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Executive Summary & Introduction

  • Executive Summary
  • Introduction

I. REASONS TO KEEP THE ZEV REGS

  • A. Canada, and the World, Must Cut GHG Emissions
  • B. Ceasing to Burn Fossil Fuels for Transport is Absolutely Necessary
  • C. Burning Fossil Fuels, Including to Power Light Duty Vehicles, Is a Health Hazard
  • D. The Automakers Will Not Transition to ZEVs Unless They Are Forced to Do So
  • E. The Automakers Have Met 2024 and Earlier Sales Quotas in Canada and Other Jurisdictions
  • F. The Automakers Will Still Make Profits With a 100% ZEV Sales Quota
  • G. Canada’s 20% Sales Quota for 2026 Could Be Achieved If Not Hindered by Changes in Government Policy
  • H. Canada’s 20% Sales Quota for 2026 Could Be Achieved But for the Automakers’ Intransigence
  • I. Canadian ZEV Sales Are Depressed By Limited Selection
  • J. The ZEV Regs Already Have “Compliance Flexibility” to Help Automakers
  • K. ZEV sales mandates work, and they work in Canada

III. SUGGESTIONS FOR COMPLEMENTARY POLICIES TO ASSIST THE ZEV REGS

  • A. SUGGESTIONS FOR COMPLEMENTARY POLICIES TO ASSIST THE ZEV REGS

II. SUGGESTIONS FOR IMPROVING OR "FIXING" THE ZEV REGS

  • A. The 2035 sales quota requiring that 100% of light duty vehicles be ZEVs must be maintained
  • B. Maintain the 2027 and future sales quotas as they are currently set, but let the automakers earn credits for the ZEVs they sell in 2026
  • C. Provide extra credit for selling ZEVs at a price below $40,000 CDN
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Introduction

The Zero Emission Vehicle Regulations, formally known as the “Regulations Amending the Passenger Automobile and Light Greenhouse Gas Emission Regulations”1 and referred to throughout this Toolkit as the “ZEV Regs,” became law on 20 December 2023.2

They define a “zero-emission vehicle” as “an automobile that is an electric vehicle, a plug-in hybrid electric vehicle or a fuel cell vehicle.”3 In other words, ZEVs do not emit climate change-causing GHGs, unlike traditional gas-powered vehicles.

The ZEV Regs require that 20% of an automaker’s new car sales be ZEVs in 2026, with the percentage increasing each year, to 60% in 2030, until in 2035 all new light vehicle sales must be ZEVs.4 The system of annually-increasing sales quotas is called the “Electric Vehicle Availability Standard” (EVAS).

Table of Annual Sales Quotas set out in the ZEV Regs5

YearSalesQuota
20250%
202620%
202723%
202834%
202943%
203060%
203174%
203283%
203394%
203497%
2035100%

On 5 September 2025, Prime Minister Mark Carney announced that the EVAS will be amended to remove the target for the 2026 model year vehicles. He stated that the reason for doing so was “to help reduce the economic pressure due to tariffs.”6

At the same time, he launched a 60-day review of the EVAS “to ensure it continues to reflect market realities, remains effective for Canadians, and does not place undue burden on automakers. The review will consider potential amendments to the annual sales targets, including the 2035 goal, and will explore possible additional flexibilities.”7

The cancellation of the 2026 sales quota and the review of the ZEV Regs/EVAS stem from the enormous lobbying effort by the automakers.8 The automakers want to have the ZEV Regs removed entirely or, if they cannot achieve that, they want to have the EVAS made as lenient as possible.9

It is vital that climate concerned citizens like ourselves learn more about the ZEV Regs, including how they can be improved. Using the information in this toolkit, we can provide well-informed feedback to the Government of Canada during its 60-day review of these measures by emailing our comments to the Transportation Division’s inbox at infovehiculeetmoteur-vehicleandengineinfo@ec.gc.ca by 15 October 2025. (The 60-day review period ends on 4 November 2025, but it appears that Prime Minister Carney wants to receive the results of the review at the close of the 60-day period, so we must submit our comments in time for them to be considered.)

This Toolkit is divided into three sections:

  • I. REASONS TO KEEP THE ZEV REGS;
  • II. SUGGESTIONS FOR IMPROVING OR “FIXING” THE ZEV REGS; and
  • III. SUGGESTIONS FOR COMPLEMENTARY POLICIES TO ASSIST THE ZEV REGS.
✉️ Make Your Submission!

1Passenger Automobile and Light Truck Greenhouse Gas Emission Regulations (SOR/2010-201). Retrieved on 13 September 2025 from https://laws-lois.justice.gc.ca/eng/regulations/sor-2010-201/index.html

2Canada Gazette Part II, Vol.157, No. 26, p. 3969. 20 December 2024. Retrieved on 14 September 2025 from https://gazette.gc.ca/rp-pr/publications-eng.html#a2

3ZEV Regs, section 1.

4ZEV Regs, section 30.12.

5ZEV Regs, section 30.12.

6Statement posted to the Prime Minister of Canada’s website, 5 September 2025. Retrieved on 14 September 2025 from https://www.pm.gc.ca/en/news/backgrounders/2025/09/05/prime-minister-carney-launches-new-measures-protect-build-and

7Statement posted to the Prime Minister of Canada’s website, 5 September 2025. Retrieved on 14 September 2025 from https://www.pm.gc.ca/en/news/backgrounders/2025/09/05/prime-minister-carney-launches-new-measures-protect-build-and

8See the discussion of the automakers’ lobbying in the section entitled “The Automakers Will Not Transition to ZEVs Unless They Are Forced to Do So”, below.

9“Ottawa pauses ZEV mandates: will review program,” Newsline: The National Voice of the Automobile Dealer, 8 September 2025. Retrieved on 16 September 2025 from https://www.cada.ca/CADA/News1/Newsline_Stories/2025-09-Sep/zev-vze.aspx

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