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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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C. Provide extra credit for selling ZEVs at a price below $40,000 CDN

Clean Energy Canada recommends that carmakers “receive extra credits under the system for selling EVs below a price point of $40,000, the maximum price most Canadians wish to spend on a new car. Many of these vehicles already exist, being sold in markets such as Europe.”1 The group commissioned Abacus Data to poll 3,000 people in Canada’s two largest English-speaking urban and suburban centres, the Greater Toronto and Hamilton Area and Metro Vancouver. They found that, overall, 59% are inclined to buy an EV as their next car. That figure was 69% in Vancouver, where adoption is much higher. However, 73% are unwilling to spend more than $40,000 upfront on a new ZEV.2

For comparison’s sake, in Europe, 21 EV models are priced less than the equivalent of CAD $40,000, “and only one of those cars, a small, relatively low-range Fiat, is available in Canada (it is the only sub-$40,000 EV available in Canada, period).”3

✉️ Make Your Submission!

1 Rachel Doran, “Mark Carney could make it easier for us to buy EVs if he wanted. Right now he’s making it harder”, Clean Energy Canada, 11 September 2025. Retrieved on 28 September 2025 from https://cleanenergycanada.org/mark-carney-could-make-it-easier-for-us-to-buy-evs-if-he-wanted-right-now-hes-making-it-harder/ . (Hyperlinks omitted.)

2 “Empowering Households: The small but mighty household is key to unlocking the energy transition, but doing so starts with understanding people. While interest in clean technologies is high, barriers keep many would-be adopters at bay”, Clean Energy Canada, 4 September 2024. Retrieved on 28 September 2025 from https://cleanenergycanada.org/report/empowering-households/

3 “Missing Out Europe enjoys 21 electric vehicles selling for less than $40,000 Canadian. Only one of them is available in Canada”, Clean Energy Canada, September 2025. Retrieved on 28 September 2025 from https://cleanenergycanada.org/report/missing-out/

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