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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. SUGGESTIONS FOR COMPLEMENTARY POLICIES TO ASSIST THE ZEV REGS

Reintroduce the federal ZEV sales rebate on new ZEVs ASAP

The federal government should reintroduce the federal ZEV sales rebate on new ZEVs as soon as possible. It should be kept in place until at least some ZEVs have achieved price parity with comparable ICE vehicles. The RIAS for the ZEV Regs suggests that ZEV cars should reach price parity with comparable ICE cars in the early 2030s. However, ZEV and PHEV (plug-in hybrid electric vehicles) pickup trucks and SUVs are not expected to reach price parity with ICE pickup trucks and SUVs before 2035.1

The government should commit to the sales rebate for a certain number of years and at a certain price. It should also guarantee funding for the rebate program.

The government should extend the sales rebate to both new and used ZEVs.

Consider waiving the federal portion of the H.S.T. on ZEVs

The federal government should consider waiving the federal portion of the Harmonized Sales Tax (the “HST”) on both new and used ZEVs for some number of years. The federal portion of the HST is 5%.

Norway is the global leader in ZEV adoption. “Between January and May 2025, battery electric vehicles (BEVs) and plug-in hybrid electric vehicles (PHEVs) made up 96% of Norway’s new passenger car registrations.”2 Much of what they have achieved has been by using incentives. Here is a list of those incentives and the year they were implemented:

  • 1990: Temporary abolishment of import tax.
  • 1996: Reduced annual electric vehicle registration tax.
  • 1996: Permanent abolishment of import tax.
  • 1997: Reduced company car tax.
  • 2001: Zero VAT (Value Added Tax), a reduction from the former 25% VAT.
  • 2005: Access to bus lanes nationwide.
  • 2009: Free access to road ferries.3

The ZEV Regs can influence supply, but they have very little influence over consumer demand. The federal government should do all that it can to increase demand, and this includes taking steps to make the initial purchase price of ZEVs lower than that of comparable ICE vehicles.

End B.C. Ferries’ and Transport Canada’s restrictions on EV ferry transport

In June 2025, B.C. Ferries announced that it would no longer allow tow trucks carrying non-operational EVs to board its vessels. It cited safety risks associated with transporting potentially damaged lithium-ion batteries and Transport Canada’s Transportation of Dangerous Goods Regulations.4 For owners of EVs that require complicated repairs, though, this new restriction could prevent them from having their cars transported to a car dealership that can handle such repairs. A barge or some other form of commercial cargo may be available in certain areas, but at a significant expense to the owners.

It is important to note that “Transport Canada says that no safety incidents regarding EVs on commercial marine vehicles have been reported to them.”5

B.C. Ferries and Transport Canada should reconsider this policy in light of this fact and because it places an undue burden on EV owners. Moreover, Transport Canada should consider allowing all EVs to ride on ferries for free, as is the case in Norway, which would provide a further incentive for purchasing them.

✉️ Make Your Submission!

1 RIAS, p. 4046. Canada Gazette Part II, Vol.157, No. 26, 20 December 2024. Retrieved on 14 September 2025 from https://gazette.gc.ca/rp-pr/publications-eng.html#a2

2 Sandra Wappelhorst and Sonsoles Díaz, “Europe’s Electric Vehicle Market Leaders: Denmark, Sweden, and Finland,” International Council on Clean Transportation, 11 August 2025. Retrieved on 28 September 2025 from https://theicct.org/publication/europes-ev-market-leaders-denmark-sweden-and-finland-aug25/#:~:text=Norway%20is%20the%20region%27s%20top,Norway%27s%20new%20passenger%20car%20registrations.

3 Harald Nils Rostvik, “The mobility revolution as seen through Norwegian eyes,” Architectural Science Review, 2018, Vol. 61, No. 5, 362-366, p. 363.

4 Akshay Kulkarni, “B.C. Ferries will no longer allow tow trucks with non-operational EVs on board,” CBC News Report, 30 June 2025. Retrieved on 30 September 2025 from https://www.cbc.ca/news/canada/british-columbia/tow-trucks-damaged-electric-vehicles-bc-ferries-1.7574664. See also Harry Corro, “New regulations ban badly damaged electric vehicles from BC Ferries,” Coast Mountain News, 1 July 2025. Retrieved on 30 September 2025 from https://www.coastmountainnews.com/news/new-regulations-ban-badly-damaged-electric-vehicles-from-bc-ferries-8105270; and Transport Canada, “Guidelines to safely transport electric vehicles on Canadian ferries – SSB No.: 04/2024.” Retrieved on 30 September 2025 from https://tc.canada.ca/en/marine-transportation/marine-safety/ship-safety-bulletins/guidelines-safely-transport-electric-vehicles-canadian-ferries-ssb-no-04-2024

5 Akshay Kulkarni, “B.C. Ferries will no longer allow tow trucks with non-operational EVs on board,” CBC News Report, 30 June 2025. Retrieved on 30 September 2025 from https://www.cbc.ca/news/canada/british-columbia/tow-trucks-damaged-electric-vehicles-bc-ferries-1.7574664

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