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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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D. The Automakers Will Not Transition to ZEVs Unless They Are Forced to Do So

During the development of the draft ZEV Regs, the traditional automakers strenuously objected to their creation. Their explicit objections can be seen by anyone willing to read through the Canada Gazette, Part I website where the draft ZEV Regs are set out and where the federal government has recorded and displayed the comments that individuals and groups submitted during the mandatory online consultation period that occurred upon the release of the draft ZEV Regs.1

The automakers’ opposition did not end when the ZEV Regs became law. On 2 July 2025, the Chief Executive Officers of the Ford Motor Company of Canada, General Motors of Canada, and Stellantis Canada met with Prime Minister Mark Carney in Ottawa and urged him to repeal the ZEV Regs.2 As researchers at the Pembina Institute argued later that month in the Globe and Mail, “industry opposition to the target isn’t about what’s best for consumers, workers or the industry in Canada; it’s about protecting short-term profits of U.S.-owned corporations.”3

Corporations and paid lobbyists who contact the people working in the federal government with the intent of influencing policy must register with the Registry of Lobbyists, maintained by the Office of the Commissioner of Lobbying in Canada. When these corporations or lobbyists communicate with someone in the government, whether the person lobbied is a politician, political staff, or a non-partisan bureaucrat, the corporation or lobbyist must enter a “Communication Report” in the Registry of Lobbyists.

In preparing this Toolkit, members of the Climate Messengers searched the Lobbyist Registry for the period from the last federal election (Monday 28 April 2025) to near the end of August (there is a roughly 30-day delay in reports in the Registry). They searched for the lobbying being done by the following groups:

  • The Canadian Vehicle Manufacturers Association;
  • The Canadian Automobile Association;
  • Global Automakers of Canada;
  • Toyota Canada;
  • Ford Motor Company of Canada;
  • Canadian Automobile Association; and
  • Nissan Canada.

All these groups, among others, have a history of opposing the ZEV Regs. While some of the communications might have dealt with other subject matter, many of the Communications Reports specifically identified the ZEV Regs as being the subject-matter of the communication.

After counting over 125 Communications Reports between 28 April 2025 and near the end of August 2025, the members of the Climate Messengers stopped looking.4

The traditional automakers’ current opposition to the ZEV Regs is part of a longstanding pattern of behaviour characterized by a resistance to many, if not most, safety- and health-related automobile improvements regardless of scientific findings. For 60 years, the automakers opposed eliminating lead in gasoline, despite the fact that the lead emitted into the air people breathed was a potent neurotoxin that damaged brains, lowered IQs, and harmed child development.5

The automakers opposed the requirement to install catalytic converters, which are emission control devices in a vehicle’s exhaust system that make emissions somewhat less dangerous. In 1975, a top executive at General Motors announced:

[I]f GM is forced to introduce catalytic converter systems across the board on 1975 models . . . it is conceivable that complete stoppage of the entire production could occur, with the obvious tremendous loss to the company, shareholders, employees, suppliers, and communities.6

Not only was the executive wrong that catalytic converters would shut down GM, they were so popular with consumers that GM used them in their 1975 advertising campaign.7

The automakers campaigned strenuously against the requirement to install seat belts in automobiles. They later campaigned just as strenuously against laws requiring the wearing of seat belts.8 In the 1980s, the automakers campaigned against the requirement to install airbags in automobiles. Somewhat ironically, they argued that stringent laws requiring the use of seat belts would eliminate the need for airbags.9

In each case, the automakers have made virtually the same arguments:

  • “It cannot be done:” Automakers overstate technical challenges to meeting new rules.
  • “It will cost too much:” They claim that complying with new standards will cost far more than federal agencies estimate.
  • “It will destroy the industry and kill jobs:” They cast every new requirement as a potential apocalypse for automakers, leading to mass layoffs and closed factories.
  • “Consumers do not want this:” Their industry groups suggest that automakers must choose whether to produce vehicles that customers want or vehicles the new rules would mandate.
  • “The science is not clear:” On issues like air pollution, climate change, and the effectiveness of seat belts, auto companies and trade groups attack the science, inflate uncertainty, and deny or question the facts.
  • “The market will solve it:” Whatever the issue, automakers claim that voluntary, self-enforcement is sufficient.

Time after time, all these arguments have been proven wrong. The record shows that automakers have over-performed when faced with new rules. Rising to each challenge, they have implemented innovative solutions, complying with health, environmental, and safety standards at lower cost than even the agencies had initially estimated.10

These are exactly the arguments that the automakers are using to oppose the ZEV Regs. The government must see the arguments for the disinformation that they are, and climate concerned citizens must tell the government to do so.

The history of the automakers’ repeating the same arguments to oppose a number of different changes that benefit society has been set out in a number of sources. Concerned citizens should bring these sources to the attention of those who are conducting the review of the ZEV Regs:

Steven Chohen, “The Impact of Regulation on Automobile Innovation”, State of the Planet – News from the Columbia Climate School, 17 April 2023. Retrieved on 20 September 2025 from https://news.climate.columbia.edu/2023/04/17/the-impact-of-regulation-on-automobile-innovation/.

Dave Cook, Union of Concerned Scientists, “Time for a U-Turn: Automakers’ History of Intransigence and an Opportunity for a Change”, December 2017, pp. 1-2. Retrieved on 15 September 2025 from https://www.ucs.org/sites/default/files/attach/2017/12/cv-fuel-efficiency-intransigience-full_0.pdf.

Chelsea Hodgkins and Alan Zibel, “Stuck in Neutral – Big Automakers Lobby Against Cleaner Vehicles, Make Record Profits from Dirty Cars”, Public Citizen, 14 March 2024. Retrieved on 20 September 2025 from https://www.citizen.org/article/stuck-in-neutral/.

✉️ Make Your Submission!

1 Canada Gazette, Part I, Volume 156, Number 53: Regulations Amending the Passenger Automobile and Light Truck Greenhouse Gas Emission Regulations, Regulatory Impact Analysis Statement. Retrieved on 15 September 2025 from https://gazette.gc.ca/rp-pr/p1/2022/2022-12-31/html/reg1-eng.html

2 Steven Chase and Eric Atkin, “Automakers ask Carney to repeal zero-emission vehicle mandate”, The Globe and Mail, 2 July 2025. Retrieved on 17 September 2025 from https://www.theglobeandmail.com/politics/article-automakers-ask-carney-to-repeal-zero-emission-vehicle-mandate/

3 Chris Severson-Baker and Adam Thorn, “Let’s not let foreign automakers press us into changing the EV mandate,” Globe and Mail, 25 July 2025. Retrieved on 18 September 2025 from https://www.theglobeandmail.com/business/commentary/article-lets-not-let-foreign-automakers-press-us-into-changing-the-ev-mandate/

4 The search was conducted on 18 September 2028 using this website: https://lobbycanada.gc.ca/app/secure/ocl/lrs/do/clntSmmrySrch

5 George Weiner, “The Rise and Fall of Leaded Gasoline: An Absurd and True Timeline”, Non-Profit News Feed, 7 April 2025. Retrieved on 15 September 2025 from https://nonprofitnewsfeed.com/resource/the-rise-and-fall-of-leaded-gasoline-an-absurd-true-timeline/#:~:text=For%20over%2060%20years%2C%20Americans%20breathed%20air,turn%E2%80%94denying%20science%2C%20attacking%20researchers%2C%20and%20launching%20lawsuits.

6 Dave Cook, “Automakers’ Long List of Fights Against Progress, and Why We Must Demand Better”, Union of Concerned Scientists, 6 December 2017. Retrieved on 30 September 2025 from https://blog.ucs.org/dave-cooke/automakers-long-list-of-fights-against-progress-and-why-we-must-demand-better/

7 Ibid.

8 See generally Dave Cook, Union of Concerned Scientists, “Time for a U-Turn: Automakers’ History of Intransigence and an Opportunity for a Change”, December 2017. Retrieved on 15 September 2025 from https://www.ucs.org/sites/default/files/attach/2017/12/cv-fuel-efficiency-intransigience-full_0.pdf

9 James Barron, “Auto Makers Hoping State Laws Save Them From Air Bag Ruling”, New York Times, 12 July 1984. Retrieved on 15 September 2025 from https://www.nytimes.com/1984/07/12/us/auto-makers-hoping-state-laws-save-them-from-air-bag-ruling.html

10 Dave Cook, Union of Concerned Scientists, “Time for a U-Turn: Automakers’ History of Intransigence and an Opportunity for a Change”, December 2017, pp. 1-2. Retrieved on 15 September 2025 from https://www.ucs.org/sites/default/files/attach/2017/12/cv-fuel-efficiency-intransigience-full_0.pdf

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