary lead smelters in 

North America that process spent lead-acid 

batteries. It also includes pollution release 

information for 2007–2010, if available, as 

reported by the facilities and in accordance 

with national pollutant release and transfer 

registries (PRTRs). The following maps show 

the approximate locations of smelters that 

The strong 

demand 

for used 

batteries in 

North America 

today means 

price incentives 

are sufficient 

to ensure that 

almost all SLABs 

are diverted 

from the 

waste stream 

and collected 

and sent to 

a recycler.

’

28 Guberman, 2010 Minerals Yearbook, Lead, 42.18. 29 A tolling agreement is an arrangement in which a smelter agrees with a battery manufacturer to smelt the lead from SLABs for a 

specified fee, or “toll.” 30 When a person buys a new battery and returns an old one, these fees are paid as the return of a deposit or a discount on the price 

of a new replacement battery. 31 A summary of US state laws can be found at <http://batterycouncil.org/?page=State_Recycling_Laws>. 32 See Environmental Management Act, Recycling Regulation (includes amendments up to B.C. Reg. 132/2011, 21 July 2011), 

<http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/449_2004#Schedule>. 33 JCI operates a closed-loop distribution chain throughout 30 Mexican states, including collection centers for batteries, as well as a 

fleet of dedicated trucks and trailers. See <http://www.epa.gov/osw/conserve/materials/ecycling/conference/guillen/guillenpresent.pdf>.

’

Introduction
Hazardous Trade? 7

Table 1-1. Spent Lead-acid Battery Processing Facilities in North America, 

including Pollution Release Information as Reported for 2007–2010

Facility Name Location NAICS* Capacity 

(tons)

PRTR ID PRTR Reported Air Emissions of Lead 

(and/or its compounds) (kg)

Description Codes 2007 2008 2009 2010

CANADA – NPRI

1 Teck Trail 

Operations 

(primary lead 

smelter which also 

consumes SLABs)

Trail, 

British Columbia

Non-ferrous 

Metal (except 

Aluminum) 

Smelting and 

Refining

33141 3802 2,050.33 1,562.87 1,089.21 882.88

2 Xstrata Zinc 

– Brunswick 

Smelter 

(primary lead 

smelter which also 

consumes SLABs)

Belledune, 

New Brunswick

Non-ferrous 

Metal (except 

Aluminum) 

Smelting and 

Refining

33141 4024 5,319.60 5,873.70 6,814.40 7,586.00

3 Newalta Ste-Catherine, 

Quebec

Non-ferrous 

Metal Foundries

33152 4402 642.38 583.00 545.80 573.94

4 Tonolli Mississauga, 

Ontario

Non-ferrous 

Metal Rolling, 

Drawing, 

Extruding and 

Alloying

33149 2256 452.84 419.84 352.24 432.49

5 Metalex 

Products Ltd.

Richmond, 

British Columbia

All Other 

Miscellaneous 

Manufacturing

33999 732 28.00 3.19 3.90 5.01

United States – TRI

1 The Battery 

Recycling 

Company

Arecibo, 

Puerto Rico

Non-ferrous 

Metal Rolling, 

Drawing, 

Extruding and 

Alloying

33149 18,268.25

[1]

00612BTTRYRD2KM 74.72 42.38 29.84 48.10

2 Buick Resource 

Recycling 

(Doe Run)

Boss, Missouri Non-ferrous 

Metal Rolling, 

Drawing, 

Extruding and 

Alloying

33149 65440BCKSMHIGHW 35,351.18 11,486.77 13,259.41 15,658.01

3 East Penn 

Manufacturing 

Co., Inc.

Lyon Station, 

Pennsylvania 

Battery 

Manufacturing 

and Recycling

33591 167,754

[2]

19536STPNNDEKAR 2,037.17 1,997.62 2,738.34 2,574.14

4 Exide 

Technologies, Inc. 

– Facility 1

Muncie, Indiana Non-ferrous 

Metal Rolling, 

Drawing, 

Extruding and 

Alloying

33149 130,000

[3]

46302XDCRP2601W 790.61 469.92 349.72 165.56

5 Exide 

Technologies, Inc. 

– Facility 2

Vernon, 

California

Non-ferrous 

Metal Rolling, 

Drawing, 

Extruding and 

Alloying

33149 90058GNBNC2717S 1,557.58 778.36 275.78 275.78

* NAICS = North American Industry Classification System; a collaborative effort by Mexico's Instituto Nacional de Estadística y Geografía (INEGI), Statistics Canada, and the 

United States Office of Management and Budget (OMB), through its Economic Classification Policy Committee (ECPC), staffed by the Bureau of Economic Analysis (BEA), the 

Bureau of Labor Statistics (BLS), and the Census Bureau.
8

6 Exide 

Technologies, Inc. 

– Facility 4

Baton Rouge, 

Louisiana 

Non-ferrous 

Metal Rolling, 

Drawing, 

Extruding and 

Alloying

33149 100,000

[4]

70874SCHYLWESTE 2,948.35 2,857.63 635.03 --

7 Exide 

Technologies, Inc. 

- Facility 5

Canon Hollow, 

Missouri

Non-ferrous 

Metal Rolling, 

Drawing, 

Extruding and 

Alloying

33149 64451SCHYLRRIII 9.07 9.07 9.07 9.07

8 Exide 

Technologies, Inc. 

- Facility 6 

(ceased operations 

in late 2012)

Frisco, Texas Non-ferrous 

Metal Rolling, 

Drawing, 

Extruding and 

Alloying

33149 72,000

[5]

75034GNBNCSOUTH 1,731.82 2,248.46 1,420.65 986.56

9 Exide 

Technologies, Inc. 

- Facility 7 

(will idle facility by 

31 March 2013)

Reading, 

Pennsylvania

Non-ferrous 

Metal Rolling, 

Drawing, 

Extruding and 

Alloying

33149 208,050

[6]

19605GNRLBSPRIN 1,392.67 910.29 963.25 894.84

10 Gopher Resource Eagan, 

Minnesota

Non-ferrous 

Metal Rolling, 

Drawing, 

Extruding and 

Alloying

33149 228,636

[7]

55121GPHRS3385S 451.78 619.15 646.01 597.83

11 Gopher Resource 

– Envirofocus 

Technologies

Tampa, Florida Non-ferrous 

Metal Rolling, 

Drawing, 

Extruding and 

Alloying

33149 150,000

[8]

33619GLFCS1901N 839.60 591.94 639.52 191.05

12 Johnson 

Controls, Inc. 

(began operations 

in 2012)

Florence, 

South Carolina 

Battery 

Manufacturing

33591 174,762

[9]

29506JHNSN346BI 0.00 0.00 0.00 0.00

13 RSR Corporation, 

Quemetco –

Facility 1

City of Industry, 

California

Non-ferrous 

Metal Rolling, 

Drawing, 

Extruding and 

Alloying

33149 241,338

[10]

91745QMTCN720SO 244.03 120.66 10.69 5.08

14 RSR Corporation, 

Quemetco –

Facility 2

Indianapolis, 

Indiana

Non-ferrous 

Metal Rolling, 

Drawing, 

Extruding and 

Alloying

33149 333,046

 [11]

46231QMTCN7870W 560.64 571.07 399.16 381.02

15 RSR 

(Revere Smelting 

& Refining Corp.)

Middleton, 

New York

Non-ferrous 

Metal Rolling, 

Drawing, 

Extruding and 

Alloying

33149 285,583 

[12] 

10940RVRSMRD2BA 336.11 356.07 284.86 245.85

16 Sanders Lead 

Company

Troy, Alabama Non-ferrous 

Metal Rolling, 

Drawing, 

Extruding and 

Alloying

33149 145,000

[13]

36081SNDRSHENDE 3,842.38 4,168.51 2,101.04 1,360.78

 Table 1-1.

Introduction

Facility Name Location NAICS Capacity 

(tons)

PRTR ID PRTR Reported Air Emissions of Lead 

(and/or its compounds) (kg)

Description Codes 2007 2008 2009 2010
Hazardous Trade? 9

MEXICO – RETC data available*

1 Enertec México, 

S. de R.L. de C.V. 

Ciénega de 

Flores, Nuevo 

León

Non-ferrous 

Metal (except 

Aluminum) 

Smelting 

and Refining

33141 254,085 EMCLJ1901211 -- 11,011.57 8,129.05 6,811.76

2 Enertec México, 

S. de R.L. de C.V. 

(began operations 

in 2011)

García, 

Nuevo León

252,000

3 Recicladora 

Industrial de 

Acumuladores, 

S.A de C.V.

Santa Catarina, 

Nuevo León

Ferrous Metal 

Foundries

33151 121,804 RIALJ1904811 65,643.00 12,628.00 1,977.00 2,030.00

4 Corporación 

PIPSA, 

S.A. de C.V. 

García, 

Nuevo León

Waste 

Collection

56211 104,760 CPILJ1901811

(or: CPILV1901811)

0.00 0.00 166.00 199.00

5 M3 Resources 

México, S. de 

R.L. de C.V.

Reynosa, 

Tamaulipas

Non-ferrous 

Metal Foundries

33152 50,000 MTRBD2803211 -- 72.70 -- 393.28

6 Eléctrica 

Automotriz 

Omega, 

S.A. de C.V. 

Planta Doctor 

González, 

Nuevo León 

Non-ferrous 

Metal (except 

Aluminum) 

Smelting 

and Refining

33141 94,000 EAOBB1901611 1,627.22 941.60 941.60 

7 La Batería Verde, 

S.A de C.V. 

(began operations 

in 2012)

Tezoyuca, Estado 

de México

36,000

8 Productos 

Metalúrgicos 

Salas, S.A. de C.V.

Aguascalientes, 

Aguascalientes

Waste 

Collection

56211 15,000 PMSRE0100111 -- 95.17 111.02 66.08

9 Óxidos y 

Pigmentos 

Mexicanos, 

S.A. de C.V.

Tijuana, Baja 

California

Non-ferrous 

Metal (except 

Aluminum) 

Smelting 

and Refining

33141 12,400 OPM7L0200421 58.08 332.16 -- 0.00

10 Hornos de 

Fundición, 

S.A. de C.V.

Valle Hermoso, 

Tamaulipas

Waste 

Collection

56211 9,500 HFUTF2804011 -- 0.00 20.57 0.00

11 Aleaciones 

Metalúrgicas, 

S.A. de C.V.

León, Guanajuato Waste 

Collection

56211 7,425 AMEBD1102011 -- 42.89 48.00 42.89

12 Reciclajes y 

Destilados 

Monterrey, 

S.A. de C.V.

García, 

Nuevo León

Waste 

Collection

56211 4,267 RDMQ71901811 0.00 -- -- --

 Table 1-1.

Facility Name Location NAICS Capacity 

(tons)

PRTR ID PRTR Reported Air Emissions of Lead 

(and/or its compounds) (kg)

Description Codes 2007 2008 2009 2010
10

MEXICO – RETC data not available

13 Industrial 

Mondelo, S. de 

R.L. de C.V.)

Naucalpan 

de Juárez, 

Estado de México

180,000

14 Metalúrgica 

Xicohténcatl, 

S. de R.L. de C.V.

Tlaxco, Tlaxcala 65,515

15 South American 

Metals,

S. de R.L. de C.V.

Ciudad Juárez, 

Chihuahua

24,000

16 Martha Alicia 

Boites Jiménez

León, Guanajuato 17,100

17 Versisa, 

S.A. de C.V.

Soledad Graciano 

Sánchez, San 

Luis Potosí (SLP)

16,000

18 Omega Solder 

México, 

S.A. de C.V.

San Luis Potosí, 

SLP

10,700

19 Fundametz 

México, 

S.A. de C.V.

San Luis Potosí, 

SLP

10,094

20 Sion 

Acumuladores, 

S.A. de C.V.

El Salto, Jalisco 7,500

21 Funofec, 

S.A. de C.V.

Tizayuca, Hidalgo 5,100

22 Dian Procesos 

Metalúrgicos, 

S.A de C.V.

Tlajomulco, 

Jalisco

4,320

23 Transformadora 

del Centro 

de Michoacán 

“Eric Bobadilla”

(Morelia, 

Michoacán)

3,000

24 Productos 

Metalúrgicos 

Poblanos, 

S.A. de C.V.

Huejotzingo, 

Puebla

2,000

25 Industria de 

Acumuladores 

Jalisco 

(reportedly closed 

by Profepa in 2012)

Tlaquepaque, 

Jalisco

Notes: 0.00 kg means the facility reported in the amount of 0 kg; whereas (--) means there is no PRTR report for the facility for the given year/s.

Capacity volumes for Mexico from: <http://tramites.semarnat.gob.mx/images/stories/menu/empresas/rubro1.pdf> (consulted 21/09/2012). 

Introduction

 Table 1-1.

[1] From Title V Permit, unclear if this is actual production or capacity

[2] Maximum Capacity from Title V Permit

[3] May 2010 Operating Permit

[4] Maximum Operating Rate from Title V Permit. This plant is currently idle.

[5] USGS survey information. This facility plans to close by the end of 2012

and transfer the capacity from this facility to other Exide plants.

[6] Maximum rated capacity from Title V Permit

[7] Maximum Operating Rate from Title V Permit

[8] After recent expansion

[9] From Title V Permit

[10] From Title V Permit

[11] From Title V Permit

[12] Estimate provided by RSR to Secretariat

[13] Maximum production capacity from EPA ICR response

Facility Name Location NAICS Capacity 

(tons)

PRTR ID PRTR Reported Air Emissions of Lead 

(and/or its compounds) (kg)

Description 5 Codes 2007 2008 2009 2010
 Hazardous Trade? 11

Map 1-1a Facilities Processing Spent Lead-acid Batteries (SLABs) in Canada and the United States

Map reflects US facilities in operation in 2012.

Projection: Lambert Azimuthal Equal Area

± 0 200 400 km

Canada

1 Teck Trail Operations Trail, British Columbia

2 Xstrata Zinc- Brunswick Belledune, New Brunswick

3 Newalta Ste-Catherine, Quebec

4 Tonolli Mississauga, Ontario

5 Metalex Products Ltd. Richmond, British Columbia 

United States

1 The Battery Recycling Company Arecibo, Puerto Rico

2 Buick Resource Recycling (Doe Run) Boss, Missouri 

3 East Penn Manufacturing Co., Inc. Lyon Station, Pennsylvania 

4 Exide Technologies Inc. - Facility 1 Muncie, Indiana

5 Exide Technologies Inc. - Facility 2 Vernon, California

6 Exide Technologies Inc. - Facility 4 Baton Rouge, Louisiana 

7 Exide Technologies Inc. - Facility 5 Canon Hollow, Missouri

8 Exide Technologies Inc. - Facility 6 Frisco, Texas

9 Exide Technologies Inc. - Facility 7 Reading, Pennsylvania

10 Gopher Resource Eagan, Minnesota

11 Gopher Resource - Envirofocus Technologies Tampa, Florida

12 Johnson Controls Inc. Florence, South Carolina 

13 RSR Corporation, Quemetco Facility 1 City of Industry, California

14 RSR Corporation, Quemetco Facility 2 Indianapolis, Indiana

15 RSR (Revere Smelting & Refining Corp.) Middleton, New York

16 Sanders Lead Company Troy, Alabama 

Puerto Rico

1

2

7

8

5

6

10

9 3

15

5

2

3

4

4 14

13

16

11

12

1

+ –
12

Map 1-1b Facilities Processing Spent Lead-acid Batteries (SLABs) in Mexico

Projection: Lambert Azimuthal Equal Area

± 0 100 200 km

10

5 2 3 6

1 12

17

18

15

13

19

1611

8

9

7

4

23 21 14

25 22

20

24

Mexico

1 Enertec México, S. de R.L. de C.V. Ciénega de Flores, Nuevo León

2 Enertec México, S. de R.L. de C.V. García, Nuevo León

3 Recicladora Industrial de Acumuladores, S.A. de C.V. Santa Catarina, Nuevo León

4 Corporación PIPSA, S.A. de C.V. García, Nuevo León

5 M3 Resources México, S. de R.L. de C.V. Reynosa, Tamaulipas

6 Eléctrica Automotriz Omega, S. A. de C.V. Planta Doctor González, Nuevo León 

7 La Batería Verde, S.A. de C.V. Tezoyuca, Estado de México

8 Productos Metalúrgicos Salas, S.A. de C.V. Aguascalientes, Aguascalientes

9 Óxidos y Pigmentos Mexicanos, S.A. de C.V. Tijuana, Baja California

10 Hornos de Fundición, S.A. de C.V. Valle Hermoso, Tamaulipas

11 Aleaciones Metalúrgicas, S.A. de C.V. León, Guanajuato

12 Reciclajes y Destilados Monterrey, S.A. de C.V. García, Nuevo León

13 Industrial Mondelo, S. de R.L. de C. V. Naucalpan de Juárez, Estado de México

14 Metalúrgica Xicohténcatl, S. de R.L. de C.V. Tlaxco, Tlaxcala

15 South American Metals, S. de R.L. de C.V. Ciudad Juárez, Chihuahua

16 Martha Alicia Boites Jiménez León, Guanajuato

17 Versisa, S.A. de C.V. Soledad Graciano Sánchez, San Luis Potosí

18 Omega Solder México, S.A. de C.V. San Luis Potosí, SLP

19 Fundametz México, S.A. de C.V. San Luis Potosí, SLP

20 Sion Acumuladores, S.A. de C.V. El Salto, Jalisco

21 Funofec, S.A. de C.V. Tizayuca, Hidalgo

22 Dian Procesos Metalúrgicos, S.A. de C.V. Tlajomulco, Jalisco

23 Transformadora del Centro de Michoacán “Éric Bobadilla” Morelia, Michoacán

24 Productos Metalúrgicos Poblanos, S.A. de C.V. Huejotzingo, Puebla

25 Industria de Acumuladores Jalisco Tlaquepaque, Jalisco

+ –

Introduction
 Hazardous Trade? 13

process SLABs in Canada and the United States 

(Map 1-1a) and Mexico (Map 1-1b).

In Canada, there are three secondary 

smelters and two facilities that combine 

primary and secondary smelting. According 

to the 2010 Minerals Yearbook issued by the 

US Geological Survey (USGS), secondary lead 

production totaled 167,042 t in 2010.

34

In the United States, at the end of 2011, 

eight companies were operating 15 domestic 

secondary lead smelters.35 Because some 

secondary smelters withhold capacity information as confidential, the CEC Secretariat 

was unable to determine the estimated 

US secondary lead production capacity. In 

2011, however, secondary smelters in the 

United States produced about 1,200,000 t 

of lead.36

In Mexico, the CEC Secretariat has 

identified, based on information provided 

by Mexico’s Secretariat of Environment and 

Natural Resources (Secretaría de Medio 

Ambiente y Recursos Naturales—Semarnat), 

25 authorized secondary smelters with a 

permitted capacity to process 1,337,171 t 

of SLABs (see Table 1-1, above).37 The 2010

Minerals Yearbook puts Mexico’s annual 

production at 110,000 t, a figure that industry 

sources indicate is low and does not reflect 

the increased capacity that has come on 

line in Mexico since 2010.

38 The authorized 

capacity will always be much greater than 

actual capacity because industry wants to 

have growth potential built into its permits. 

If smelters in Mexico are currently operating 

in the range of 50 percent capacity, as some 

industry sources have suggested, Mexico’s 

industry would be processing close to 668,585

t of SLABs each year, and its production levels 

of lead would be around 401,151 t.39

34 Guberman, 2010 Minerals Yearbook, Lead, 42.16. 35 See Table 1-1. The list of 15 smelters producing lead in 2011 does not include Johnson Control’s facility in Florence, South Carolina, which began production in 

2012. It does include Exide’s Frisco, Texas, facility, which Exide closed in late 2012, its Baton Rouge, Louisiana, facility, which is currently not recycling batteries and 

is conducting minimal recycling operations, and Exide’s Reading, Pennsylvania, facility, which Exide plans to close by March 2013. 36 US Geological Survey, Minerals Commodity Summaries, 2012 (Washington, DC: US Department of the Interior, US Geological Survey, January 2012), p. 90. 37 The list of secondary smelters in Table 1-1 includes facilities registered as recyclers, as well as smelters. Information provided by Semarnat, e-mail from Óscar Trejo 

Cuevas, Subdirector of Licencia Ambiental Única, to Marco Heredia, CEC Secretariat program manager, 26 October 2012. 38 Guberman, 2010 Minerals Yearbook, Lead, 42.6. 39 Lead-acid batteries are usually between 58 and 65 percent lead alloy by weight. This estimate of 401,151 t was derived by taking 60 percent of 668,585. Photo: Profepa
14

In addition to authorized capacity, 

industry sources have suggested that an 

unknown number of small, unregulated 

secondary lead smelters are operating 

in Mexico. The CEC Secretariat is unable 

to document the extent of such activity, 

although the Office of the Federal Attorney 

for Environmental Protection (Procuraduría 

Federal de Protección al Ambiente—Profepa), 

Mexico’s environmental enforcement agency, 

forced the closure of at least one unauthorized secondary lead smelter in 2012 and has 

undertaken various actions, including inspections of transportation, storage, recycling 

and import/export documentation for SLABs 

or lead. A summary of Profepa’s inspection 

and enforcement action in 2011 and 2012

SLAB imports and handling is presented in 

Appendix 1. 

Industry Trends

Over the last 40 years, the SLAB recycling 

business in the United States has undergone significant consolidation. In 1969, the 

United States had 154 smelters, including five 

primary plants, and 18 manufacturers and 

foundries that produced 547,849 t of lead.40

In 2011, by contrast, 15 secondary smelters 

produced about 1,200,000 t of lead in the 

United States.41

Increasingly stringent environmental 

regulations have increased capital costs and 

process improvements, which in turn have 

been a factor in forcing smaller and less 

profitable or lower-capitalized smelters out 

of business. 

The remaining smelters are demonstrating higher environmental performance, 

as well as greater volumes and efficiencies 

of scale. Although the absolute numbers of 

individual smelters have greatly contracted, 

globally as well as in North America, the 

overall capacity of the remaining operations 

has increased substantially. This in turn has 

increased the competition to secure sufficient 

numbers of SLABs to provide for efficient 

recycling and supplies of refined lead for 

battery manufacturing.

The same consolidation and industrial 

transition that have occurred in both Canada 

and the United States may also be on the 

verge of occurring in Mexico, albeit for 

different reasons. Mexico’s 25 authorized 

smelters have a permitted capacity ranging 

from 2,000 to 254,000 t per year. Of these 

smelters, 15 have a capacity of less than 

30,000 t. During the CEC Secretariat’s 

interviews with industry officials and others 

in conjunction with this study, many representatives of smelters in Mexico and lead 

analysts indicated that smaller smelters are 

having difficulties obtaining SLABs at a price 

and in a quantity to make their operations 

profitable. Indeed, many reported operating 

at no more than 50 percent capacity. Several 

industry observers believe that, because of 

the diminishing margin between the cost of 

SLABs and the LME price of lead, together 

with the apparent overcapacity in the Mexican 

industry, industrial consolidation appears 

unavoidable, and many of the unprofitable 

smaller smelters will be forced out of business in the coming years.

Vertical integration and internationalization are also becoming more common in the 

industry.42 In North America, many companies have some level of vertical integration 

or otherwise have established continental 

supply chains. For example, four major 

North American battery manufacturers—Exide 

40 Donald E. Moulds, Bureau of Mines, Minerals Yearbook, Vol. 1–2, Metals, Minerals, and Fuels 1969, Ecology and Natural 

Resources Collection, 1968, p. 627 (citing production of 603,900 short tons, which is equivalent to 547,849 metric tons using a 

conversion of 0.90718474), <http://digicoll.library.wisc.edu/cgi-bin/EcoNatRes/EcoNatRes-idx?type=turn&entity=EcoNatRes.

MinYB1969v1and2.p0635&id=EcoNatRes.MinYB1969v1and2&isize=M>. 41 See notes 35 and 36. 42 Vertical integration, which occurs when battery manufacturers own the smelters and control the networks that collect and 

transport SLABs to the smelter, either directly or through contracts, is a way in which battery manufacturers can control costs and 

acquire the flexibility they need to manage their supply of SLABs.

In North America, 

many companies 

have some 

level of vertical 

integration or 

otherwise have 

established 

continental 

supply chains.

’

’

Introduction
 Hazardous Trade? 15

Technologies Manufacturing Company 

(Exide), Johnson Controls Inc. (JCI), East 

Penn Manufacturing and Grupo Gonher de 

México (Gonher)—have vertical integration 

in their supply chains. Exide, the secondlargest lead-acid battery manufacturer in the 

world, operates seven battery manufacturing 

plants43 and six secondary lead smelters in 

the United States.44

JCI, the largest battery manufacturer 

in the world, produces batteries at plants 

in the United States and in Mexico. As part 

of its integrated North American business, 

it operates two secondary lead smelters 

in Mexico and one in the United States. In 

Mexico, it maintains a system of retailers 

that sell and replace JCI-produced batteries. 

East Penn Manufacturing operates a battery 

manufacturer and a smelter in Pennsylvania.45

In Mexico, it maintains a tolling agreement 

with Recicladora Industrial de Acumuladores, 

S.A. de C.V. (RIASA), a division of Gonher. 

Under this agreement, SLABs are shipped 

from the United States to Gonher’s secondary 

lead smelter near Monterrey, Nuevo León, 

and refined lead is returned to Pennsylvania. 

Gonher, for its part, also manufactures bat-

teries adjacent to its Monterrey smelter.46 M3 Resources of Birmingham, Alabama, 

operates a smelter in Reynosa, Mexico, 

under Mexico’s temporary import regime 

program—IMMEX—previously known as the 

maquiladora program.47

43 Exide Technologies, “Exide’s Worldwide Facilities,” <http://www.exide.com/en/about/locations.aspx

>. 

Exide’s secondary lead smelter in Frisco, Texas, 

will close in late 2012. 44 America’s Battery Recyclers, “Member Recycling 

Companies,” <http://www.americasbatteryrecyclers.com/

association.html>. 45 See <http://www.dekabatteries.com/

>. 46 For RIASA, see <http://www.grupogonher.com/_

ScriptLibrary/XSite.Esp/GrupoGonher/riasa.htm>. 47 Interview with Tom Mayfield, president, M3 Resources USA 

LLC, 15 August 2012.

Photo: Profepa
2
 Hazardous Trade? Hazardous Trade? 17

International Framework 

for Managing the Trade 

in SLABs

In Canada, Mexico and the United States, SLABs are considered 

hazardous waste.48 The trade in SLABs is therefore subject to 

bilateral agreements between the United States and Canada and the 

United States and Mexico. 

This framework provides for a notice and 

consent process, which allows countries to 

object to the shipment of hazardous waste.

Despite this framework, one important difference between the countries is that the 

United States, unlike Canada and Mexico, 

does not require a hazardous waste manifest 

to accompany each shipment of SLABs. 

International Agreements

The United States has separate bilateral 

agreements with Canada and Mexico on 

trading hazardous waste because the 

United States is not a party to the Basel 

Convention on the Control of Transboundary 

Movements of Hazardous Wastes and Their 

Disposal.49 The convention states that parties to the convention, such as Mexico and 

Canada, should not trade with nonparties to 

the convention unless a bilateral agreement 

is in place.50

In addition to these bilateral agreements, 

all three countries are members of the 

Organisation for Economic Co-operation and 

Development (OECD). OECD has adopted 

a number of decisions on the movement of 

hazardous waste that apply to member countries. One OECD decision requires contracts 

between the exporter and the recycling facility 

and the use of “movement documents” or 

manifests to accompany hazardous waste 

shipments.51 It also requires facilities recycling the waste to provide notice of receipt 

of the wastes and issue a “certificate of 

recovery” upon completion of recycling.52 The 

United States does not follow this decision 

because, as noted, it does not require manifests to accompany SLAB shipments or other 

hazardous waste destined for recovery, and 

it does not require recycling facilities to issue 

a certificate of recovery upon completion 

of recycling.

48 SLABs exhibit characteristics of toxicity and corrosivity. In addition, the sulfuric acid in SLABs can volatilize and explode. 49 Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal, 

<http://www.basel.int/convention/about.html>. 50 Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal, art. 4, 5 May 1992, 

General Obligations, Text of the Basel Convention, <http://www.basel.int/text/con-e-rev.doc>. 51 Organisation for Economic Co-operation and Development, “Decision of the Council Concerning the Control of Transboundary 

Movements of Wastes Destined for Recovery Operations,” OECD Doc. C (2001) 107/FINAL, 14 June 2001 (amended 2002, 2004, 

2005, 2008), ch. II(D)(2), Case 1(j), <http://webnet.oecd.org/oecdacts> (hereafter OECD Decision). 52 Ibid. 
18

Import and Export Controls

The US-Canada53 and US-Mexico54 agreements 

establish procedures for a governmentto-government export notice and consent 

process for the shipment of hazardous waste, 

including SLABs. This process consists of the 

following steps: 

 An exporter must submit a “notice of 

intent” to export SLABs to the environmental authority of the country in which 

the exporter is located. This notice lists the 

type and anticipated amount of waste to 

be shipped, the receiving facility and the 

specified time period of up to 12 months.

 The exporting country’s environmental 

authority forwards the notice of intent to 

the importing country, which can consent 

or object to the shipments.

 The importing country then sends the 

approval or objection back to the exporting 

country’s environmental authority.

 The exporting country’s environmental 

authority sends the approval (in the form 

of a consent or a permit) or the objection 

to the exporter. 

Although the US-Canada agreement presumes 

consent if no objection or conditions are 

imposed within 30 days of receipt of notice,55

in practice, the US does not presume consent 

and requires that Canada provide written consent before an Acknowledgement of Consent 

document is issued to the US exporter.56 In 

the US-Mexico agreement, notification must 

be provided to the designated government 

authority at least 45 days prior to shipment, 

and consent is not presumed if a government 

fails to respond to the notice.57 In addition, a 

copy of the notification has to be sent “simultaneously through diplomatic channels.”58

In 2012, the environmental agencies in 

Canada, Mexico and the United States began 

to share electronically export requests and 

consent documents for hazardous waste 

exports, including SLABs, through the Notice 

and Consent Electronic Data Exchange 

(NCEDE) project. This system is replacing a 

paper-based system in which governments 

exchange notice and consent information by 

mail, fax and cable.59

In each of the three countries, exporters 

of SLABs must report back to the environmental authority on an annual basis on the 

amounts of SLABs exported, as well as the 

destination country and recycling facility.

Transporting SLABs

In each of the three countries, handlers 

that store SLABs must adhere to the standard management practices prescribed in 

regulations. Transport regulations include 

requirements for when hazardous materials 

placards must be placed on a vehicle, how 

the SLABs must be wrapped and stacked, and 

what hazardous material documentation must 

accompany the shipment.60

In Canada and Mexico, a hazardous 

waste manifest61 must accompany each 

shipment. In the United States, SLABs are 

also categorized as universal waste, a designation intended to streamline hazardous 

waste management standards. The universal 

waste regulations of the US Environmental 

Protection Agency (USEPA) exempt generators, transporters and disposal facilities 

handling SLABs from hazardous waste manifesting requirements. USEPA’s rationale for 

establishing this exemption is that it encourages recycling by reducing the regulatory 

burden on those companies recycling SLABs.62

In 2012, the 

environmental 

agencies 

in Canada, 

Mexico and the 

United States 

began to share 

electronically 

export requests 

and consent 

documents 

for hazardous 

waste exports, 

including 

SLABs, through 

the Notice 

and Consent 

Electronic 

Data Exchange 

(NCEDE) project. 

’

’

53 Agreement Between the Government of the United States of America and the Government of Canada Concerning the 

Transboundary Movement of Hazardous Waste, 28 October 1986, <http://www.epa.gov/osw/hazard/international/canada86and92.pdf> (hereafter US-Canada Agreement). 54 Annex III to the Agreement on Cooperation for the Protection and Improvement of the Environment in the Border Area, Agreement 

of Cooperation Regarding the Transboundary Shipments of Hazardous Wastes and Hazardous Substances, 12 November 1986, 

<http://www.epa.gov/osw/hazard/international/mexico86.pdf> (hereafter US-Mexico Agreement). 55 US-Canada Agreement, Art. Sec. 3(d). 56 Comments received from the USEPA, 21 December 2012, p. 2. 57 US-Mexico Agreement, para. 4. 58 US-Mexico Agreement, para. 1. 59 <http://www.cec.org/Page.asp?PageID=924&ContentID=25234>. 60 Art. 86, Reglamento to the Ley General para la Prevención y Gestión de los Residuos (LGPGIR). See <http://www.diputados.gob.

mx/LeyesBiblio/regley/Reg_LGPGIR.pdf>. 61 A manifest is a form prepared by generators who transport, or offer for transport, hazardous waste for off-site treatment, 

recycling, storage or disposal. A paper document with multiple copies of a single form, it contains information on the type and 

quantity of the waste being transported, instructions for handling the waste, and signature lines for all parties involved in the 

transport, handling, and disposal process. Each party that handles the waste signs the manifest and retains a copy for itself. 62 See US Environmental Protection Agency, Hazardous Waste Recycling and Universal Wastes, Chapter III: Managing Hazardous 

Waste—RCRA Subtitle C, <http://www.epa.gov/wastes/inforesources/pubs/orientat/rom32.pdf>.

International Framework for Managing the Trade in SLABs
 Hazardous Trade? 19

Improving the North American

Framework for Managing the

Trade in SLABs

Canada, Mexico and the United States could 

improve the North American framework for 

managing the trade in SLABs in at least three 

ways. First, the United States should require 

the use of manifests for each international 

shipment of SLABs, and it should require 

exporters to obtain a certificate of recovery 

from foreign recycling facilities. This will allow 

end-to-end tracking of SLAB shipments across 

borders and help ensure they are recycled in 

accordance with international authorizations.

Second, the United States should explore 

the establishment of a system that would 

allow exporters to submit annual report 

information electronically. Currently, USEPA 

maintains paper copies of annual reports that 

contain information on the amount of SLABs 

that US companies have exported abroad and 

the names of the transporters and receiving 

facilities. (In developing USEPA data for this 

report, the CEC Secretariat and the USEPA created their own databases and populated them 

by manually entering thousands of pieces 

of information from the annual reports.63) 

However, that system is cumbersome and 

resource-intensive, and it draws resources 

from the USEPA’s goal of ensuring that SLAB 

exports comply with US law. 

Finally, Canada, Mexico and the 

United States should share the import and 

export data maintained by their respective environmental and border agencies on 

an annual basis. This information sharing 

could be used to identify trends that may 

require a policy response or that may raise 

compliance issues.

63 These data can be found at <http://www.cec.org/slabs>.
3
 Hazardous Trade? Hazardous Trade? 21

In order to better understand the trade flows in SLABs, the CEC 

Secretariat examined trade data from the environmental agencies of 

all three countries and from the US Census Bureau.64 Our review of 

US trade data indicates a rapid increase in exports of SLABs from the 

United States to Mexico since 2004 and significant data abnormalities 

that may indicate compliance issues by some companies exporting 

SLABs from the United States to the rest of the world.

Trade Data

In Canada, Mexico and the United States, 

companies are required to report import and 

export information to the national environmental agencies. For its analysis of trade 

flows of SLABs, the CEC Secretariat collected:

 from Environment Canada, SLAB import 

and export data for 2002–2011;

65

 from Mexico’s Secretaría de Medio 

Ambiente y Recursos Naturales (Semarnat), 

SLAB import and export data for 2006–

2011 and from the Procuraduría Federal de 

Protección al Ambiente (Profepa) for 2011; 

and 

 from the US Environmental Protection 

Agency, trade data from mid-July 2010

when USEPA began collecting this

information.66

In addition, the Secretariat collected US 

Census Bureau import and export data that 

have been classified using the Harmonized 

Tariff Schedule (HTS). The US harmonized 

system provides two specific classification 

codes that cover SLABs exported or imported 

for the recovery of lead: 8548100540, which 

covers starting, lighting, ignition SLABs, and 

8548100580, which covers industrial SLABs.67

The North American 

Trade in SLABs

64 The trade data collected by the CEC Secretariat can be found at <http://www.cec.org/slabs>. The US Census Bureau compiles 

trade data from information submitted to US Customs and Border Protection, and in the case of exports to Canada, import 

documents filed with Canadian agencies and forwarded to the US Census Bureau. See US Census Bureau, “About Foreign Trade 

Programs and Products,” <http://www.census.gov/foreign-trade/about/index.html>. The Secretariat purchased its data from 

the US Census Bureau’s subscription service; see US Census Bureau, “Foreign Trade on Electronic Media,” 

<http://www.census.gov/foreign-trade/reference/products/catalog/orderform.html>; and made corrections to those data 

based upon statistical corrections issued by the US Census Bureau; see US Census Bureau, “Statistical Corrections,” 

<http://www.census.gov/foreign-trade/statistics/corrections/index.html>. The online trade databases found at 

<http://dataweb.usitc.gov/> and at <http://www.usatradeonline.gov> do not contain these statistical corrections. 65 Environment Canada collects annual reports from companies and categorizes exports based on United Nations (UN) Codes 2794

(batteries, wet, filled with acid, electric storage) and 2800 (batteries, wet, nonspillable, electric storage). SLABs do not have a 

stand-alone UN code. These two codes largely overlap with SLABs, although UN Code 2800 can include a wide variety of sealed 

batteries such as lead absolyte batteries, which would include batteries such as sealed cell batteries with lead in the electronic 

industry (home alarm system, power supplies unit, road and railroad signal system, etc.). 66 Applicability and Requirements, 40 C.F.R. sec. 266.80(a) (effective 7 July 2010); OECD requirements: Export Shipments of Spent 

Lead-Acid Batteries, 75 Federal Register, 1236–1262 (8 January 2010), 1244, 1261. 67 Harmonized Tariff Schedule (HTS) of the United States, <http://hts.usitc.gov/>. The HTS has three other lead scrap–related 

codes: 7802000030 (lead waste and scrap obtained from lead-acid storage batteries), 7802000060 (lead waste and scrap other 

than that obtained from lead-acid storage batteries) and 8548102500 (waste and scrap primary cells, primary batteries and 

electric storage batteries for the recovery of lead, not specified elsewhere).
22

Figures 3-1–3-4 provide an overview of the US trade data collected by the Secretariat.

Source: Figure based on compilation of export data collected by US Census Bureau under the harmonized tariff codes 854800540 (starting, lighting, ignition SLABs) 

and 8548100580 (industrial SLABs).

FIGURE

+ –

3-1 US Exports of SLABs to Canada, Mexico and All Other Destinations, 2002–2011

YEAR

2002 2003 2004 2005 2006 2007 2008

Millions of kg

500

450

400

350

300

250

200

150

100

50

0

2009 2010 2011

Canada

Mexico

Total World Exports

Source: Environment Canada. Figure based on compilation of export/import data collected by Environment Canada based on United Nations (UN) Codes 2794

(batteries, wet, filled with acid, electric storage) and 2800 (batteries, wet, nonspillable, electric storage).

FIGURE

+ –

3-2 Canada: Trade in SLABs to and from the United States, 2002–2011 Millions of kg 140

120

100

80

60

40

20

0

YEAR

Imports

Exports

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

The North American Trade in SLABs
 Hazardous Trade? 23

The sections that follow describe specific 

findings from the trade data and the data reliability and compliances issues that emerged.

Global US Exports

 In terms of the global volume of SLABs 

exported by the United States, according 

to USEPA data, Mexico is the leading destination (68 percent), followed by Canada 

(19 percent) and Korea (13 percent).

 According to both USEPA and US Census 

Bureau data, other countries receiving 

US-generated SLABs in 2011 were Peru, 

the Philippines, Spain and the United 

Kingdom. However, US Census Bureau 

data indicate that SLABs were also 

shipped to 47 other countries, including 

China, Colombia, Dominica, Dominican 

Republic, Germany, Honduras, Jamaica, 

Panama, Trinidad and Venezuela. USEPA 

did not have notice and consent information for shipments to these countries.68

68 For a complete list of the 47 countries, see Appendix 2.

Units: Millions of kg (% of total, rounded). 

Source: USEPA. Figure based on compilation of data from annual reports submitted to USEPA by firms exporting SLABs.

FIGURE

+ –

3-3 US Exports of SLABs, by Destination, 2011 (USEPA)

Mexico, 389.5

68%

Canada, 108.0

19%

S. Korea, 72.3

13%

Spain, 1.3

0.2%

Peru, 0.5

0.1%

UK, 0.09

0.0%

Philippines, 0.03

0.0%

+ –

FIGURE 3-4 US Exports of SLABs, by Destination, 2011 (US Census Bureau)

Mexico, 342.2

74%

Canada, 104.8

23%

Spain, 9.4

2%

S. Korea, 1.2

0.3%

Rest of World, 2.2

0.5%

Units are: Millions of kg (% of total, rounded). 

Source: Figure based on compilation of data collected by US Census Bureau of exports under the harmonized tariff codes 

854800540 (starting, lighting, ignition SLABs) and 8548100580 (industrial SLABs).
24

US-Mexico Trade in SLABs

 According to USEPA data, in 2011 the 

United States exported 389,539,362 kilograms (kg) of SLABs to Mexico. According 

to US Census Bureau data, in 2011 the 

United States exported 342,186,978

kg of SLABs to Mexico and imported 

191,341 kg. 

 The USEPA export figure exceeds the 

US Census Bureau export figure by 

47,352,382 kg, indicating that exporters 

of SLABs may not be correctly classifying 47,352,382 kg of SLABs under the 

harmonized tariff code system. 

 We estimate that from 2004 to 201169

US exports to Mexico increased between 

44970 and 525 percent.71

 The majority of the increase in SLAB 

exports is attributed to the business 

development of JCI. In 2004, JCI’s subsidiary in Mexico, Enertec, acquired Ciénega, 

a smelter near Monterrey, Mexico, and 

began directing SLABs to that facility 

for recycling. In 2011, JCI opened a new 

secondary smelter in García, also near 

Monterrey. According to USEPA data, 

in 2011 JCI’s operations at Ciénega

accounted for 43 percent of all US SLAB 

exports to Mexico, and García accounted 

for 31 percent (see Table 3-1). 

 The remaining 26 percent of the authorized exports of US-generated SLABs is 

sent to seven facilities in three states 

in Mexico (Nuevo León, Baja California, 

and Tamaulipas). These seven facilities 

imported 100,669,466 kg of SLABs in 2011.

 We estimate that in 2011, 12–18 percent of all lead in US-generated SLABs 

was recycled in Mexico,72 and that 

30–60 percent of all SLABs recycled in 

Mexico came from the United States.73

US-Canada Trade in SLABs

 In 2011, according to Environment Canada 

data, the United States was a net exporter 

of SLABs to Canada by 86,987,630 kg. 

It exported 119,144,435 kg of SLABs to 

Canada and imported 32,156,805 kg of 

SLABs from Canada. Between 2004 and 

2011, US net exports to Canada increased 

221 percent.74

 Two secondary lead smelters in Ontario 

(Tonolli Canada) and Quebec (Newalta) 

accounted for about 93 percent of these 

imports in 2011 (see Table 3-2).75

69 Although the CEC Secretariat collected trade data from 2002 to 2011, statistically corrected trade data are not available for 2002 and 2003. See <http://www.

census.gov/foreign-trade/statistics/corrections/index.html>. This has relevance for calculating SLAB exports and the accuracy of the US Census Bureau data. For 

example, between 2004 and 2009 about 95 corrections were made to SLAB export data. According to the Secretariat’s calculations, statistical corrections in 2004

resulted in an additional 3,211,248 kg being classified as SLAB exports to Mexico under the 8548100540 code; in 2005, 4,108,877 kg; in 2006, 5,057,829 kg; in 

2007, 2,133,244 kg; in 2008, 341,204 kg; and in 2009, 328,936 kg. Because corrections are not available for 2002 and 2003, SLAB exports for the 8548100540

code may have been underreported, as they were from 2004 through 2009. 70 This percentage increase was calculated using US Census Bureau numbers. In 2004, US Census Bureau data indicate SLAB exports were 62,349,588 kg; in 2011

they were 342,186,978 kg. 71 This percentage increase was calculated using the US Census Bureau import number for 2004, 62,349,588 kg, and USEPA number for 2011, 389,539,362 kg. 72 Occupational Knowledge International (OKI) estimates that in 2010, 12 percent of all US lead was being exported to Mexico in lead batteries. See Occupational 

Knowledge International and Fronteras Comunes, Exporting Hazards, appendix G, for OKI’s calculations. The CEC Secretariat arrived at a figure of 18 percent, using 

the following calculation. The lead in batteries consumed domestically from 2007 to 2011 amounted to 14,246,696,956 pounds (Battery Council International, 

National Recycling Rate Study, May 2012, 7), or 6,462,193,036 kg. If the battery lead available from 2007 to 2011 is divided by 5, then 1,292,438,607 kg were available for lead recycling per year between 2007 and 2011. In 2011, according to the US Census, 389,539,362 kg of SLABs were exported to Mexico. Assuming that 

about 60 percent of each battery contains lead available for recycling, 233,723,617 kg of lead were sent to Mexico for recycling. If 1,292,438,607 kg were available 

for lead recycling per year in the United States and 233,723,617 kg were going to Mexico, about 18 percent of the lead from SLABs was going to Mexico. 73 The 30–60 percent was calculated in the following manner. The authorized capacity for process inputs, or SLABs, in Mexico at permitted secondary lead smelters 

is 1,337,171 t per year. The United States exported 389,539,362 kg of SLABs to Mexico in 2011. If Mexican facilities were operating at full capacity, 389,539,362

kg would be 30 percent of Mexico’s authorized capacity of 1,337,171 t, and about 60 percent of Mexico’s process inputs if they were operating at half-capacity, or 

650,035,000 kg. 74 See North American SLAB Trade Data at <http://www.cec.org/slabs>. 75 The CEC Secretariat believes that Environment Canada data more accurately reflect the actual trade in SLABs over time than US Census data. USEPA and 

Environment Canada have slightly different trade figures (see Figures 3-2 and 3-3). For the purposes of this report, we are using Environment Canada’s data. It is 

possible that exporters of SLABs to Canada from the United States were classifying SLABs under the wrong harmonized tariff code prior to USEPA’s implementation 

of notice and consent requirements and annual report requirements for SLAB exports in 2010. 

The North American Trade in SLABs
 Hazardous Trade? 25

 At least prior to 2010, US Census Bureau 

data may not be a reliable indicator of the 

historical trade in SLABs to Canada. The 

CEC Secretariat believes that prior to 2010

US exporters sometimes improperly classified SLAB exports under harmonized tariff 

code 8548102500.

76

 We estimate that US net exports to Canada 

in 2011 represent about 4 percent of all 

lead in US-generated SLABs77 and that the 

net export of SLABs from the United States 

accounted for about 31 percent of 

Canadian secondary lead production.78

These SLAB trade flows between the three 

countries are shown in Map 3-1.

Table 3-1. Facilities in Mexico Receiving Spent Lead-acid Batteries from the United States in 2011

Receiving facility Government annual report data on US to Mexico SLAB exports/imports (kg)

Semarnat

Profepa

(approximate volume 

registered at Sirev)a USEPA

Enertec México, S. de R.L. de C.V. (Ciénega) 77,483,005 72,318,200 (Ciénega) 168,942,895

(García) 82,165,474 203,261,640 (García) 119,927,000

(Total Enertec) 159,648,479 (Total Enertec) 275,579,840 (Total Enertec) 288,869,895

M3 Resources México, S.A. de C.V. 36,041,154 33,476,790 34,983,765

Recicladora Industrial 

de Acumuladores 20,021,080 40,489,860 26,113,327

Corporación Pipsa, S.A. de C.V. 8,131,680 19,422,610 19,867,870

Óxidos y Pigmentos 

Mexicanos, S.A. de C.V. No data cited 8,611,230 9,601,802

Pesquería (previously, Eléctrica Automotriz 

Omega, S.A. de C.V.) 1,191,836 8,778,980 8,705,664

Omega Solder México, S.A. de C.V. No data cited 1,287,440 1,286,515

Hornos de Fundición, S.A. de C.V. No data cited 110,520 110,522

Total, environmental agency data 225,034,229 387,757,270 389,539,360

Total, US Census Bureau data, HTS 

codes 8548100540 and 854800580 342,186,978

Total, US Census Bureau data 

(total of 5 HTS codes related to 

lead scrap and lead batteries)b 343,016,255

Source: Data provided by Semarnat and USEPA and compiled by the Secretariat of the Commission for Environmental Cooperation (available at <www.cec.org/

slabs>). Profepa volumes are as reported to the CEC Secretariat in June 2012. See Appendix 3. Differences between Semarnat and US EPA data may stem 

from a difference in reporting dates according to either the fiscal year in which the authorization was issued or shipment dates.

a. Sistema Institucional del Registro de Verificación (Sirev)

b. See note 67 and the accompanying text.

76 In 2006, 2007 and 2008 a large number of exports to Canada were occurring under harmonized tariff code 8548102500, which is a designation for lead-acid 

batteries not specified elsewhere in the harmonized tariff schedule. Industry sources indicate that exports to Canada consist of almost exclusively automobile batteries (8548100540) and industrial batteries (8548100580) and that exports that occurred under harmonized tariff code 8548102500 were most likely automobile 

or industrial batteries. See the yearly amounts reported as US exports to Canada at <http://www.cec.org/slabs>, North American SLAB Trade Data, US Census 

Bureau Trade Data_5_codes_11-16.xlsx, on the tabs for “US Exports,” “Corrections and graphs,” “New data and graphs.” 77 The net export of SLABs to Canada represents about 52,192,578 kg of lead, using 0.6 kg of lead recoverable from every SLAB (86,987,630 kg x 0.6 = 52,192,578

kg). If 1,292,438,607 kg of lead were available for recycling in 2011 (see note 72), 52,192,587 kg represents 4 percent of lead available for recycling. 78 This figure was calculated in the following way: an estimated 52,192,578 kg of lead were recoverable from the net export of 86,987,560 kg of SLABs in 2011. 

According to the 2010 Minerals Yearbook (<http://minerals.usgs.gov/minerals/pubs/commodity/lead/myb1-2010-lead.pdf>), production of secondary lead in 

Canada was 167,042 t, or 167,042,000 kg, and 52,192,578 kg is 31 percent of 167,042,000 kg.
26

Total Canada to US

32,156,805 kg

Total US to Canada

119,144,435 kg

Total US to Mexico 

389,539,360 kg

Total Mexico to US 

191,341 kg

SLAB processing facilities

Map 3-1 North American Imports and Exports of Spent Lead-acid Batteries (SLABs), 2011

Note: US EPA, Environment Canada, US Census Bureau. See Tables 3-1 and 3-2 for distribution and details.

+ –

The North American Trade in SLABs
 Hazardous Trade? 27

Mexico–Canada Trade in SLABs

The CEC Secretariat did not identify any trade 

in SLABs between Mexico and Canada.

Data Reliability and Compliance 

in the United States 

The research carried out by the CEC 

Secretariat revealed data discrepancies that 

may indicate two compliance issues warranting further review by the appropriate US 

government agencies. Until this matter was 

quantified in the course of this research, the 

magnitude of these two issues was unknown 

to regulatory agencies in the United States.

First, as noted previously, our review 

of USEPA data and US Census Bureau data 

indicated that 47,352,382 kg of SLABs 

are being exported to Mexico without 

having the proper harmonized tariff code 

applied(see Table 3-1).79

Second, also as noted previously, our 

review of US Census Bureau data indicates 

that exporters are sending SLABs to countries 

where USEPA has no record of having 

obtained permission from those countries 

to receive the SLABs. To the extent this has 

occurred, it would be a violation of US law80

and most likely a violation of the importing 

countries’ laws.81

Data Reliability across North America

In addition, we note that data on the import 

and export volumes compiled within both 

the US and Mexico by different agencies, in 

Mexico by Semarnat and Profepa and in the 

US by the USEPA and US Census Bureau, 

are not consistent. Moreover, national 

cross-border accounts in all three countries 

do not accord with shipping or receiving 

volumes from either sending or receiving 

countries. Agencies responsible for such 

monitoring within and across borders need 

to work together to identify and improve 

data management issues that exist across 

North America.

79 Our review of US Census Bureau data leads us to conclude that this does not appear to be a situation in which the 47,352,382 kg 

of exports were classified under the wrong lead waste scrap code. The total amount of exports to Mexico under the lead waste 

scrap codes 7802000030 (lead waste and scrap obtained from lead-acid storage batteries) and 780200060 (lead waste and scrap 

other than obtained from lead-acid storage batteries) amounted to 829,277 kg, according to US Census Bureau figures. 80 On 1 July 2005, the secretary of the US Department of Commerce issued 13 U.S.C. 304, 305 and specific regulations in 15 C.F.R. 

30.71(b)(3); 73 Federal Register 31548. 81 Any export of hazardous waste to a non-OECD country without consent of the importing country is a violation of domestic and 

international provisions governing the transboundary movement of SLABs. Refer: Basel Convention Article 6 (1), and 7, and OECD 

Decision 2001 107 Final, amended by C (2004) 20; C(2005) 141, and (2008) 156.

Table 3-2. Facilities in Canada Receiving Spent Lead-acid Batteries from the United States in 2011

Receiving facility Government data on imports (kg)

Environment Canada USEPA

Newalta CBI 67,721,066

Tonolli Canada CBI 32,689,589

KC Recycling* CBI 5,644,356

Xstrata Zinc, Brunswick Smelter CBI 1,952,553

Stablex* CBI 3,520

Total, environmental agency data 119,144,435 108,011,084

Total, US Census Bureau data, 

HTS codes 8548100540 and 8548100580 104,767,399

Total, US Census Bureau data 

(total of 5 HTS codes related to lead and lead batteries) 109,773,061

Note: CBI = Confidential Business Information.

* Stablex and KC Recycling are not secondary lead smelters and are not listed in Table 1-1. Stablex treats and disposes of hazardous waste and KC recycling 

processes and extracts lead from batteries for smelting at Teck. 
28

What Is Driving US

Exports to Mexico?

This discussion of trade evokes a key 

question underlying this study: what is driving 

US exports to Mexico? The CEC Secretariat is 

not able to answer this question definitively. 

However, the cost gap between recycling 

batteries in Mexico versus the United States 

is likely to grow with the implementation of 

stricter air standards in the United States, 

making this question more pertinent.

As part of our public comment process, 

the CEC Secretariat sought comments on two 

questions designed to help us better understand the driving forces behind SLAB exports 

from the United States to Mexico and Canada:

 What forces are driving SLAB exports from 

the United States to Mexico and Canada?

 To what extent are different environmental regulatory requirements and lower 

compliance costs relative to those of the 

United States a factor in increasing the 

recycling of SLABs in Mexico or Canada?

As a result of the aforementioned request for 

comments the Secretariat received input that 

reveals no general consensus on the driving 

forces behind SLAB exports, or whether 

different environmental regulatory requirements and lower compliance costs are the 

determining factors in the increase in SLAB 

recycling in Mexico. These comments are 

publicly available at <www.cec.org/slabs>. 

Some commentators assert that the increase 

in exports to Mexico is driven by weaker environmental regulations and lower compliance 

costs, as well as lower wages and fixed capital 

costs, which allow Mexican smelters to pay 

more for SLABs or offer lower tolling prices 

than their US counterparts. Others found 

no significant regulatory compliance cost 

advantage to operating facilities in Mexico 

compared with those in the United States, 

and argued that other factors, including 

transportation costs and the proximity of the 

smelters to the SLAB sources and the battery 

manufacturing facilities are the dominant cost 

considerations determining where SLABs are 

recycled. One response noted that the location of operating facilities in Mexico is based 

on multiple factors, including consumer 

demand, overall global economic conditions, 

and maintenance of high-quality, efficient performance throughout a facility’s operations. 

Based on our research, we would add 

three observations. First, the trade patterns 

that have seen steady growth in the export 

of US-generated SLABs to both Mexico and 

Canada began several years before the most 

recent tightening of USEPA regulations. 

Moreover, the fact that the provincial jurisdictions where most SLAB recycling occurs 

in Canada have stack and fugitive emission 

requirements and other controls where 

Mexico has none, reinforces the underlying 

importance of market and economic drivers 

for such decisions.

Second, the cost gap between US 

smelters and smelters that operate in Mexico 

and Canada that are not compelled to follow 

US standards and practices is likely to grow 

more pronounced with the new US emissions 

standards for secondary lead smelters set to 

take effect in 2014.

82 The USEPA estimates 

that these standards will require secondary 

lead smelters to incur additional total annualized costs for control measures and workplace 

practices of up to US$13.4 million.83 JCI has 

estimated that these new regulations will 

cost the industry $600 million.84 These costs 

are in addition to improvements made to 

comply with the 1994 emissions standards for 

secondary smelters. At the time, USEPA estimated that those improvements would result 

in a national annualized cost of $2.8 million, 

including $1.86 million for the installation of 

control devices and $0.93 million in monitoring, reporting and recordkeeping costs.85

82 “National Emissions Standards for Hazardous Air Pollutants from Secondary Lead Smelting,” 77 Federal Register 556

(5 January 2012). 83 Ibid., 576. In 2009 dollars; costs vary depending on the smelter. 84 Karen Norton, “Rising Lead Recycling Costs May Prompt Cutbacks,” Reuters, 26 March 2012, 

<http://www.reuters.com/article/2012/03/26/us-metals-lead-environment-idUSBRE82P0HC20120326>. Johnson 

Controls announced it would raise the price of its lead-acid batteries sold in the United States and Canada by 8 percent because of the rising environmental and safety costs and that it was “investing $162 million in its North American 

recycling centers to make them compatible with recommended environmental standards.” The company said this move 

was in response to EPA’s tightened environmental, health and safety regulations. See “Johnson Controls Raises Battery 

Prices to Charge Up Margins,” Forbes, 20 March 2012, <http://www.forbes.com/sites/greatspeculations/2012/03/20/

johnson-controls-raises-battery-prices-to-charge-up-margins/>. 85 “National Emission Standards for Hazardous Air Pollutants from Secondary Lead Smelting,” 60 Federal Register 32587, 32591

(23 June 1995). 

...the cost gap 

between US 

smelters and 

smelters that 

operate in 

Mexico and 

Canada that are 

not compelled 

to follow US 

standards and 

practices is likely 

to grow more 

pronounced 

with the new 

US emissions 

standards for 

secondary 

lead smelters...

’

’

The North American Trade in SLABs
 Hazardous Trade? 29

Third, as several industry sources noted 

to us, in the secondary lead smelting business 

it is critical to take a 10-year measure of the 

costs of operation in order to factor in the corrosive consequences of dealing with lead and 

the need to undertake ongoing maintenance, 

repairs and capital replacements. In Mexico, 

where many smelters are undercapitalized, 

may not be making sufficient profit, and are 

operating in an environment in which no regulatory requirements are forcing capital repairs 

or improvements in process technology, some 

smelters will be unable to maintain—let alone 

improve—their environmental management.

Because of the lack of public data on 

the economics of secondary lead recycling in 

North America, the CEC Secretariat is unable 

to determine with certainty the extent to 

which different environmental regulatory 

requirements and lower compliance costs 

relative to those of the United States are the 

deciding factors in increasing the recycling 

of SLABs in Mexico or Canada. To make 

this determination, the Secretariat would 

require data on the environmental costs 

at each facility in Canada, Mexico and the 

United States, as well as definitive information on any regional or national capacity 

constraints and tolling costs that would drive 

investment and recycling decisions. More 

specifically, the Secretariat would need data 

reflecting the cost of purchasing and transporting SLABs to the secondary smelter, the 

direct cash cost of smelter operations, the 

direct cash cost of lead refining, the annual 

capital expenditures required to sustain the 

smelter operation, and the cost of delivery of 

the product (the recycled lead) to the customer, including handling, freight, insurance 

and administrative expenses. These costs, 

which will vary greatly, will depend not only 

on regulatory requirements but also on the 

smelter management practices and the location of the smelter in relation to its customers.

Photo: Profepa
4
 Hazardous Trade? Hazardous Trade? 31

In this chapter, we examine the laws, regulations and policies that 

cover secondary lead smelters in the United States, the Canadian 

provinces of Ontario and Quebec, where Tonolli Canada and Newalta 

are located, and Mexico.

Our examination reveals that in terms of 

addressing lead air emissions from secondary 

lead smelters and their effects on workers 

and surrounding communities, Mexico’s regulatory framework is less stringent than that 

of the United States or Canada. We also note 

that certain regulatory gaps exist in Mexico 

within the regulatory framework covering 

secondary lead smelters. 

To provide context for this discussion, Table 4-1 shows the air emissions 

standards for secondary lead smelters in the 

United States, Mexico and Canada (Ontario 

and Quebec). Table 4-2 summarizes some of 

the occupational health and safety standards 

for lead that apply to the secondary lead 

smelters in North America and the non-occupational health lead standards that apply to 

children and pregnant and lactating women.

Pollution Control and 

Occupational Standards 

Across North America

Table 4-1. Overview of Standards Mandated for Secondary Lead Smelters: 

United States, Mexico and Canada (Ontario and Quebec)

Air emissions United States Mexico Canada (Ontario* and Quebec**)

End of stack 1.0 mg/dscm max/stack 

0.2 mg/dscm facility-wide

No standards Ontario: Point of Impingement (POI) 

standards, 0.5 μg/m3

 for 24-hour average 

and 0.2 μg/m3

 for 30-day average

Quebec: kiln, 30 mg/Rm3

; other lead 

production units, 15 mg/Rm3

Fugitive Enclosure, 

negative pressure

No requirement for enclosure, negative pressure Ontario: Enclosure, negative pressure

Quebec: Enclosure, negative pressure

Ambient air 0.15 μg/m3

 over 

3-month rolling period

1.5 μg/m3 (average 

over 3-month period)

Ontario: 0.5 μg/m3 for 24-hour average 

and 0.2 μg/m3

 for 30-day average

Quebec: 0.1 μg/m3

 for 1-year average

 *Ontario Ministry of the Environment and **Ministère du Développement durable, de l'Environnement, de la Faune, et des Parcs du Québec)

Source: See footnotes 86 to 101 and accompanying text.

Note: mg/dscm = milligrams per dry standard cubic meter; μg/m3

 = microgram per cubic meter; mg/Rm3 = milligrams per reference cubic meter.
32

Facility Permitting

In the United States, Canada and Mexico, 

secondary lead smelters operate under 

permits or licenses containing conditions that 

are enforceable against the facility. In the 

United States, state governments issue pollution discharge permits under the authority of 

federal environmental statutes. Although the 

federal government sets minimum standards, 

state requirements may, in most instances, 

exceed the federal requirements. 

In Canada, the provinces issue permits, 

based on provincial law, that reflect a collaborative process between the regulator and the 

regulated entity. 

In Mexico, the federal government has 

sole authority to issue operating permits 

for secondary lead smelting facilities, based 

on federal environmental statutes. It is at 

the permitting stage of the facility that the 

government evaluates the environmental 

impacts, including those caused by lead emissions, of the facility in determining whether to 

issue a permit. Various requirements include: 

 acquiring a federal license for air 

emissions; 

 filing a management plan for authorizing 

SLAB processors that are also lead-acid 

battery manufacturers; and 



 reporting annually all facility operations in what is known as the Cedula de 

Operación Anual (COA), which contains 

the operational conditions—such as 

protocols, techniques, technologies and 

equipment—that the permittee must 

adhere to in operating the facility.

One important difference between the 

permitting process in Mexico and those 

of the United States and Canada is that in 

Mexico there is no specific standard for 

lead emissions.

Air Standards

Two types of standards apply to the control 

and monitoring of emissions in and around 

secondary lead smelters: emissions standards and ambient air standards. Emissions 

standards set permissible levels of lead that 

can be released into the environment from 

a facility. They require monitoring the air 

released from a facility’s stacks and vents, 

and they may also establish the specific 

processes, practices and control technologies that a facility must implement to control 

fugitive emissions. 

Ambient air standards set levels of pollutants considered to be harmful to the public 

health and the environment. They apply to air 

quality beyond a smelter’s property and may 

require the facility or a government agency to 

Table 4-2. Select Lead Standards: United States, Mexico and Canada (Ontario and Quebec)

Occupational United States Mexico Canada

Ontario/Quebec

Permissible 

airborne exposure

50 μg/m3

 averaged over 

8-hour period

150 μg/m3 averaged 

over 8 hours per 

day, 40 hours per week

Ontario: 0.05mg/m3 per 

8-hour exposure (50 μg/m3

)

Quebec: 0.05 mg/m3

 per 

8-hour exposure (50 μg/m3

) 

Blood lead levels (BLLs), 

medical removal

60 μg/dL, or 50 μg/dL over an 

extended time period; industry 

voluntary standard for removal 

at 40 μg/dL

No standard Ontario: 3.38 μmol/L 

(69.966 μg/dL) (Tonolli’s lower 

standard, 57.9599 μg/dL)

Quebec: 400 μg/L (40 μg/dL) 

Non-occupational United States Mexico Canada

BLLs of concern 

in children

5 μg/dL—reference based on the 

97.5th percentile of population; 

no longer using BLL terminology

10 μg/dL 10 μg/dL

BLLs of concern in pregnant 

and lactating women

10 μg/dL 10 μg/dL 10 μg/dL

Source: See footnotes 109 to 120 and 20 to 25 and accompanying texts.

Note: μg/m3

 = micrograms per cubic meter; μmol/L = micromoles per liter; μg/L = micrograms per liter; μg/dL = micrograms per deciliter.

Pollution Control and Occupational Standards across North America
 Hazardous Trade? 33

monitor the air for lead particulates, typically at or near the fence line of the facility. In 

some jurisdictions, ambient air standards are 

used to guide permit decisions and to inform 

the setting of emissions standards but are 

not enforceable against a specific facility. In 

other jurisdictions, exceedance of ambient 

standards at a facility’s fence line may trigger 

the implementation of additional monitoring 

requirements and enforcement actions.

United States 

In January 2012, the USEPA finalized new 

emission standards for secondary lead 

smelters. All secondary lead smelters must 

comply with these standards by January 2014. 

These standards set a facility-wide, flowweighted average lead emissions limit from 

stacks of 0.20 milligrams per dry standard 

cubic meter (mg/dscm) and an individual 

stack lead emissions limit of 1.0 mg/dscm 

for each stack at existing sources.86 These 

standards will be 10 times lower than the 

standards now in place in the United States. 

To reduce fugitive lead and arsenic emissions, 

the new regulation will also require facilities to fully enclose all operations within a 

building operated under negative pressure, to 

vent emissions through a controlled stack and 

to implement comprehensive work practices. 

Those work practices include paving facility 

grounds, frequently cleaning plant roadways, 

cleaning vehicles prior to leaving total enclosures, transporting lead-bearing materials 

within closed containers, and performing 

maintenance activities within total enclosures. These standards minimize generation 

of fugitive dust, thereby preventing deposition of lead in areas surrounding secondary 

lead smelters.87

The federal government’s ambient 

air quality standard (National Ambient 

Air Quality Standard—NAAQS) for lead is 

0.15 micrograms per cubic meter (μg/m3

) 

for a three-month rolling average, which 

was lowered from 1.5 μg/m3

 in 2008. In 

the United States, state and local governments have monitoring systems to help 

determine whether air quality standards for 

lead are being attained.88 Federal ambient 

air standards are not enforceable against 

facilities. Rather, they are an important tool 

for regulatory authorities in the United States 

to make decisions regarding the issuance 

of permits and the setting of air emissions 

standards.89 USEPA’s decision to tighten 

air emissions standards at secondary lead 

smelters in 2012, for example, was based 

on a finding that actual lead emissions from 

secondary lead smelters resulted in modeled concentrations of lead above the lead 

NAAQS at nine of 15 secondary lead smelters. 

The USEPA concluded that stack and fugitive 

emissions of lead from such smelters had to 

be reduced to provide an ample margin of 

safety to protect public health.90

States in the US that issue emission 

permits based on the federal standards 

can also impose standards that are more 

stringent than the federal requirements. 

California, for example, requires secondary 

lead smelters to conduct ambient air monitoring at their fence lines. The two secondary 

lead smelters in California may not discharge 

lead emissions that contribute to ambient 

concentrations exceeding 0.15 μg/m3

, 

calculated as a 30-day rolling average. If 

ambient concentrations exceed certain levels 

below this threshold, the facility must implement additional monitoring and institute a 

compliance plan.91

Canada

In Canada, the federal government has set 

stack emissions standards for secondary lead 

smelters,92 but provincial permit requirements 

in Ontario and Quebec are more stringent 

than the federal requirements. Ontario 

One important 

difference in 

the permitting 

process in 

Mexico and 

those of the 

United States 

and Canada 

is that in 

Mexico there 

is no specific 

standard for 

lead emissions.

’

’

86 Standards for Process Vents, 40 C.F.R. sec. 63.543 (a) (2012). For new sources, a lead emissions limit of 0.20 mg/dscm applies to 

each individual stack at a modified or new facility. 87 Total Enclosure Standards, 40 C.F.R. sec. 63.544 (2012); Standards for Fugitive Dust Sources, 40 C.F.R. sec. 63.545 (2012). 88 See US Environmental Protection Agency, “Air Data, Interactive Map,” <http://www.epa.gov/airquality/airdata/ad_maps.html>. 89 When an area is not in attainment, the state must develop a written State Implementation Plan (SIP) for attaining the standard 

and submit it to USEPA for review and approval. See US Environmental Protection Agency, “State Implementation Plan Overview,” 

<http://www.epa.gov/airquality/urbanair/sipstatus/overview.html>. 90 “National Emissions Standards for Hazardous Air Pollutants from Secondary Lead Smelting,” 77 Federal Register 563

(5 January 2012). 91 South Coast Air Quality Management District (CA), “Emissions Standard for Lead from Large Lead-Acid Battery Recycling 

Facilities,” <https://www.aqmd.gov/rules/reg/reg14/r1420-1.pdf>. 92 Secondary Lead Smelter Release Regulations, SOR/91-155, Sec. 5, 

<http://laws-lois.justice.gc.ca/eng/regulations/SOR-91-155/FullText.html>.
34

controls industrial emissions by setting Point 

of Impingement (POI) standards that specify 

the maximum permitted concentration of a 

pollutant at the points at which it leaves the 

facility’s property.93 In Ontario, the POI standard94 and the Ambient Air Quality Criteria95

are both 0.5 μg/m3

 for a 24-hour average and 

0.2 μg/m3

 for a 30-day average. As a condition of its permit, Tonolli Canada, the only 

secondary lead smelter operating in Ontario, 

has enclosed all process sources and most 

material handling sources, and it maintains 

negative pressure to prevent fugitive dust 

emissions and restricts lead emissions from 

baghouse stacks 96 to less than 0.2 milligrams 

per cubic meter (mg/m3

).97

In Quebec, Newalta must meet an 

ambient air standard of 0.1 μg/m3

 for a 

one-year average.98 The lead stack emission level for the kiln is 30 milligrams per 

reference cubic meter (mg/Rm3

), and other 

lead production units have emissions levels 

of 15 mg/Rm3

.

99 In Quebec, lead emissions 

are evaluated using a dispersion model that 

takes into consideration all stacks, the height 

of stacks and buildings, and other factors. All 

lead production units at Newalta are under 

negative pressure.100

93 Environmental Protection Act, Ontario Regulation 419/05, Part I (2), <http://www.e-laws.gov.on.ca/html/regs/english/elaws_

regs_050419_e.htm>. 94 Ontario Ministry of the Environment, Summary of Standards and Guidelines to Support Ontario Regulation 419: Air Pollution—

Local Air Quality, <http://www.ene.gov.on.ca/environment/en/resources/STDPROD_096528.html>. 95 Ontario Ministry of the Environment, Ontario’s Ambient Air Quality Criteria, April 2012, 

<http://www.ene.gov.on.ca/stdprodconsume/groups/lr/@ene/@resources/documents/resource/std01_078686.pdf>. 96 A baghouse is a fabric filter that removes particulates from air or gas. These filters are installed prior to the air or gas reaching 

the facility’s stack. 97 Visit to Tonolli Canada and interview with Ross Atkinson, president, Tonolli Canada, 12 June 2012. 98 Règlement sur l'assainissement de l'atmosphère, O.C. 501-2011, s. 164, Anexe K (Normes de qualité de l’atmosphère), 

<http://www2.publicationsduquebec.gouv.qc.ca/dynamicSearch/telecharge.php?type=2&file=%2F%2FQ_2%2FQ2R4_1.htm>. 99 Ibid. Chapter VII, article 164. 100 E-mail from André Gosselin, senior director, technical services and projects, Newalta, to Tim Whitehouse, consultant, 

Commission for Environmental Cooperation, 18 September 2012.

Pollution Control and Occupational Standards across North America
 Hazardous Trade? 35

Mexico

Mexico does not have a regulatory standard 

(Norma Oficial Mexicana—NOM) that covers 

lead air emissions from secondary lead 

smelters. The only emissions standard that 

applies to the lead smelting sector—among 

other industries—is for particulate matter 

(PM) emissions.101

The federal government issued an 

ambient air quality standard in 1993 limiting 

ambient concentrations of lead to a level 

of 1.5 μg/m3

 (average over a three-month 

period). As in the United States, federal 

ambient air standards are not enforceable 

against facilities. Rather, they are, or should 

be, an important tool for regulatory authorities. Under Mexico’s ambient air regulations, 

federal, state and local authorities are 

responsible for monitoring and assessing 

air quality.102 The monitoring network itself 

is operated by state governments. However, 

the network is incomplete, and lead is not 

consistently monitored in all stations of the 

network, known as the Sistema Nacional de 

Información de Calidad del Aire (Sinaica).

Other Pollution and 

Management Standards

In the United States and Canada, federal, 

state and local laws address issues such 

as hazardous waste management, stormwater runoff103 and remediation and cleanup 

needs at sites contaminated with lead. In 

the United States, the Superfund program, 

which requires responsible parties to perform 

cleanups or reimburse the government for 

EPA-led cleanups at hazardous waste sites, 

provides significant deterrent to lead pollution because it places responsibility on the 

industry for remediation and cleanup.104

Mexico lacks regulations to address 

stormwater runoff from secondary lead 

smelters (it is addressed on a case-by-case 

basis in each facility's permitting process) 

and releases of lead to the soil. Regulations 

have also not been finalized to address the 

development of hazardous waste management plans;105 methods for determining the 

hazardous characteristics of waste created 

as a result of secondary lead smelting;106

conditions for the construction, operation 

and closing of facilities; and the process for 

determining when remediation actions should 

occur at contaminated sites.107

101 NOM-043-SEMARNAT-1993, <http://biblioteca.semarnat.gob.mx/janium/Documentos/Ciga/agenda/PPD02/NOM-043.pdf>. 102 NOM-026-SSA1-1993, <http://sinaica.ine.gob.mx/>. 103 In the United States, see US Environmental Protection Agency, “Federal Stormwater Management Requirement,” 

<http://www.epa.gov/oaintrnt/stormwater/requirements.htm>; and “Cleanup Regulations and Standards,” 

<http://www.epa.gov/cleanups/regs.html>. For Ontario, see Corporation of the City of Mississauga, Storm Sewer By-Law 

259-05 (as amended by 356-10), see <http://www.mississauga.ca/file/COM/stormsewer2011.pdf>; Ministry of the 

Environment (MOE) Ontario Regulation 511/09, Soil, Groundwater and Sediment Standards for Use under Part XV.1 of the 

Environmental Protection Act (EPA) (27 July 2009). See <https://www.e-laws.gov.on.ca/html/source/regs/english/2009/elaws_

src_regs_r09511_e.htm>: For Quebec, see Montreal Storm Water Run-off, Regulation on the Protection and Rehabilitation 

of Land, Environmental Quality Act (C.Q.-2, a. 31, 31.69, 109.1 and 124.1). For Quebec, see Montreal Storm Water Run-off, 

Regulation on the Protection and Rehabilitation of Land, Environmental Quality Act (C.Q.-2, a. 31, 31.69, 109.1 and 124.1). 104 See US Environmental Protection Agency, “Basic Information: What is Superfund?” <http://www.epa.gov/superfund/about.htm>. 105 Mexico’s General Act for the Comprehensive Management of Residues (Ley General para la Prevención y Gestión de los 

Residuos—LGPGIR) and its regulations (Reglamento de la LGPGIR) mandates the issuance of official standards (Normas 

Oficiales Mexicanas—NOMs) aimed at establishing elements and procedures to be considered in the development of a 

“Management Plan.” This stems from the fact that lead-acid batteries will become a hazardous waste when they are no longer 

capable of storing and providing energy—see Articles 29, 31 and 32 (IV) of LGPGIR and 17 of its regulations. A draft NOM 

(PROY-NOM-160-SEMARNAT-2011) was published for public comments on 12 August 2011. See <http://www.dof.gob.mx/

normasOficiales/4466/semarnat/semarnat.htm>. 106 The NOM providing elements for the characterization and comprehensive management of wastes stemming from the metallurgical industry (this includes secondary refining of lead) and the conditions for construction, operation and closing facilities 

where these wastes are generated—Article 17 of LGPGIR, and 34 of its regulations—has not been issued. 107 There is no NOM that would provide elements for characterizing contaminated sites, assessing risks to health and the environment, and determining corresponding remediation actions derived from that analysis—Article 78, LGPGIR, regulations 133 and 

134. NOM-147-SEMARNAT/SSA1-2004, issued 2 March 2007, establishes the levels of concentrations of different pollutants, 

including lead, in a contaminated site (see 5.1.1, 5.4.2. and 5.4.7.2); however, it does not exhaustively address procedures for 

the assessment of risks to health and the environment and types of remediation actions apposite for the level of contamination 

(see 5.6), <http://www.profepa.gob.mx/innovaportal/file/1392/1/nom-147-semarnat_ssa1-2004.pdf>.

Photo: Profepa
36

Mexico’s Office of the Federal Attorney 

for Environmental Protection (Profepa) also 

administers a federal, voluntary environmental auditing and self-regulatory program 

(Programa Nacional de Auditoria Ambiental), 

commonly known as Industria Limpia. The 

program targets companies that, because 

of their operations, scope of activities, or 

industrial sector, may cause significant 

negative environmental effects or impacts, or 

could exceed limits established in environmental standards. Companies participating in 

Industria Limpia adhere to terms of reference set forth by federal regulations. In the 

implementation of these terms of reference, 

the industrial facility submits a plan of audit 

for approval by Profepa. The environmental 

audit is developed by an accredited thirdparty independent auditor. If the audit reveals 

issues to be addressed, the company submits 

a plan of action to Profepa. This plan recommends preventive and corrective actions for 

areas or operations to avoid adverse impacts 

on the environment. Once the plan of action 

is successfully implemented, verified by an 

accredited third-party independent auditor, 

and verified again by Profepa, facilities 

may receive a certificate of Clean Industry 

(Industria Limpia).108 Details of the status 

and membership of Mexico’s secondary lead 

recyclers in relation to this program are listed 

in Appendix 3.

Occupational 

Health and Safety

Occupational health standards protect 

workers at secondary lead smelters from 

exposure to lead. Three different types 

of occupational standards could apply to 

secondary lead smelters, depending on 

the jurisdiction. The first is the permissible 

exposure level—when the amount of lead 

in the air exceeds this limit, employers must 

have their employees wear respirators and 

protective clothing, and the employer must 

implement certain housekeeping and hygiene 

practices. The second is the action level—

when airborne exposure exceeds an action 

level, the employer must institute a medical 

surveillance program, including testing the 

blood lead levels of all employees. The third 

standard sets limits on the amount of lead 

in a worker’s blood stream and requires the 

employer to take certain steps if a worker’s 

blood lead level exceeds a certain threshold. 

In the United States, the permissible 

airborne exposure limit is 50 μg/m3

 averaged over an eight-hour period.109 The US 

action level for lead is 30 μg/m3

 averaged 

over an eight-hour period for all employees 

who are or may be exposed at or above 

the action level for more than 30 days per 

year.110 Employees with blood lead levels 

above 60 μg/dL (the level calling for medical 

removal protection, MRP), or exceeding 

50 μg/dL over an extended period,111 must 

be removed from occupational contact with 

lead until their blood lead levels drop below 

40 μg/dL.112 The industry in the United States 

has voluntarily agreed to remove employees 

when their blood levels exceed 40 μg/dL. 

108 See <http://www.profepa.gob.mx/innovaportal/file/3946/1/pfpa-saa-152-dtr-01.pdf>. 109 Lead, 29 C.F.R. sec. 1910.1025 (2011), <http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_

table=STANDARDS&p_id=10030&p_text_version=FALSE#1910.1025 (j)>. 110 29 C.F.R. sec. 1910.1025(j)(1)(i). 111 29 C.F.R. sec. 1910.1025(k)(1)(i)(A)(B). 112 29 C.F.R. sec. 1910.1025(k)(1)(i)(B).

Pollution Control and Occupational Standards across North America

Photo: Profepa
 Hazardous Trade? 37

Some companies told the CEC Secretariat 

that they set their MRP even lower than these 

voluntary levels. 

In Ontario, the permissible airborne 

exposure level for lead is 0.05mg/m3

 per 

eight-hour exposure.113 Ontario requires that 

when a worker’s blood lead level exceeds 

3.38 micromoles per liter (μmol/L), or 

69.966 μg/dL, he or she must be removed 

from the lead exposure.114 However, Tonolli 

follows a written practice of removing all 

employees with blood lead levels higher 

than 2.8 μmol/L (57.9599 μg/dL), and does 

not return them to the same area of operation until their blood lead levels fall below 

2.4 μmol/L (49.68 μg/dL).115

In Quebec, the permissible airborne 

exposure level for lead is 0.05 mg/m3

 per 

eight-hour exposure.116 Workers with blood 

lead levels of 400 μg/L are removed from the 

source of lead exposure.117

In Mexico, the permissible airborne 

occupational exposure limit is 150 μg/m3

(8 hours per day, 40 hours per week).118

Mexico has no blood level limit mandating 

that workers be removed from occupational exposures, although some managers 

interviewed in Mexico indicated that, following corporate policies, they regularly 

test and report the blood lead levels of their 

employees and follow the US action level 

or other standards for employee removal. A 

recently issued official standard in Mexico 

establishes the biological exposure indexes 

(BEIs) for workers exposed to chemicals, 

including lead.119 This standard foresees a 

general BEI of 30 μg per 100 ml for the BLL of 

workers in general and 10 μg of lead per deciliter for women. No medical removal protocol 

or worker removal requirement is associated 

with implementation of this new standard.120

The Environmental 

Disincentives of 

Lower Standards

A weaker regulatory framework in Mexico 

puts those Mexican secondary lead smelters 

that have made environmental improvements at a competitive disadvantage. This 

is particularly true for midsize operations 

without a secure supply of SLABs. In Mexico, 

where outside of JCI’s reverse distribution 

system, most batteries are bought on the spot 

market or on the basis of short-term contracts, industry observers note that smelters 

with less stringent environmental controls, 

and thus lower environmental costs, routinely 

outbid those facilities subject to higher levels 

of environmental protection and costs in the 

domestic SLAB market. Because of the tight 

supply of SLABs and the overcapacity of 

recycling in Mexico, this dynamic creates an 

unfair market advantage for those smelters 

with lower environmental costs and may 

jeopardize the long-term sustainability of 

those smelters that are trying to improve their 

environmental performance.

In addition, as noted previously, current 

market incentives to recycle industrial 

batteries may not be as strong as they are 

for automobile batteries. Several industry 

insiders expressed concerns that companies 

that use industrial batteries are choosing 

the lowest-cost and least environmentally 

appropriate methods to recycle their industrial batteries, which skews the market toward 

those companies with poorer environmental 

practices. The CEC Secretariat was unable to 

independently verify these concerns.

A weaker 

regulatory 

framework in 

Mexico puts 

those Mexican 

secondary lead 

smelters that 

have made 

environmental 

improvements 

at a competitive 

disadvantage.

’

’

113 Ontario Regulation 833, as amended 149/12 (2013). 114 Ontario Regulation 490/09 (2010), 

<http://www.e-laws.gov.on.ca/html/source/regs/english/2009/elaws_src_regs_r09490_e.htm>. 115 Copy on file with the CEC Secretariat. 116 O.C. 885-2001, s. 45, Regulation Respecting Occupational Health and Safety, R.S.Q., c. S-2.1, s. 223, Div. VI, Individual 

Protective Respiratory Equipment, O.C. 885-2001, s. 45 (2001), <http://www2.publicationsduquebec.gouv.qc.ca/dynamicSearch/telecharge.php?type=3&file=/S_2_1/S2_1R13_A.HTM>. 117 E-mail from André Gosselin, 18 September 2012. 118 Ministry of Labor, NOM-010-STPS-1999, Occupational Health in Areas Where Chemicals Are Handled, Transported, Processed 

or Stored (Condiciones de seguridad e higiene en los centros de trabajo donde se manejen, transporten, procesen o almacenen 

sustancias químicas capaces de generar contaminación en el medio ambiente laboral), 

<http://asinom.stps.gob.mx:8145/upload/nom/10.pdf>. 119 In June 2012, the Secretariat of Health in Mexico released a regulation that set a biological exposure index of 30 μg/dl of lead 

for males and of 10 μg/dl for women. However, the regulation does not set a mandatory removal level for workers. Norma Oficial 

Mexicana NOM-047-SSA1-2011, effective December 2012, <http://www.dof.gob.mx/normasOficiales/4724/salud/salud.htm>, 

Environmental Health Biological Exhibition Indexes for the Personnel Occupationally Exposed to Chemical Substances (Salud 

ambiental-indices biológicos de exposición para el personal ocupacionalmente expuesto a sustancias químicas). 120 Ibid.
5
 Hazardous Trade? Hazardous Trade? 39

Because of a lack of data, the CEC Secretariat has been unable to 

specify and document the environmental performance of the SLAB 

recycling industry in Mexico, how it compares with the performance 

in the United States or Canada, and the impacts that the industry may 

have on people living near smelters. 

To help understand this issue, in this chapter 

we examine the public comments the 

Secretariat received on the impacts of the 

industry on people living near secondary lead 

smelters, a selection of known instances of 

lead poisoning and lead pollution from the 

lead recycling industry in the United States 

and Mexico, the available lead air emissions 

data for Mexico and how they compare with 

those of the United States, information on 

lead releases as reported through the pollutant release and transfer registries, and our 

observations of the industry, based on our 

visits and discussions.

Impacts of SLAB Recycling on

People Living Near Smelters

One goal of this study was to examine 

concerns around the pollution and health 

effects impacting people living near certain 

recycling operations in the [North American] 

region and notably in Mexico.121 As part of the 

public comment process, the CEC Secretariat 

sought responses to the following question 

on the pollution outputs and health effects of 

secondary lead smelting: what are the public 

health and environmental consequences of 

the growth in exports of SLABs to Mexico 

for recycling?

The Secretariat received comments 

reflecting two different perspectives. Some 

commentators believed SLAB exports to 

Mexico for recycling will have negative 

health impacts because Mexico does not 

have adequate standards to protect public 

and worker health from lead poisoning. 

Others noted, however, that recycling of 

US-generated SLABs should not result in 

harm as long as the recycling operations 

operate in accordance with US standards. 

Moreover, they pointed out that the development of a modern smelting industry in Mexico 

would likely improve the environment as new 

facilities displace the older, inferior smelters 

and informal sector smelting and melting.

Environmental Performance 

of the Secondary Lead Smelting Industry

121 See <http://www.cec.org/slabs>.
40

Examples of Lead

Poisoning and Pollution

Examples of the lead poisoning and pollution 

that can be caused by lead smelting and of the 

difficulties that arise in addressing this type 

of pollution can be found in North America. In 

the United States, more than 300 Superfund 

sites have lead contamination and more 

than 70 are a result of smelting or mining.122

Cleanup actions at these sites have resulted in 

wide-spread lead-level reductions in children.123 However, despite this success, lead 

contamination from facilities can persist, often 

undetected, for decades. A recent newspaper 

series in the United States identified, for 

example, 230 lead smelters, which it called 

“forgotten factories,” that operated mainly 

from the 1930s to 1960s. Through soil testing, 

it identified potentially dangerous levels of 

lead in 21 neighborhoods across 13 states, 

and high blood lead levels in some children 

in those communities.124

Even with strict emission controls, 

dangerous levels of lead can be carried into 

neighboring communities by workers. For 

example, in a recent case in Arecibo, Puerto 

Rico, workers at a secondary lead smelter 

were carrying lead particles into their homes 

and communities on their clothes and in their 

cars. The US Centers for Disease Control and 

Prevention found that among 68 children 

under the age of 6 years of employees of the 

battery recycling company, 11, or 16 percent, 

had confirmed blood lead levels of ≥10 micrograms per deciliter (μg/dL).125

Specifically, in this population of secondary lead smelter workers, 85% of vehicle 

dust samples and 49% of home dust samples 

exceeded EPA's level of concern on wipe 

samples, of greater than or equal to 40 μg/

ft2

 (430.6 μg/m2).126 In comparison, a study of 

wipe samples taken on composite floor dust 

collected during an island-wide, cross-sectional blood lead prevalence study in 2010, 

found only one (0.4%) of 235 households had 

a lead level exceeding the EPA level of concern. Dust lead levels in homes with children 

aged under 6 years with BLLs of greater than 

or equal to 5 μg/dL were more than triple 

the levels of homes with children with BLLs 

less than 5μg/dL. As of October 2012, 147

homes and 148 vehicles have been decontaminated. EPA required the company to set 

up shower facilities for the workers, as well 

as shoe washes and clean changing areas. 

The CDC assigned a case manager to provide 

education, environmental follow-up, and case 

management of all children with BLLs greater 

than or equal to 5 μg/dL. On average, children's BLLs have decreased 9.9 μg/dL since 

they were enrolled in case management.

In Mexico, very little information is 

available on lead contamination near 

smelters. One high-profile case that has been 

closely monitored involves lead poisoning 

among children living near a primary lead 

smelter, Met-Mex Peñoles, in Torreon, Mexico. 

In 1999, investigators found that the median 

lead concentration in soils near that facility 

was six times the remediation levels for soils 

in the United States.127 They also found that 

of the 367 children tested who lived near 

the plant, 20 percent had blood lead levels 

greater than 10 μg/dL, and 5 percent of the 

children had blood lead levels greater than 

20 μg/dL. Thanks to vigorous intervention 

by government agencies and the company, 

exposure levels have dropped, although they 

are still about five times higher than the level 

in the United States.128

Another well-known case, Metales y 

Derivados, involved a US battery recycler 

122 USEPA Questions/Comments on draft report titled “Hazardous Trade? An examiniation of US-generated Spent lead Acid Batteryexports and secondary lead recycling in Mexico, the United States and Canada,” December 21, 2012. The EPA comments are 

posted at: <http://www.cec.org/Storage/142/16836_EPA_comments_on_CEC_draft_SLABs_report_Dec_21_2012.pdf>. 123 US Environmental Protection Agency, “Examples of Superfund Site Cleanups,” 

<http://www.epa.gov/superfund/lead/success.htm>. 124 Alison Young, “Long-gone Lead Factories Leave Poisons in Nearby Yards,” USA Today, updated 25 April 2012, 

<http://usatoday30.usatoday.com/news/nation/lead-poisoning>; Alison Young and Peter Eisler, “Some Neighborhoods 

Dangerously Contaminated by Lead Fallout,” 20 April 2012, 

<http://usatoday30.usatoday.com/news/nation/story/2012-04-20/smelting-lead-contamination-soil-testing/54420418/1>. 125 “Take-Home Lead Exposure Among Children with Relatives Employed at a Battery Recycling Facility, Puerto Rico, 2011,” 

CDC Morbidity and Mortality Weekly, 30 November 2012, 61(47), pp. 967–70, available at: 

<http://www.cdc.gov/mmwr/preview/mmwrhtml/mm6147a4.htm?s_cid=mm6147a4_e > 126 Wipe and blood lead levels of concern and sampling results in this paragraph as given in the CDC report (ibid.) and in the corresponding erratum <http://www.cdc.gov/mmwr/preview/mmwrhtml/mm6149a4.htm>. 127 Marisela Rubio-Andrade, Francisco Valdés-Pérezgasga, J Alonso, Jorge L. Rosado, Mariano E. Cebrián and Gonzalo G. GarcíaVargas,“Follow-up Study on Lead Exposure in Children Living in a Smelter Community in Northern Mexico,” Environmental 

Health (2011), <http://www.ehjournal.net/content/10/1/66>. 128 US Centers for Disease Control and Prevention, “Blood Lead Levels and Risk Factors for Lead Poisoning Among Children in 

Torreón, Coahuila, Mexico,” <http://www.bvsde.paho.org/bvsea/fulltext/torreon.pdf>.

In Mexico, 

very little 

information 

is available 

on lead 

contamination 

near smelters. 

’

’

Environmental Performance of the Secondary Lead Smelting Industry
 Hazardous Trade? 41

located outside of Tijuana. The owner of the 

facility abandoned the plant in 1994 after 

being cited by the Mexican government for 

environmental violations. The abandoned 

site, located adjacent to a community of 

10,000 people, contained 6,000 t of lead slag, 

waste sulfuric acid and a mix of other heavy 

metals. The attempt to remediate this facility 

to protect the neighboring community from 

lead poisoning has involved extensive binational remediation measures spanning over a 

decade. This remediation effort was prompted 

by the NAAEC’s Article 14/15 process, under 

which the CEC Secretariat prepared a factual 

record in response to a citizen’s complaints 

that Mexico was failing to effectively enforce 

its environmental laws.129 The Metales y 

Derivados property is now owned by the 

state of Baja California as a result of a landtransfer agreement. Also located there is the 

air quality laboratory for Baja California’s 

Secretaría de Protección al Ambiente.

Evaluating Lead Air Emissions

Closely tied to the issue of the impacts of lead 

recycling on people living near smelters is the 

overall environmental performance of the SLABs 

recycling industry. After initiating its study, the 

CEC Secretariat expanded its scope to gauge 

the health and pollution impacts of the entire 

industry in Mexico, not just those smelters 

receiving US-generated SLABs. Although it is 

important to consider the performance of the 

nine secondary smelters that process imported 

SLABs, it is equally important from an environmental perspective to include the health and 

pollution impacts of the remaining 16 authorized 

facilities across Mexico, as well as the small, 

unauthorized facilities that may be operating in 

the informal market. As mentioned elsewhere, 

there is wide variation in the control technologies and operating procedures employed across 

Mexico among the smelters that recycle US 

SLABs and those that do not. Moreover, because 

of the competitive market for SLABs in general, 

several managers of secondary lead smelters in 

Mexico that have not yet imported US-generated 

SLABs have indicated that they would like to do 

so in the future.

In evaluating lead air emissions, we 

found that the USEPA has collected comparative performance data on lead emissions 

and that such data are publicly available. 

However, in Mexico the same type of information is not collected on a regular basis for all 

smelters and is not publicly available, making 

it impossible to assess the actual performance of secondary lead smelting facilities 

in Mexico and to compare their performance 

with facilities operating in the United States.

129 Secretariat, Commission for Environmental Cooperation, Metales y Derivados, Final Factual Record (SEM-98-007), 

<http://www.cec.org/Page.asp?PageID=2001&ContentID=2372&SiteNodeID=547&BL_ExpandID=502>.
42

Some examples of the US data for 

secondary lead smelting facilities are presented here. Figure 5-1 shows data collected 

by the USEPA from secondary lead smelters on 

their point source emissions (e.g., stacks and 

vents) from 2006 to 2010.

130 It is an assessment carried out independently of the PRTR 

reporting requirements described in the next 

section. Similar government information is not 

available in Mexico.

Figure 5-2 presents ambient lead 

concentrations collected by USEPA at all 

ambient air monitoring stations near secondary 

lead smelters and compares that data to the 

new National Ambient Air Quality Standard of 

0.15 μg/m3

.

131 This type of information is not 

available in Mexico, however. These data have 

allowed USEPA to evaluate the effectiveness 

of different pollution control technologies such 

as fabric filters, Highly Efficient Particulate Air 

(HEPA) filters, cartridge collectors and the Wet 

Electrostatic Precipitator (WESP). In a technology review of the secondary lead smelting 

industry, USEPA assessed facility emissions 

data to compare outlet lead concentrations 

from different technologies, as illustrated in 

Figure 5-3.

132

130 Emission estimates developed in support of the recent amendments to the National Emission Standards for Hazardous Air 

Pollutants from Secondary Lead Smelting. Development of the RTR Emissions Dataset for the Secondary Lead Smelting Source 

Category. Available at <http://www.regulations.gov, Document ID – EPA-HQ-OAR-2011-0344-0163>. 131 The public can access air quality data for lead at USEPA, “Air Data, Interactive Map,” 

<http://www.epa.gov/airquality/airdata/ad_maps.html>. 132 US Environmental Protection Agency, “Summary of the Technology Review for the Secondary Lead 

Smelting Source Category,” EPA-HQ-OAR-2011-0344-0152, December 2011, p. 6, 

<http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2011-0344-0055>.

Environmental Performance of the Secondary Lead Smelting Industry

FIGURE 5-1 Estimated Annual Lead (Pb) Emissions at US Secondary Smelters for 2006–2010

Source: US Environmental Protection Agency, Development of RTR Emissions Dataset for Secondary Lead Smelting Source Category, EPA-HQ-OAR-2011-0344-0163, 

December 2011, pp. 6, 12, 13; <http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2011-0344-0163>. 

Sanders Lead Company - AL

Quemetco, Inc. - CA

Exide Technologies - CA

EnviroFocus Technologies, LLC - FL

Quemetco, Inc. - IN

Exide Technologies -IN

Exide Baton Rouge Recycling Center - LA

Gopher Resource, LLC - MN

Buick Resource Recycling, LLC (Doe Run) - MO 

Exide, Canon Hollow Recycling - MO

EAST PENN Manf. Co., Inc. - PA

Exide Technologies - Reading Recycling - PA

Exide Technologies, Inc. - TX

The Battery Recycling Company - PR

Revere Smelting & Refining Corp - NY

Annual Lead Emissions (kg)

7,000

6,000

5,000

4,000

3,000

2,000

1,000

0

Fugitive Emissions

Point Source Emissions

+ –

Facility
 Hazardous Trade? 43

Source: US Environmental Protection Agency, “Summary of the Technology Review for the Secondary Lead Smelting Source Category,” EPA-HQ-OAR-2011-0344-0154, 

December 2011, p. 6.

FIGURE

+ –

5-3 Average Outlet Concentration, by Control Technology

Fabric Filter HEPA Filter Cartridge Collectors Fabric Filter + WESP

0.16

0.14

0.12

0.10

0.08

0.06

0.04

0.02

0.00

Pb Concentration (mg/dscm)

Filter Type

Source: US Environmental Protection Agency, Summary of Ambient Lead Monitoring Data around Secondary Lead Smelting Facilities, EPA-HQ-OAR-2011-0344-0152, 

December 2011, p. 5.

FIGURE

+ –

5-2 Mean of Three-month Rolling Average Lead Concentrations near Secondary Lead Smelting 

Facilities, 2008–2010

Concentration (μg/m3) 0.70

0.60

0.50

0.40

0.30

0.20

0.10

0.00

Buick Resources Recycling 

Facility (Boss, MO)

East Penn Manufacturing (Lyons, PA)

Exide Technologies (Vernon, CA)

Exide Technologies 

(Reading, PA)

Exide Technologies (Muncie, IN)

Exide Technologies (Frisco, TX)

Gopher Resources (Eagan, MN)

EnviroFocus Technologies 

(Tampa, FL)

Quemetco, Inc. 

(Industry, CA)

Quemetco, Inc.

(Indianapolis, IN)

Sanders Lead Company 

(Troy, AL)

Battery Recycling (Arecibo, PR)

Revere Smelting and Refining (Middletown, NY)

Primary Lead NAAQS

Facility
44

Analyzing Pollution

Release Information

Across North America

One way to undertake a study of industry 

performance is to compare the lead emissions 

that battery recyclers across North America 

reported to their government’s pollutant 

release and transfer registries.133 Under 

these PRTR programs, certain facilities, such 

as secondary lead smelters, are required 

to report environmental releases and other 

waste management quantities of lead to the 

respective federal environmental authorities if a threshold for reporting is exceeded 

and other reporting requirements are met.134

In turn, these registries publish this information as part of the public’s established 

“right-to-know.” 

Our research reveals that there are gaps 

in the application of and compliance with the 

reporting requirements for lead emissions 

from secondary smelters under Mexico’s 

PRTR program, Registro de Emisiones y 

Transferencias de Contaminantes (RETC)—see 

133 In Canada, this program is called the National Pollutant Release Inventory (NPRI); in Mexico, the Registro de Emisiones y Transferencia de Contaminantes (RETC); 

and in the United States, the Toxics Release Inventory (TRI). An annual compilation of each of these registries has been prepared by the CEC and is available online 

at <http://www.cec.org/takingstock>. 134 Table 1-1 lists all authorized North American facilities that smelt secondary lead from SLABs, including those that are classified as recyclers. In Mexico, the 

obligation to report to the RETC applies to any industrial facility under federal jurisdiction that manufactures, processes or otherwise uses (MPO) more than 5 kg 

of lead or that has more than 1 kg per year of emissions. In the United States, the reporting threshold is 100 pounds (45 kg) of lead MPO annually. In Canada, the 

reporting threshold is 50 kg MPO annually. In Mexico, the Cédula de Operación Anual (COA) is the reporting mechanism through which Semarnat receives information for input to the RETC related to releases, handling and transfers of substances subject to mandatory reporting in terms of the General Law of Ecological 

Equilibrium and Environmental Protection (Ley General del Equilibrio Ecológico y la Protección al Ambiente—LGEEPA).

* 13 facilities did not report to Mexico's RETC in 2010.

** Facility was not in operation or did not report in given year.

Source: Compiled by the CEC from the CEC Taking Stock Online database, using information reported by facilities to RETC, NPRI, and TRI. As noted in Table 1-1, 

Xstrata Zinc - Brunswick and Teck Trail Operations in Canada are primary lead smelters that also process SLABs. 

FIGURE

+ –

5-4 SLAB Processing Facilities Reporting Air Emissions of Lead (and/or Its Compounds), 2010

16,000

15,000

14,000

13,000

12,000

11,000

10,000

9,000

8,000

7,000

6,000

5,000

4,000

3,000

2,000

1,000

Reported Air Emissions (kg)

Xstrata Zinc - Brunswick

Teck Trail Operations

Newalta

Tonolli

Buick Resource Recycling (Doe Run)

East Penn Manufacturing Co., Inc.

Sanders Lead Company

Exide Technologies Inc. - Facility 6Exide Technologies Inc. - Facility 7

Gopher Resource

RSR Corporation, Quemetco Facility 2

Exide Technologies Inc. - Facility 2

RSR (Revere Smelting & Refining Corp.)

Gopher Resource - Envirofocus Technologies

Exide Technologies Inc. - Facility 1

The Battery Recycling Company

Exide Technologies Inc. - Facility 5

RSR Corporation, Quemetco Facility 1

Metalex Products, Ltd.

Enertec México, S. de R.L. de C.V.

Recicladora Industrial de Acumuladores, S.A de C.V.

Eléctrica Automotriz Omega, S.A. de C.V.

M3 Resources México, S. de R.L. de C.V.

Corporación PIPSA, S.A. de C.V.

Productos Metalúrgicos Salas, S.A. de C.V.

Aleaciones Metalúrgicas, S.A. de C.V.

Hornos de Fundición, S.A. de C.V.

Óxidos y Pigmentos Mexicanos, S.A. de C.V.

Enertec México, S. de R.L. de C.V.**

La Batería Verde, S.A de C.V.**

Reciclajes y Destilados Monterrey, S.A. de C.V.**

Canada (5) USA (14 of 16) Mexico (12 of 25*)

Environmental Performance of the Secondary Lead Smelting Industry

Facilities Processing Spent Lead-acid Lead Batteries in North America

7,586

2,574

15,658

381

6,812

883

1,361

276

2,030

66

574

987

246

48

942

432

43

895

191

9

393

12

5

598

166

5

1990
 Hazardous Trade? 45

Table 1-1. Over 50 percent of the secondary 

lead smelters in Mexico have not reported 

their lead emissions to the RETC. Table 1-1

reveals serious annual data gaps among 

facilities obliged to report lead emissions. 

Moreover, according to Semarnat, some secondary lead smelters in Mexico may also be 

classified as recycling centers and thus are not 

subject to the federal licensing and associated 

RETC reporting requirements for air emissions, 

whereas other smelters employing the same 

foundry practices do not receive a similar classification and must obtain a license from and 

report their emissions to federal authorities.135

A different analysis, illustrated by 

Figure 5-5, has compared RETC data for 

facilities in Mexico with TRI and NPRI data 

from facilities with similar capacities in the 

United States and Canada, respectively, and 

shows that reported lead emissions from lead 

battery recycling plants in Mexico are about 

20 times higher than from plants of similar 

permitted capacity in the United States.136

Although an analysis may provide a general 

yardstick of industry performance, because 

actual capacity figures for these facilities are 

not available (and are usually much lower than 

permitted capacities), more detailed comparison of facilities with similar actual capacities 

is not possible. Despite this shortcoming, we 

believe that potential differences in operating 

capacity cannot account for observed differences in lead emissions. In addition, although 

that analysis provides useful information 

on annual emissions rates, it does not give 

an accurate picture of the ambient air pollution caused by the smelter, the dispersion of 

the lead particles, and the amount of pollution emitted relative to how much lead the 

facility produced. 

Observing Pollution

Control Features

During this study, the CEC Secretariat 

visited smelters in Canada, Mexico and the 

United States. Certain new smelters in Mexico, 

such as JCI’s Enertec plant in García, Nuevo 

León, and La Batería Verde in Estado de México, 

demonstrate features common to modern 

plants in the United States—they are fully 

enclosed and maintain negative pressure to 

limit fugitive dust emissions, and have adopted 

pollution controls to reduce air emissions and 

strict controls to protect worker health and 

safety. In addition, JCI has announced that it will 

upgrade its facility in Ciénega de Flores, Nuevo 

León, purchased in 2005, with more efficient 

furnaces and to environmental control technologies,137 although a specific time frame for 

this upgrade was not given.

135 The Secretariat has also learned that there is a proposal to include air emissions from industrial activities in the recycling of hazardous waste as an activity subject 

to federal authority. Source: e-mail from Óscar Trejo Cuevas, Subdirector of the Licencia Ambiental Única, Semarnat, to Marco Heredia, CEC program manager, 26

October 2012. 136 Occupational Knowledge International and Fronteras Comunes, Exporting Hazards, 17. The 2010 RETC data used for this analysis was later revised for publication, 

which explains why our Table 1-1 and Figure 5-4 give a different amount for Recicladora Industrial de Acumuladores. 137 “Johnson Controls Announces Planned Investment in Its Automotive Battery Recycling Center in Ciénega de Flores, Nuevo León, Mexico,” PR Newswire, 30 August 

2011, <http://www.prnewswire.com/news-releases/johnson-controls-announces-planned-investment-in-its-automotive-battery-recycling-center-in-cienega-deflores-nuevo-leon-mexico-128692183.html>.

Note: PRTR data for 2010, tabulated by OK International. The RETC data were preliminary, later revised for final publication of the 2010 data set.

FIGURE

+ –

5-5 Lead Air Emissions from Recycling Facilities Reporting to RETC (Mexico), NPRI (Canada), 

and TRI (US), 2010

382kg

Quemetco, Inc.

Indianapolis, IN

(110,000 t/yr capacity)

432kg

Tonolli Canada

Mississauga, ON

(70,000 t/yr capacity)

5032kg

Recicladora Industrial de Acumuladores 

Santa Catarina, Nuevo León

(110,400 t/yr capacity)
6
 Hazardous Trade? Hazardous Trade? 47

Key Findings

Levels of Environmental and 

Public Health Protection

The regulatory frameworks covering 

secondary lead smelters in the United States, 

Canada and Mexico do not provide equivalent 

levels of environmental and health protections. Currently, the United States has the 

most stringent overall framework, while in 

Mexico, with significant gaps in its existing 

regulatory framework, certain emission controls and requirements are the least stringent 

and need to be augmented.

Tracking the SLAB Trade 

in North America

 The United States, unlike Canada and 

Mexico, does not require a manifest to 

accompany international shipments of 

SLABs. It also does not require exporters 

of SLABs to obtain a certificate of recovery 

from the recycling facility.

 The United States operates a notice 

and consent system via bilateral agreements with Canada and Mexico that 

addresses the trade in hazardous waste, 

including SLABs.

 In 2012, the environmental agencies in 

Canada, Mexico and the United States 

began to share electronically export 

requests and consent documents for hazardous waste exports, including SLABs, 

through the Notice and Consent Electronic 

Data Exchange (NCEDE) project. This 

system is replacing a paper-based one in 

which governments exchanged notice and 

consent information by mail, fax and cable.

 At present, the US Environmental 

Protection Agency manually enters into a 

database thousands of pieces of information from annual reports submitted by 

exporters of SLABs. 

Exports of US-generated SLABs

Global US Exports

 In terms of the global volume of SLABs 

exported by the United States, according 

to USEPA data Mexico is the leading destination (68 percent), followed by Canada 

(19 percent) and Korea (13 percent).

 Our review of US Census Bureau data 

indicates that exporters are sending SLABs 

to 47 countries where the USEPA has no 

record of having obtained permission from 

those countries to receive the SLABs. 

US-Mexico Trade in SLABs

 According to USEPA data, in 2011 the 

United States exported 389,539,362 kg of 

SLABs to Mexico. According to data from 

US Census Bureau, in 2011 the United 

States exported 342,186,978 kg of SLABs 

to Mexico and imported 191,341 kg. 

 The USEPA export figure is 47,352,382 kg 

higher than the US Census Bureau figure, 

indicating that exporters of SLABs may 

not be correctly classifying that quantity 

of SLABs under the harmonized tariff 

code system. 

 According to our estimates, between 2004

and 2011 US exports to Mexico increased 

by 449–525 percent.

Key Findings 

and Recommendations
48 Key Findings and Recommendations

 Most of the increase in SLAB exports to 

Mexico is attributed to the business development and supply chain management of 

Johnson Controls Inc. (JCI), a US-based, 

globally diversified company. In 2004, 

JCI acquired Ciénega, a smelter in the 

municipality of Ciénega de Flores, Nuevo 

León, near Monterrey, Mexico, and began 

directing both US- and Mexican-generated 

SLABs to that facility for recycling. In 2011, 

JCI opened a secondary smelter, García, in 

the municipality of García in the greater 

Monterrey metropolitan area. According 

to USEPA data, in 2011 JCI’s operations 

at Ciénega accounted for 43 percent of 

all SLAB exports to Mexico, with García

accounting for 31 percent. 

 The remaining 26 percent of the authorized exports of US-generated SLABs 

is being sent to seven facilities in three 

states in Mexico. These seven facilities imported 100,669,466 kg of SLABs 

in 2011.

 We estimate that in 2011 between 12 and 

18 percent of all lead in US-generated 

SLABs was recycled in Mexico, and 

that between 30 and 60 percent of all 

SLABs recycled in Mexico came from the 

United States.

US-Canada Trade in SLABs

 According to Environment Canada data, in 

2011 the United States was a net exporter 

of SLABs to Canada by 86,987,630 kg. 

Between 2004 and 2011, net exports to 

Canada increased 221 percent. 

 A secondary lead smelter in Ontario, 

Tonolli Canada, and one in Quebec, 

Newalta, accounted for about 93 percent 

of these imports from the United States 

in 2011.

 Industry sources and regulatory authorities have informed the CEC Secretariat 

that they do not believe US Census Bureau 

data are a reliable indicator of the historical trade in SLABs to Canada prior to 

2010. We concur in that assessment. Our 

review indicates that prior to 2010 some 

US exporters were improperly classifying 

SLAB exports under the harmonized tariff 

code 8548102500.

 We estimate that US net exports in 2011

to Canada represented about 4 percent of all lead in US-generated SLABs, 

and that the net export of SLABs from 

the United States accounted for about 

31 percent of Canadian secondary 

lead production.

Data Reliability and Compliance in 

the United States 

 The Secretariat’s research has revealed 

data discrepancies that may indicate 

two compliance issues warranting 

further review by the appropriate US 

government agencies. The magnitude and relative importance of these 

issues were previously unknown to 

regulatory agencies. 

• First, as noted previously, our review 

of USEPA and US Census Bureau data 

indicated that 47,352,382 kg of SLABs 

were exported to Mexico in 2011

without having the proper harmonized 

tariff code applied. 

• Second, also as noted previously, 

our review of US Census Bureau data 

indicates that exporters are sending 

SLABs to countries where USEPA has 

no record of having obtained permission from those countries to receive the 

SLABs. To the extent this has occurred, 

it would be a violation of US law and 

potentially a violation of the importing 

countries’ laws. 

Data Reliability across North America

In addition, we note that data on the import 

and export volumes compiled within both 

the US and Mexico by different agencies—in 

Mexico by Semarnat and Profepa and in the 

US by the USEPA and US Census Bureau—

are not consistent. Moreover, national 

cross-border accounts in all three countries 

do not accord with shipping or receiving 

volumes from either sending or receiving 

countries. Agencies responsible for such 

monitoring within and across borders need 

to work together to improve the availability, 

accuracy, and comparability of data across 

North America.

Permitting Secondary Lead Smelters 

in North America

 In the United States, Canada and Mexico, 

secondary lead smelters operate under 

permits or licenses that contain conditions 

that are enforceable against the facility. 

 In the United States, state governments 

issue pollution discharge permits under 

the authority of federal environmental 

statutes. Although the federal government 

[US] exporters 

are sending 

SLABs to 

countries where 

USEPA has 

no record of 

having obtained 

permission 

from those 

countries to 

receive SLABs.

’

’
 Hazardous Trade? 49

sets minimum standards, state requirements may in most instances exceed the 

federal requirements. 

 In Canada, the provinces issue permits, 

based on provincial law, that reflect a collaborative process between the regulator 

and the regulated entity. 

 In Mexico, the federal government 

issues operating permits for secondary 

lead smelting facilities based on federal 

environmental statutes. These permits 

specify operational conditions, processes 

and technologies, and address issues 

such as environmental impacts, licensing 

requirements for air emissions, and the 

management of hazardous waste. 

Environmental Standards and 

Performance in Mexico for 

SLAB Recycling

 Notwithstanding Mexico’s permitting 

process, important gaps remain within 

its overall regulatory framework, as 

well as with respect to the prevailing 

environmental and public health standards in the United States and Canada. 

Specifically, Mexico: 

• lacks regulations that establish 

lead emission limits from stacks 

and contain requirements to control 

fugitive emissions; 

• lacks regulations that require secondary 

lead smelters to have management 

plans to address stormwater discharges 

and releases of lead to the soil;

• has not finalized regulations that would 

address outstanding hazardous waste 

management plans in the industry;

• has not issued an official standard 

(Norma Oficial Mexicana—NOM) 

addressing the construction, operation 

and closure of secondary lead smelters; 

• has yet to complete a standard for the 

characterization and remediation of 

sites contaminated with lead (and other 

pollutants); and 

• does not have a blood lead level standard that includes a protocol for the 

medical removal of workers who exceed 

the specified levels. 

 The United States strengthened its 

ambient air standard for lead in 2008. 

Thus today the ambient air standard in 

Mexico is 10 times less stringent than that 

in the United States.

 Moreover, Mexico’s network of ambient air 

monitoring is incomplete. Air quality data 

for lead concentrations near all secondary 

lead smelters are unavailable, and no data 

are publicly available on stack emissions 

from secondary lead smelting facilities. 

 The requirement that companies report 

pollution release data is not applied 

and enforced consistently across the 

secondary lead smelting industry. Over 

50 percent of the secondary lead smelters 

in Mexico have not reported their lead 

emissions to the RETC program.

 Finally, although some companies in 

Mexico indicate that they strive to meet 

US standards, the Secretariat is unable 

to evaluate the performance of individual 

facilities and to assess the health risks to 

workers and the general population from 

lead emissions caused by secondary lead 

smelting facilities in Mexico. This situation 

stems from the absence of publicly available performance data on lead emissions 

and the lead concentration in the ambient 

air near secondary lead smelters, and on 

the overall blood lead levels of workers in 

the industry.
50

Recommendations

The CEC Secretariat recommends that the 

governments of Canada, Mexico and the 

United States adopt six broad goals to 

address the findings presented in this report. 

For each of these goals, we have offered 

specific steps that governments can take to 

help realize them. These recommendations 

are designed to improve the management 

of information across North America and to 

ensure that adequate measures are in place 

to protect workers and the general public 

from the lead emitted during the recycling 

of spent lead-acid batteries in Mexico.

1 Raise the Bar

(North America) 

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 United States. Raising the 

bar across North America to equivalent 

levels will avoid the development of 

pollution havens and provide greater 

levels of environmental and public 

health protection.

2 Improve Trade Compliance Efforts

(North America)

Canada, Mexico and the United States 

should streamline and improve the flow 

of notice and consent information and the 

tracking of SLABs. Specifically: 

 The United States should require the 

use of manifests for each international 

shipment of SLABs, and it should require 

exporters to obtain a certificate of 

recovery from the recycling facility. 

 Canada, Mexico and the United States 

should cooperate to allow the regulated community to submit export 

requests electronically. 

 Finally, Canada, Mexico and the United 

States should work together to share 

the import and export data maintained 

by their respective environmental and 

border agencies. This information sharing 

could be used to identify trends that may 

require a policy response or that may raise 

compliance issues.

The goals of these recommendations are 

to reduce administrative burdens, improve 

data quality, make it easier to provide data 

to environmental enforcement and border 

protection agencies for compliance purposes, 

facilitate the adoption of emerging tracking 

technologies, and help the governments provide timelier and more reliable and coherent 

information on what crosses their national 

borders.

3 Close Information and 

Performance Gaps 

(Mexico)

Mexico should establish a regulatory 

framework that covers the entire 

industry and provides public health and 

environmental protections functionally 

equivalent to those in the United States. 

The following points are applicable to 

this framework:

 It should be based on performance data 

from the completion or establishment of 

a comprehensive monitoring system to 

measure lead air emissions from every 

secondary lead smelter. More specifically:

• Performance data, including average 

stack emissions and ambient air lead 

concentrations near smelters, should be 

collected by competent environmental 

authorities and compared across the 

entire sector.

• Performance data should be provided to 

environment and health authorities at 

the federal, state and municipal levels, 

as well as to the public, on a periodic 

and timely basis.

• Performance data should be compared 

against Mexico’s existing ambient air 

standard of 1.5 micrograms per cubic 

meter (μg/m3

) to identify the most 

pressing gaps in meeting this standard.

 It should establish standards for stack 

and fugitive lead emissions functionally 

equivalent to those in the United States. 

 It should adopt an ambient lead standard 

that is functionally equivalent to that of 

the United States.

 A medical removal limit should be included 

in the requirement to test the blood lead 

levels of workers in the battery recycling 

and manufacturing sectors.

 Secondary lead smelting facilities 

should be required to have storm water 

Key Findings and Recommendations
 Hazardous Trade? 51

management plans, and standards and criteria should be issued for the development 

of hazardous waste management plans.

 Clear standards should be established for 

the construction, operation and closure of 

secondary lead smelters. 

 A standard should be established for the 

characterization and remediation of sites 

contaminated with lead. In line with this, 

a policy mechanism should be established to ensure secure funding, sound 

management, and appropriate oversight 

of remediation of contaminated sites in 

Mexico.

 All facilities that undertake secondary lead 

smelting in Mexico should be required to 

report and publicize pollutant releases and 

transfers to the federal RETC program.

 Mexico should continue efforts to identify, 

halt and deter any SLAB recycling and 

lead recovery operations in the informal or 

clandestine sector.

 The Secretariat of Environment and 

Natural Resources (Secretaría de Medio 

Ambiente y Recursos Naturales—

Semarnat), the Office of the Federal 

Attorney for Environmental Protection 

(Procuraduría Federal de Protección al 

Ambiente—Profepa) and other federal 

agencies should have sufficient resources 

to ensure adherence to the law and protect 

public health and the environment.

4 Ensure Accurate and Comparable 

Information on Lead Emissions

(North America)

 Performance data—including facilityspecific stack emissions estimates, average 

ambient lead concentrations, and worker 

blood lead levels, as collected by competent environmental authorities in Canada, 

Mexico and the United States—should be 

maintained in a central North American 

repository and made available to the public. 

 Emission data specific to the secondary 

lead smelting sector, as reported to each 

country’s respective pollutant release 

and transfer registry (PRTR), should be 

catalogued and made available to the 

public via the CEC’s North American 

PRTR initiative.

 CEC support of Mexico’s PRTR initiative 

(Registro de Emisiones y Transferencia de 

Contaminantes—RETC) should continue, 

to ensure that comprehensive, comparable 

and quality data are available on the 

reported releases and transfer of lead by 

Mexico’s secondary lead smelters.

5 Support Best Practices

(North America)

The governments of Canada, Mexico and 

the United States should work together 

with the North American secondary lead 

smelting industry and nongovernmental 

organizations to develop strategies to 

support the adoption of best practices 

throughout the region. This effort should 

include the following:

 Support Mexico to enact legislation 

to establish a comprehensive battery 

stewardship program requiring the 1:1

exchange and recycling of batteries in only 

the highest-performing facilities. Such 

legislation would be expected to establish 

minimum deposit fees and control the 

return of used batteries to authorized recycling facilities throughout Mexico.

 Given the integrated nature of the SLAB 

recycling market in North America, ensure 

trilateral stakeholder input into any new 

stewardship or voluntary market-based 

mechanisms intended to drive continuous 

improvements in the industry throughout 

North America.

6 Foster Regional Cooperation 

and Technical Assistance

(North America)

The North American governments, through 

the CEC or other appropriate venues, 

should cooperate to ensure:

 a plan of action to share information, 

technical assistance and best practices in 

order to assist Mexico in implementing the 

recommendations contained in this report;

 the highest level of comparable and 

publicly available information on the performance of the secondary lead smelting 

sector throughout North America; and

 enhanced cooperation and encouragement of cross-border support and 

intelligence-sharing on any illegal or 

unsanctioned traffic in SLABs across 

North American borders.

Emissions data 

specific to the 

secondary lead 

smelting sector, 

as reported to 

each country’s 

respective 

PRTR, should be 

catalogued and 

made available 

to the public 

via the CEC’s 

North American 

PRTR initiative.

’

’
52

The Office of the Federal Attorney for 

Environmental Protection (Procuraduría 

Federal de Protección al Ambiente—Profepa) 

inspects the import, export and return of 

spent lead-acid batteries (SLABs) at the country’s main ports of entry and customs offices. 

For this purpose, it reviews the documents evidencing the legal source of the waste, such as 

carrier authorizations and bonds or insurance 

guaranteeing the payment of environmental 

damages caused in the case of incidents 

associated with the handling of SLABs. 

Profepa also verifies the environmentally 

sound management of SLABs, including 

ad hoc carriers, proper product identification and hazard signage, absence of leaks 

or seepage, that carriers have the necessary 

emergency equipment, and that batteries are 

properly stacked. 

The flows of SLABs shown in the 

following tables occurred during 2011 and 

2012 (all data collected by Profepa for those 

years, see Tables A-1 through A-4).

Appendix 1

Inspection and Oversight of the Transboundary 

Movement of Spent Lead-acid Batteries in Mexico

Table A-1. Spent Lead-acid Battery Importers and Exporters during 2011 and 2012 

Imports 2011

Company name No. of 

movements

Approximate quantities 

recorded in SIREV (tons)

Quantities 

as % of total

Quantity authorized 

by Semarnat

Corporación Pipsa, S.A. de C.V. 1,020 19,422.61 5.01 69,600

Eléctrica Automotriz Omega, S.A. de C.V. 434 8,778.98 2.26 35,200

Enertec Exports, S. de R.L. de C.V. 251 72,318.20 18.65 408,213

Enertec México, S. de R.L. de C.V. 706 203,261.64 52.42 486,056

Hornos de Fundición, S.A. de C.V. 6 110.52 0.03 2,000

M3 Resources México, S. de R.L. de C.V. 1,931 33,476.79 8.63 40,000

Omega Solder México, S.A. de C.V. 66 1,287.44 0.33 3,600

Óxidos y Pigmentos Mexicanos, S.A. de C.V. 450 8,611.23 2.22 12,500

Recicladora Industrial de Acumuladores, 

S.A. de C.V. 562 40,489.86 10.44 79,929

Total 5,426 387,757.28 100.00 1,137,098

Exports 2011

Company name No. of 

movements

Approximate quantities 

recorded in SIREV (tons)

Quantities 

as % of total

Quantity authorized 

by Semarnat

Exide de México, S. de R.L. de C.V. 10 194.52 100.00 1,920

Total 10 194.52 100 1,920
CEC – CEC – Hazardous Trade? Hazardous Trade? Hazardous Trad Hazardous Tradee?? 53

Table A-2. Spent Lead-acid Battery Importers and Exporters during 2012

Imports 2012

Company name Movements Approximate tons Quantities 

as % of total

Quantity authorized 

by Semarnat

Corporación Pipsa, S.A. de C.V. 29 567 0.15 24,000 

Eléctrica Automotriz Omega, S.A. de C.V. 30 621 0.17 10,000 

Enertec Exports, S. de R.L. de C.V. 1,093 313,292 84.44 493,914 

Enertec México, S. de R.L. de C.V. 59 1,054 0.28 *

M3 Resources México, S. de R.L. de C.V. 1,678 31,551 8.50 48,000 

Omega Solder México, S.A. de C.V. 8 158 0.04 3,600 

Óxidos y Pigmentos Mexicanos, S.A. de C.V. 175 3,354 0.90 15,900 

Recicladora Industrial de Acumuladores, 

S.A. de C.V. 253 20,409 5.50 76,000 

Total 3,325 371,006 100 671,414 

* Note: Ruling issued by DGGIMAR without authorization for the company, because the waste is in the border region.

Exports 2012

Company name Movements Approximate tons Quantities 

as % of total

Quantity authorized 

by Semarnat

Residuos Industriales Multiquim, 

S.A. de C.V. 1 9.93 100 20

Total 1 9.93 100 20

Table A-3. Companies filing Return Notices for Spent Lead-acid Batteries during 2011

Company name No. of movements Quantities recorded 

in SIREV (tons)

Quantities 

as % of total

Accuride Internacional, S.A. de C.V. 2 2.821 0.86

Ademco de Juárez, S. de R.L. de C.V. 13 1.383 0.42

Ascotech, S.A. de C.V. 3 0.0805 0.02

Autopartes y Arneses de México, S.A. de C.V. 1 1.016 0.31

Black & Decker de Reynosa, S. de R.L de C.V. (Planta 3) 4 0.918 0.28

Black & Decker de Reynosa, S. de R.L. de C.V. (Planta 1) 12 62.779 19.24

Bose, S.A. de C.V. 2 0.2035 0.06

California Metals and Electronics México, S.A. de C.V. 1 4.057 1.24

Compañía Rinquim, S.A. de C.V. 16 3.975 1.22

Componentes Universales de Matamoros, S.A. de C.V. 1 0.089 0.03

Controles Reynosa, S.A. de C.V. (Planta 2) 5 0.993 0.30

Controles Reynosa, S.A. de C.V. (Planta 1) 7 1.616 0.50

Cordis de México, S.A. de C.V. 3 0.237 0.07
54 appendiX 1

Covalence Specialty Materials México, S. de R.L. de C.V. 1 0.021 0.01

Critikon de México, S. de R.L. de C.V. 4 0.154 0.05

Delphi Delco Electronics de México, S. de R.L de C.V. 

(Deltronicos Operations) 1 2.879 0.88

Eaton Industries, S. de R.L. de C.V. 7 2.34 0.72

EES, S.A. de C.V. 13 0.101 0.03

Electrónica BRK de México, S.A. de C.V. 1 2.555 0.78

Ensambladora de Matamoros, S. de R.L. de C.V. 4 6.3465 1.94

Ensatec, S.A. de C.V. 1 0.026 0.01

Fortune Plastic Metal de México, S.A. de C.V. 2 16.647 5.10

Fram Group Operations Mexicali, S.A. de C.V. 1 0.03 0.01

Globe Motors de México, S.A. de C.V. 2 0.021 0.01

Grupo Ambiental del Noroeste, S. de R.L. de C.V. 3 0.613 0.19

Honeywell Productos Automotrices, S.A. de C.V. 1 0.041 0.01

Honeywell Aerospace de México, S. de R.L. de C.V. 3 0.08 0.02

INTEL Tecnología de México, S.A. de C.V. 8 5.739 1.76

M3 Resources México, S. de R.L. de CV. 3 51.988 15.93

Mabamex, S.A. de C.V. 3 1.119 0.34

Motorola de Juárez, S. de R.L. de C.V. 3 1.388 0.43

Motorola Solutions de Juárez, S. de R.L. de C.V. 5 1.268 0.39

Pacific Treatment Environmental Services, S.A. de C.V. 63 5.303 1.62

Power Sonic, S.A. de C.V. 21 139.151 42.64

Puertas y Vidrios de Matamoros, S.A. de C.V. 1 1.525 0.47

Rectificadores Internacionales, S.A. de C.V. 1 0.016 0.00

Robert Bosch Sistemas Automotrices, S.A. de C.V. 1 0.177 0.05

Scientific Atlanta de México, S. de R.L. de C.V. 3 1.262 0.39

Servicios Ambientales Mexicanos, S.A. de C.V. 1 0.027 0.01

Sony Nuevo Laredo, S.A. de C.V. 1 1.051 0.32

System Sensor de México, S. de R.L. de C.V. 3 0.145 0.04

Tecnologías Internacionales de Manufactura, S.A. de C.V. 1 0.013 0.00

Termocontroles de Juárez, S.A. de C.V. 4 2.017 0.62

Termotec de Chihuahua, S.A. de C.V. 4 0.206 0.06

TRW Electrónica Ensambles, S.A. de C.V. 1 1.84 0.56

TYCO International de México, S. de R. L. de C.V. 1 0.1 0.03

Total 242 326.358 100

 Table A-3.

Company name No. of movements Quantities recorded 

in SIREV (tons)

Quantities 

as % of total
CEC – CEC – Hazardous Trade? Hazardous Trade? Hazardous Trad Hazardous Tradee?? 55

Table A-4. Companies Filing Return Notices for Spent Lead-acid Batteries during 2012

Company name Transboundary 

movements

Approximate tons Quantities 

as % of total

Accuride International, S.A. de C.V. 1 0.277 0.11

ADC de Juárez, S. de R.L. de C.V. 3 3.073 1.26

Ademco de Juárez, S. de R.L. de C.V. 19 1.834 0.75

Ascotech, S.A. de C.V. 2 0.054 0.02

Autopartes y Arneses de México, S.A. de C.V. 4 0.043 0.02

Bendix CVS de México, S.A. de C.V. 2 2.162 0.88

Black & Decker de Reynosa, S. de R.L. de C.V. (Planta 1) 5 14.530 5.95

Buenaventura Autopartes, S.A. de C.V. 1 0.855 0.35

Celestica de Reynosa, S.A. de C.V. 3 1.838 0.75

Controles Reynosa, S.A. de C.V. (Planta 2) 2 0.272 0.11

Controles Reynosa, S.A. de C.V. (Planta 1) 2 0.147 0.06

Cordis de México, S.A. de C.V. 4 0.479 0.20

Critikon de México, S. de R.L. de C.V. 2 0.158 0.06

Cummins Juárez, S.A. de C.V. 2 0.430 0.18

Dafmex, S. de R.L. de C.V. 2 0.209 0.09

Eaton Industries, S. de R.L. de C.V. 1 0.038 0.02

EES, S.A. de C.V. 3 0.036 0.01

Ensambladora de Matamoros, S. de R.L. de C.V. 1 4.000 1.64

Ensambladora de Matamoros, S. de R.L. de C.V. 2 3.000 1.23

Fram Group Operations Mexicali, S.A. de C.V. 1 0.059 0.02

Globe Motors de México, S.A. de C.V. 6 0.081 0.03

Grupo Ambiental del Noroeste, S. de R.L. de C.V. 2 0.850 0.35

Grupo Ambiental del Noroeste, S. de R.L. de C.V. 3 0.209 0.09

Harman de México, S.A. de C.V. 1 0.055 0.02

Intel Tecnología de México, S.A. de C.V. 11 0.282 0.12

Juver Industrial (Planta 2) 4 3.694 1.51

Juver Industrial, S.A. de C.V. 1 0.005 0.00

M3 Resources México, S. de R.L. de C.V. 2 31.927 13.07

Motorola Solutions de Juárez, S. de R.L. de C.V. 9 3.763 1.54

North Safety de Mexicali, S. de R.L. de C.V. 1 0.003 0.00

Pacific Treatment Environmental Services, S.A. de C.V. 43 10.052 4.11

Pacific Treatment Environmental Services, S.A. de C.V. / 

Comunicaciones de Calidad, S. de R.L. de C.V. 3 0.418 0.17

Pacific Treatment Environmental Services, S.A. de C.V. / 

Honeywell Productos Automotrices, S.A. de C.V. 2 0.009 0.00
56 appendiX 1

Pacific Treatment Environmental Services, S.A. de C.V. / 

Industrias Electrónicas Pacifico, S.A. de C.V 1 0.004 0.00

Pacific Treatment Environmental Services, S.A. de C.V. / 

Plamex, S.A. de C.V. 2 0.007 0.00

Pall México Manufacturing, S. de R.L. de C.V. 1 0.004 0.00

Power Sonic, S.A. de C.V. 18 35.361 14.47

Power Sonic, S.A. de C.V. 29 79.993 32.73

Puertas y Vidrios de Matamoros, S.A. de C.V. 1 1.525 0.62

Raychem Juárez, S.A. de C.V. 1 0.100 0.04

Robert Bosch Sistemas Automotrices, S.A de C.V. 3 0.139 0.06

Scientific Atlanta de México, S. de R.L. de C.V. 7 11.383 4.66

Sippican de México, S. de R.L. de C.V. 1 0.104 0.04

Sony Nuevo Laredo, S.A. de C.V. 5 15.544 6.36

System Sensor de México, S. de R.L. de C.V. 7 1.369 0.56

Tecnología Autoelectrónica de Durango, S. de R.L. de C.V. 1 4.894 2.00

TED de México, S.A. de C.V. 2 0.335 0.14

Termocontroles de Juárez, S.A. de C.V. 2 0.226 0.09

Termotec de Chihuahua, S.A. de C.V. 1 0.050 0.02

Toro Company de México, S. de R.L. de C.V. 1 4.480 1.83

Tyco International de México, S. de R.L. de C.V. 3 0.612 0.25

Valeo Sistemas Electrónicos, S. de R.L. de C.V. 3 1.139 0.47

Wistron México, S.A. de C.V. 1 2.260 0.92

Total 240 244.368 100.00

 Table A-4.

Company name Transboundary 

movements

Approximate tons Quantities 

as % of total

Annual Inspection Program

Given the hazards posed by the unsound 

management of SLABs, Profepa established an annual inspection program aimed 

at establishments authorized to recycle 

and import hazardous waste (Table A-5). 

It also asked some of its regional offices 

(delegations) to conduct inspection visits at 

establishments that, according to information 

from the Central Customs Competency and 

Modernization Administration (Administración 

Central de Competencia y Modernización 

Aduanera), have imported and exported 

SLABs (Table A-6). 
CEC – CEC – Hazardous Trade? Hazardous Trade? Hazardous Trad Hazardous Tradee?? 57

Table A-5. Spent Battery Inspection Program for 67 Industrial Establishments with 

Transboundary Movements in 2010–2011, 2012

Inspection Summary (2010–2011)*

State Two-year inspection goal (2010–2011) % Completed

Baja California 15 100

Chihuahua 12 100

Jalisco 14 100

Nuevo León 9 100

Tamaulipas 9 100

Central Offices 6 100

Mexico City Metropolitan Area 2 100

Total 67 100

*Irregularities (2010–2011) Inspections

Not in operation 2

Serious irregularities; no information submitted 31

Slight irregularities; partial information submitted 20

Company not at address 2

No irregularities 5

Company located in other state 1

Urgent measures 6

Total 67

Inspection Summary (2010–2012)

State 2010 # Completed 2011 # Completed 2012 # Completed

Baja California 11 4 5

Chihuahua 11 1 1

Jalisco 10 4 4

Nuevo León 7 2 2

Tamaulipas 7 2 2

Mexico City Metropolitan Area 2 2

Central Offices 5 1

Total Completed 51 16 16
58 appendiX 1

Table A-6. Program to Verify 40 Hazardous Waste Importation Authorizations

State 2010 

Goal

2010 

Completed

2011 

Goal

2011 

Completed

2012 

Goal

2012 

Completed

Baja California 11 8 4 1 6 6

Chihuahua 11 11 1 1

Jalisco 10 4 2 2

Nuevo León 7 4 2 24 24

Tamaulipas 7 7 2 2 5 5

Querétaro 1 1

Coahuila 1 1

Mexico City Metropolitan Area 2 1 1

Central Offices 5 1

 Total 46 35 15 5 40 40

Irregularities Inspections

Slight irregularities; 

partial information submitted 25

No irregularities 3

Company not in operation 2

Urgent measures 9

Slight irregularities 1

Total 40
CEC – CEC – Hazardous Trade? Hazardous Trade? Hazardous Trad Hazardous Tradee?? 59

Joint Inspection with Customs

Between 30 January and 4 February 2012, 

a joint inspection was carried out with the 

General Customs Administration at the 

Tijuana, Baja California customs office, to 

inspect allegedly illegal shipments of SLABs. 

Profepa’s Institutional Inspection Records 

System (Sistema Institucional del Registro 

de Verificación) had identified unreported 

transboundary movements. In this regard, 

there is a ruling establishing the classification and coding of merchandise whose import 

and export is subject to regulation by the 

Secretariat of the Environment and Natural 

Resources (Secretaría de Medio Ambiente y 

Recursos Naturales—Semarnat).

The customs office inspected shipments 

that, according to the tariff sections listed 

in Table A-7, might be used for illegal transboundary movements. The inspection did not 

find any illegal shipments.

Unsound Management of SLABs

Profepa performs inspection and oversight 

actions to verify the handling of SLABs, 

which are deemed hazardous waste subject 

to management plans, following environmental, technological, economic and social 

efficiency criteria.

In October 2011, the Profepa Delegation 

in the State of Chihuahua stopped a trailer 

improperly carrying 1,800 lead-acid batteries. 

The vehicle is still in custody and the hazardous waste was forwarded for disposal.

In February 2012, the Profepa Delegation 

in the Aguascalientes stopped a truck carrying 

148 SLABs without Semarnat authorization. 

Following an administrative proceeding, the 

batteries were sent for recycling.

That same month, the Profepa Delegation 

in Morelos inspected a collection center to 

verify compliance with the terms, conditions 

and effective term of the Semarnat authorization. The permit was not in effect and the 

authorized storage quantity was exceeded 

(1,360 SLABs, compared to the allowable 

quantity of 1,200). The facility was subject 

to partial temporary closure and ordered to 

suspend the receiving of batteries). 

In February 2012, the Profepa Delegation 

in Chiapas inspected an establishment selling 

batteries and lubricants, where 300 SLABs 

were being stored without having an area 

set aside for hazardous waste and without 

proper safety measures. The facility was not 

authorized to store and transport waste. The 

establishment was preventively secured and 

the applicable penalties will be levied.

In March 2012, Profepa’s Morelos office 

inspected another establishment collecting 

SLABs, finding 15 tons of SLABs stored 

without Semarnat authorization. The waste 

was placed under preventive attachment. 

In April 2012 the Profepa Delegation in 

Tamaulipas inspected a recycling company in 

the Municipality of Reynosa, finding several 

irregularities, such as the failure to characterize the metal casings in contact with acids 

and occupational lead levels in excess of the 

maximum allowable limits. Urgent corrective 

measures were ordered.

In April, the Aguascalientes Delegation 

found a truck carrying a total of 427 SLABs 

of different sizes, without Semarnat authorization. Officials requested the support 

of the Office of the Federal Attorney for 

Environmental Protection to secure the 

vehicle and its load; the company was 

ordered to forward the hazardous waste for 

disposal. Administrative proceedings were 

filed against the carrier.

Lastly, also in April 2012, the Profepa 

Delegation in the State of Chihuahua stopped 

a trailer carrying 2,700 kg of lead-acid batteries and 1,900 kg of contaminated brass 

scrap. The inspection report found inconsistencies with respect to the destination and 

documentation submitted by the carrier, 

although the waste appeared to be correctly 

contained and identified.

Profepa actions have prevented the 

unsound management of 4,462 SLABs, equivalent to 66,930 tons of hazardous waste, 

thereby preventing air pollution emissions 

and soil contamination. 
60 appendiX 1

Table A-7. Tariff Codes of Interest

Code 

Number

Chapter Heading Subheading Section

39159099 Plastics and articles thereof Waste, parings and scrap, 

of plastics

Of other plastics Other

78020001 Lead and articles thereof Lead waste and scrap Lead waste and scrap Lead waste and scrap

85489099 Electrical machinery and 

equipment and parts 

thereof; sound recorders 

and reproducers, television 

image and sound recorders 

and reproducers, and 

parts and accessories of 

such articles

Waste and scrap of primary 

cells, primary batteries and 

electric storage batteries; 

spent primary cells, spent 

primary batteries and spent 

electric storage batteries; 

electrical parts of machinery 

or apparatus, not specified 

or included elsewhere in 

this chapter

Other Other

85489003 Electrical machinery and 

equipment and parts 

thereof; sound recorders 

and reproducers, television 

image and sound recorders 

and reproducers, and 

parts and accessories of 

such articles

Waste and scrap of primary 

cells, primary batteries and 

electric storage batteries; 

spent primary cells, spent 

primary batteries and spent 

electric storage batteries; 

electrical parts of machinery 

or apparatus, not specified 

or included elsewhere in 

this chapter

Other Printed circuit 

assemblies comprising electrical and/

or electronic components mounted on a 

printed circuit board, 

except as included 

in section

85071001 Electrical machinery and 

equipment and parts 

thereof; sound recorders 

and reproducers, television 

image and sound recorders 

and reproducers, and 

parts and accessories of 

such articles

Electric accumulators, 

including separators thereof, 

whether or 

not rectangular 

(including square)

Lead-acid storage 

batteries, of a kind 

used for starting 

piston engines

Recognizable 

for aircraft

85071099 Electrical machinery and 

equipment and parts 

thereof; sound recorders 

and reproducers, television 

image and sound recorders 

and reproducers, and 

parts and accessories of 

such articles

Electric accumulators, 

including separators thereof, 

whether or 

not rectangular 

(including square)

Lead-acid storage 

batteries, of a kind 

used for starting 

piston engines

Other

85072003 Electrical machinery and 

equipment and parts 

thereof; sound recorders 

and reproducers, television 

image and sound recorders 

and reproducers, and 

parts and accessories of 

such articles

Electric accumulators, 

including separators thereof, 

whether or 

not rectangular 

(including square)

Other lead-acid 

storage batteries

Of a kind used as 

the primary source 

of electrical power 

for electrically 

powered vehicles
CEC – CEC – Hazardous Trade? Hazardous Trade? Hazardous Trad Hazardous Tradee?? 61

85072004 Electrical machinery and 

equipment and parts 

thereof; sound recorders 

and reproducers, television 

image and sound recorders 

and reproducers, and 

parts and accessories of 

such articles

Electric accumulators, 

including separators thereof, 

whether or 

not rectangular 

(including square)

Other lead-acid 

storage batteries

Lead-acid, with 

internal gas recycling 

system, sealed, with 

immobilized electrolyte, for electronics, 

weighing less than 

9 kg, with screw or 

clip terminals

85072099 Electrical machinery and 

equipment and parts 

thereof; sound recorders 

and reproducers, television 

image and sound recorders 

and reproducers, and 

parts and accessories of 

such articles

Electric accumulators, 

including separators thereof, 

whether or 

not rectangular 

(including square)

Other lead-acid 

storage batteries

Other

85078099 Electrical machinery and 

equipment and parts 

thereof; sound recorders 

and reproducers, television 

image and sound recorders 

and reproducers, and 

parts and accessories of 

such articles

Electric accumulators, 

including separators thereof, 

whether or 

not rectangular 

(including square)

Other batteries Other accumulators

85079003 Electrical machinery and 

equipment and parts 

thereof; sound recorders 

and reproducers, television 

image and sound recorders 

and reproducers, and 

parts and accessories of 

such articles

Electric accumulators, 

including separators thereof, 

whether or 

not rectangular 

(including square)

Parts Parts

39159099 Plastics and articles thereof Waste, parings and scrap, 

of plastics

Of other plastics Other

39159001 Plastics and articles thereof Waste, parings and scrap, 

of plastics

Of other plastics Of products made 

of polymethyl 

methacrylate

 Table A-7.

Code 

Number

Chapter Heading Subheading Section
62

Appendix 2

Sources of US SLAB Export Data Compared

Country 2011 Census Bureau 

data 

total (kg)

2011 EPA data 

total (kg)

AFGAN[ISTAN] 48

ANG[UI]LLA 5,469

ANGOLA 376

[UNITED] ARAB EM[IRATES] 10,323

AUSTRAL[IA] 16

B[RITISH] VIRG[I]N [ISLANDS] 30,098

BAHAMAS 16,117

BELGIUM 9,729

BOLIVIA 1,072

BRAZIL 3,852

C[OSTA] RICA 17,997

CANADA 104,767,399 107,832,627.56

CAYMAN [ISLANDS] 12,494

CHILE 33,413

CHINA 13,643

COLOMB[IA] 501,583

CONGO-B[RAZZAVILLE] 2,200

DOM[INICAN] REP[UBLIC] 20,515

DOMINCA 229,553

ECUADOR 2,280

EGYPT 449

F[RENCH] GUIAN[A] 146

FRANCE 5,601

GERMANY 119,431

GRENADA 1,225

GUAT[A]M[ALA] 218

GUYANA 5,009

HAITI 4,271
CEC – CEC – Hazardous Trade? Hazardous Trade? Hazardous Trad Hazardous Tradee?? 63

H[ON]G KONG 12,928

HONDURA[S] 129,525

INDIA 80

JAMAICA 60,210

JAPAN 1,758

KOREA, REP[UBLIC OF] 1,239,319 72,317,813.39 

LIBERIA 500

LIBYA 69

MEXICO 342,186,978 389,539,361.60 

N[ETHERLANDS] ANTIL[LES] 2,064

NETHERL[AN]DS 8,738

PANAMA 45,878

PERU 788,978 464,890.00 

R[EPUBLIC OF THE] PHIL[IPPINES] 15,876 31,987.33 

S[ANTA] LUCIA 3,238

S[AINT] MAARTEN 1,949

S[T] VIN[CENT & THE] GR[ENADINES] 2,612

SALVAD[O]R 4,913

SINGAP[O]R[E] 19,938

SPAIN 9,433,555 1,271,645.00 

ST K[ITTS &] N[EVIS] 39,762

TRINID[AD & TOBAGO] 10,038

TURK[S AND CAICOS] IS[LANDS] 1,814

U[NITED] KING[DOM] 1,500 88,622.37 

URUGUAY 9,371

VENEZ[UELA] 27,088

Total kg 459,863,206.00 571,546,947.26 

Source: See notes 65 and 66 and accompanying text for information on the source of these data.

 Appendix 2

Country 2011 Census data 

total (kg)

2011 EPA data 

total (kg)
64

Appendix 3

Status and Membership of Mexico’s Secondary 

Lead Recyclers in the Programa Nacional de Auditoría Ambiental (Industria Limpia)

Company Status in Programa Nacional de 

Auditoría Ambiental (PNAA)

Enertec Exports, S. de R.L. de C.V. - Planta Ciénega de Flores Not in PNAA

Enertec México, S. de R.L. de C.V. - Planta García, Nuevo León Not in PNAA

Recicladora Industrial de Acumuladores, S.A. de C.V. No longer in PNAA – certificate expired on 10 November 2011

Corporación PIPSA, S.A. de C.V. No longer in PNAA – did not submit statement of work under 

action plan within deadline

M3 Resources México, S.A. de C.V. Not in PNAA

Eléctrica Automotriz Omega, S.A. de C.V. Planta 

Doctor González

Valid Clean Industry certificate – expires 29 November 2013

La Batería Verde, S.A. de C.V. Not in PNAA

Productos Metalúrgicos Salas, S.A. de C.V. Participating in PNAA – about to begin field work

Óxidos y Pigmentos Mexicanos, S.A. de C.V. Participating in PNAA – implementing action plan

Hornos de Fundición, S.A. de C.V. Not in PNAA

Aleaciones Metalúrgicas, S.A. de C.V. No longer in PNAA – did not complete activities defined 

in action plan following environmental audit

Reciclajes y Destilados Monterrey, S.A. de C.V. Not in PNAA

Industrial Mondelo, S. de R.L. de C.V. No longer in PNAA – did not complete activities defined 

in action plan following environmental audit

Metalúrgica Xicohténcatl, S. de R.L. de C.V. Not in PNAA

South American Metals, S. de R.L. de C.V. No longer in PNAA – did not complete requirements 

necessary to sign coordinating agreement

Martha Alicia Boites Jiménez Not in PNAA

Versisa, S.A. de C.V. Not in PNAA

Omega Solder México, S.A. de C.V. Participating in PNAA – implementing action plan

Fundametz México, S.A. de C.V. (centro de acopio) No longer in PNAA – did not complete activities defined 

in action plan following environmental audit

Sion Acumuladores, S.A. de C.V. Not in PNAA

Funofec, S.A. de C.V. Not in PNAA

Dian Procesos Metalúrgicos, S.A. de C.V. Not in PNAA

Transformadora del Centro de Michoacán 

“Éric Bobadilla 2006”

Not in PNAA

Productos Metalúrgicos Poblanos, S.A. de C.V. Not in PNAA

Industria de Acumuladores Jalisco Not in PNAA

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