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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

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

III. SUGGESTIONS FOR COMPLEMENTARY POLICIES TO ASSIST THE ZEV REGS

  • A. SUGGESTIONS FOR COMPLEMENTARY POLICIES TO ASSIST THE ZEV REGS
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A. Canada, and the World, Must Cut GHG Emissions

The world is not on track to remain under 2oC of global warming.1 “Climate Action Tracker” projects a range of global warming between 1.9oC and 2.9oC by 2100.2 Depending on whether the nation-states of the world take varying degrees of action that they are not currently taking, the UN’s Intergovernmental Panel on Climate Change (IPCC) projects a range of global warming by 2100 of between 1.5oC and over 4oC.3 The scientific consensus is clear: these levels of warming would be catastrophic for human life.

Canada is not doing nearly enough to reduce its GHG emissions. According to the Government of Canada, while being the world’s 11th largest emitter of GHGs:

Canada has the second highest GHG emission per capita rate among the top 10 emitting countries and regions. If Canada’s GHG emissions per year were shared equally by each person in Canada, each person would emit 17.9 t CO2 eq per year, which is almost 3 times the global rate. That is close to the same amount of GHG emissions released as someone driving around the world in a gasoline-powered car twice per year (about 73 358 km total).4

Despite this fact, the Canadian government has recently taken steps that will prevent Canadian GHG emissions reductions, and possibly increase our emissions. On 1 October 2024, the Government of Canada imposed a 100% tariff on Chinese EVs.5 On 1 April 2025, the Government of Canada cancelled the consumer carbon price, sometimes referred to colloquially as the “consumer carbon tax”, and also removed requirements for provinces to have a consumer-facing carbon price as of that date.6

Even before removing the consumer carbon price, Canada’s very modest progress in GHG emissions reductions in recent years had flat-lined. On 18 September 2025, the Canadian Climate Institute released its Early Estimate of National Emissions for 2024. It reported that Canadian GHG emissions for 2004 were only 0.1% lower than for 2023. Emissions from transportation fell by only 0.1%, very similar to the increase of 0.1% in 2023. The Institute declared that emissions trends put Canada’s 2030 Emission Reductions Target out of reach. It stated, “At this point, achieving Canada’s 2030 target would require year-over-year reductions equal to 40 Mt—far beyond the ambition of current policy.”7

Now, of course, Prime Minister Mark Carney and the Government of Canada have eliminated the 2026 sales quota under the ZEV Regs, and have launched a review that, if not opposed, could lead to the ZEV sales quotas being reduced or even eliminated.8

Prime Minister Carney and the Government of Canada simply must stop reversing what modest policies Canada has implemented to reduce GHG emissions, maintain the surviving policies, and introduce new policies to lower Canada’s emissions.

✉️ Make Your Submission!

1 Eric Burgueno Salas, “Projected temperature increases worldwide 2100, by scenario”, Statistica, 10 July 2025. Retrieved on 25 September 2025 from https://www.statista.com/statistics/1278800/global-temperature-increase-by-scenario/#statisticContainer ;

2 Climate Action Tracker, “Emissions Pathways – Addressing Global Warming”l Retrieved on 15 September 2025 from https://climateactiontracker.org/global/emissions-pathways/

3 United Nations Intergovernmental Panel on Climate Change, Climate Change 2022 – Impacts, Adaptation, and Vulnerability – Summary for Policymakers, 27 February 2022, p. 16. Available online at https://www.ipcc.ch/report/sixth-assessment-report-working-group-ii/

4 Government of Canada, Environment and Natural Resources, “Global greenhouse gas emissions”. Webpage updated 31 July 2025. Retrieved on 25 September 2025 from https://www.canada.ca/en/environment-climate-change/services/environmental-indicators/global-greenhouse-gas-emissions.html

5 Lisa Xing, “Chinese-made EVs are now subject to a 100% tariff. What does this mean for Canadians?”, CBC News, 1 October 2024. Retrieved on 25 September 2025 from https://www.cbc.ca/news/business/china-electric-vehicles-tariff-trade-canada-1.7338087

6 Government of Canada, Department of Finance Canada, “Removing the consumer carbon price, effective April 1, 2025”, Retrieved on 25 September 2025 from https://www.canada.ca/en/department-finance/news/2025/03/removing-the-consumer-carbon-price-effective-april-1-2025.html

7 Dave Sawyer and Seton Stiebert, “Canada’s Emissions Flatlined in 2024, Early Estimate Shows”, Canadian Climate Institute – 440 Megatonnes, 18 September 2025. Retrieved on 25 September 2025 from https://440megatonnes.ca/insight/canada-emissions-flatlined-in-2024-early-estimate-shows/?utm_source=newsletter&utm_medium=email&utm_campaign=nsep25eene24

8 Statement 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

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