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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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K. ZEV sales mandates work, and they work in Canada

A growing body of evidence shows that sales mandates are effective at significantly increasing ZEV sales.

A 2025 study that simulated the impact of a ZEV sales mandate and other policies in Canada found that a, “strong ZEV sales standard can induce 95−100% ZEV sales by 2035, while inducing more ZEV-supportive strategies by the automakers, including an average 22% reduction in the prices of ZEVs, a 6% increase in the price of conventional vehicles, and a doubling of ZEV-related Research & Development (R&D) investment.”1

We can see this in the real world too, by comparing ZEV sales in provinces and territories both with and without provincial sales mandates. In 2024, ZEVs represented 13.8% of new cars sold in Canada. The number was much higher in provinces with sales mandates and provincial rebates: 30.1% in Quebec and 20.7% in B.C.2

✉️ Make Your Submission!

1 John Axsen and Chandan Bhardwaj, “Subsidies, Standards, or Both? Trade-Offs among Policies for 100% Zero-Emissions Vehicle Sales”,Environmental Science & Technology 2025 59 (4), 1932-1941. DOI: 10.1021/acs.est.4c11772. Retrieved on 20 September 2025 from: https://pubs.acs.org/doi/pdf/10.1021/acs.est.4c11772?ref=article_openPDF&trk=public_post_comment-text.

2 Statistics Canada, “In 2024, one in seven new vehicles sold in Canada were zero emission”. Retrieved on 20 September 2025 from: https://www.statcan.gc.ca/o1/en/plus/7915-2024-one-seven-new-vehicles-sold-canada-were-zero-emission.

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