Docs Category: I. REASONS TO KEEP THE ZEV REGS
I. REASONS TO KEEP THE ZEV REGS
A. Canada, and the World, Must Cut GHG Emissions
Last Updated: October 4, 2025The 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
B. Ceasing to Burn Fossil Fuels for Transport is Absolutely Necessary
Last Updated: October 4, 2025The world’s climate change problem is caused overwhelmingly by humanity’s burning of fossil fuels. An enormous quantity of carbon had been stored in the Earth’s crust. Coal was formed during the Carboniferous Era, from about 359 to 299 million years ago.1 The majority of oil and gas was formed during the Mesozoic Era, between 252 and 66 million years ago. After organisms such as algae, plankton, bacteria and plants died, they either sank to the lake and ocean floors or ended up there after being carried to the lake or ocean by a river. Eventually, they were buried by layers of sediment. Over time, they were compacted and became rocks.2 The massive amount of carbon that was buried in the Earth’s crust created an atmosphere on the Earth with a balance of oxygen, nitrogen, and carbon dioxide that was conducive to human life, both in terms of breathing and in terms of temperature. According to Mark Jaccard, Professor of Sustainable Energy at Simon Fraser University, “Except for the last 250 years, the human energy system has relied almost entirely on wood, brush, crop waste, and animal dung, and these have been essentially carbon neutral. As they grow via photosynthesis, trees, bushes, grasses and crops extract CO2 from the air to produce carbohydrates. When plants are burned or decay, this carbon is returned to the atmosphere, with no net increase in atmospheric GHG concentrations.”3 However, by drawing the coal, oil, and gas out of the Earth’s crust and burning it over the past 250 years, humans have significantly increased the quantity of CO2 and other greenhouse gases (“GHGs”) in the atmosphere. They are called “greenhouse gases” because they trap heat within the atmosphere, similar to the way a greenhouse traps heat, rather than permitting the heat to dissipate into space. The effect is to warm the planet and cause climate change. The vast majority of climate change is caused by burning fossil fuels. We simply must stop burning fossil fuels. Unfortunately, many Canadians have not been taking the climate emergency seriously, despite the increase in deadly forest fires and the other adverse effects of climate change. As a September 2025 study by the Canadian Climate Institute indicates, “Canada’s emissions flatlined in 2024 at 694 million tonnes (Mt CO2e), with emissions essentially unchanged from the previous year…Canada’s emissions reduction progress to date is fragile.”4 Transportation is the second-largest source of greenhouse gas (GHG) emissions in Canada after the oil and gas industry.5 It is not possible to make the necessary reductions in Canada’s GHG emissions without significantly reducing emissions from transportation. In the case of fossil fuels burned for transportation, there is no feasible means of “carbon capture, utilization, and storage” (“CCUS”) on transportation vehicles. In the case of light-duty vehicles, meaning cars and pickup trucks, the solution is both obvious and readily available. Instead of powering these vehicles with internal combustion engines (“ICE vehicles”) that burn fossil fuels, we can readily power them with electric motors, with the electricity coming from renewable generation. This is about as close to a “no-brainer” as we could possibly get. A growing number of people agree, which is why the International Energy Agency (IEA) forecasted that in 2025, more than one in four cars sold worldwide would be electric vehicles, as EVs become more popular and affordable.6 In Canada, sales of ICE vehicles reportedly peaked as early as 2017.7 It is becoming more obvious to consumers that ICE vehicles are highly inefficient and expensive to operate and maintain relative to EVs. In fact, “Today’s gasoline-fueled cars and trucks waste around 80% of the energy that gets pumped into their gas tanks,” whereas EVs “operate with only around 11% energy loss.”8 ✉️ Make Your Submission! 1 University of California at Berkeley, “The Carboniferous Period”. Retrieved on 15 September 2025 from https://ucmp.berkeley.edu/carboniferous/carboniferous.php 2 Chevron, “Explainer: where do oil and gas come from?”, 30 December 2024. Retrieved on 15 September 2025 from https://www.chevron.com/newsroom/2024/q4/explainer-where-do-oil-and-gas-come-from 3 Mark Jaccard, The Citizen’s Guide to Climate Success (Cambridge: Cambridge University Press, 2020), p. 168. 4 Dave Sawyer and Seton Steibert, “Canada’s emissions flatlined in 2024, early estimate shows,” 440 Megatonnes Project, 18 September 2025. Retrieved on 18 September 2025 from https://440megatonnes.ca/insight/canada-emissions-flatlined-in-2024-early-estimate-shows/ 5 Government of Canada, “Greenhouse gas emissions: drivers and impacts”. Retrieved on 20 September 2025 from: 6 “More than 1 in 4 cars sold worldwide this year is set to be electric as EV sales continue to grow,” IEA News, 14 May 2025. 7 Arthur Zhang, “Gas-powered vehicle sales have peaked in Canada,” 440 Megatonnes Project, 15 February 2024. Retrieved on 18 September 2025 from https://440megatonnes.ca/insight/peak-gas-powered-vehicles-canada/ 8 Karin Kirk, “Electric vehicles use half the energy of gas-powered vehicles,” Yale Climate Connections, 29 January 2024. Retrieved on 19 September 2025 from https://yaleclimateconnections.org/2024/01/electric-vehicles-use-half-the-energy-of-gas-powered-vehicles/
C. Burning Fossil Fuels, Including to Power Light Duty Vehicles, Is a Health Hazard
Last Updated: October 4, 2025According to the Global Climate and Health Alliance, “Combustion, whether in power plants, vehicles, or homes, generates particulate matter 2.5 (PM2.5), nitrogen oxides, and other pollutants, significantly increasing risks of asthma, heart disease, stroke, cancer, dementia, and premature mortality.”1 In 2021, Health Canada released a paper entitled “Health Impacts of Air Pollution in Canada – Estimates of premature deaths and nonfatal outcomes”. It reported the following results: Overall, the total mortality attributable to above-background air pollution in Canada was estimated to be 15,300 premature deaths per year, based on population data for 2016 and air pollutant concentrations from 2014 to 2017. More specifically, the following population health impacts of PM2.5, ozone and NO2 were estimated: The economic cost of the 15,300 premature deaths associated with air pollution is estimated at $114 billion per year (2016 CAD). Health Canada recognizes the possibility of overlap or double counting of endpoints; this is addressed in the Uncertainties and limitations section.2 “The Regulatory Impact Analysis Statement” (RIAS) accompanying the final ZEV Regs discussed the health hazards associated with on-road vehicles generally, and ICE vehicles specifically: Health Canada analysis indicates that overall, emissions from all on-road vehicles in Canada contribute to an estimated 1,200 premature deaths and millions of cases of nonfatal health outcomes annually, with a total estimated economic value of $9.5 billion annually. The emissions from light-duty vehicles specifically contribute approximately 37% of the health burden associated with air pollution from on-road vehicles. Children, elderly people, individuals with underlying health conditions and people living in high exposure areas are populations who may be disproportionately impacted by the adverse effects of air pollution. Light-duty vehicles targeted by the Amendments are a significant source of air pollutant emissions, including fine particulate matter (PM2.5), nitrogen oxides (NOx), volatile organic compounds (VOCs), carbon monoxide (CO) and other toxic substances. These emissions also contribute to ambient levels of secondarily formed pollutants of health concern, including PM2.5 and ozone (two principal components of smog). ZEVs offer an opportunity to address traffic-related air pollution, delivering immediate and local health benefits to the Canadian population, and those benefits will accrue into the future over the lifetime of the ZEVs. The estimated reductions in select pollutants from the Amendments are included in Table 7 below. Table 7: Percent emission reductions in select air pollutants in select years Type of air pollutants 2024 2035 2050 Particulate matter(IPM 2.5) – 10% 35% Nitrogen oxides – 11% 50% Volatile organic compounds – 13% 61% Carbon monoxide – 16% 68% As annual ZEV targets are met, the on-road fleet will turn over leading to increased air pollutant reductions in the later years of the analysis. Given the cumulative nature and magnitude of these reductions, the Amendments are expected to directly benefit many Canadians, including populations most exposed and who may be disproportionately impacted by air pollution from on-road vehicles.3 To put the statement that “[t]he emissions from light-duty vehicles specifically contribute approximately 37% of the health burden associated with air pollution from on-road vehicles” in perspective, 37% of 1,200 annual premature deaths is 444 annual premature deaths. Furthermore, 37% of the estimated economic value of $9.5 billion annually is $3.5 billion. In terms of the health and associated costs alone, it would be unconscionable for the government to repeal or weaken the ZEV Regs. ✉️ Make Your Submission! 1 Shweta Narayan, Jen Kul, and Jeni Miller, “Cradle to Grave: The Health Toll of Fossil Fuels and the Imperative for a Just Transition”, Global Climate and Health Alliance, September 2025, p. XV. Retrieved on 23 September 2025 from https://climateandhealthalliance.org/wp-content/uploads/2025/09/C2G-Report-low-_res-English.pdf 2 Health Canada, Health Impacts of Air Pollution in Canada – Estimates of prematures deanths and nonfatal outcomes – 2021 Report, Her Majesty the Queen in Right of Canada, as represented by the Minister of Health, March 2021, p. 17 (PDF Version) (Footnotes omitted.) Retrieved on 23 September 2025 from https://www.canada.ca/en/health-canada/services/publications/healthy-living/health-impacts-air-pollution-2021.html 3 Final RIAS, pp. 4029-4030 (PDF Version). 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
D. The Automakers Will Not Transition to ZEVs Unless They Are Forced to Do So
Last Updated: October 4, 2025During 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: 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: 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/...
E. The Automakers Have Met 2024 and Earlier Sales Quotas in Canada and Other Jurisdictions
Last Updated: October 4, 2025The automakers have claimed that they could not achieve having 20% of new light duty vehicles being ZEVs in 2026. This is not true and the ZEV sales in Canada and other jurisdictions prove this. Here in Canada, in provinces where ZEVs are more available due to provincial sales mandates, and where the province offers consumer rebates, Canadians are buying ZEVs. In 2024, ZEVs represented 30.1% of new cars sold in Quebec and 20.7% in B.C.1 Let that sink in: almost one third of new cars sold in Canada’s second most populous province (Quebec) were ZEVs. Notably, this is well above the 20% sales mandate that was supposed to kick in in 2026 under the ZEV Regs (the mandate the automakers say they can’t meet). This demonstrates that when ZEVs are available and reasonably priced, Canadians absolutely will buy ZEVs. Internationally, we see the same story. Under California’s ZEV Regs, the 2025 sales quota was 22%.2 According to the California Energy Commission: “In the first quarter of 2025, Californians purchased 100,326 zero-emission vehicles (ZEVs) representing 23% of all new vehicle sales in the state.”3 However, on Thursday 12 June 2025, President Donald Trump signed joint resolutions of Congress that purport to block California’s ZEV regulations. The California government almost immediately launched a court action to confirm the state’s right to continue the regulations, and it remains to be seen what the courts will decide.4 The United Kingdom has a ZEV sales mandate that is more stringent than Canada’s or California’s, as set out in the table below. Table of United Kingdom Annual Sales Quotas For Zero Emission Cars5 Year Sales Quota 2024 22% 2025 28% 2026 33% 2027 38% 2028 52% 2029 66% 2030 80% 2031 84% 2032 88% 2033 92% 2034 96% 2035 100% Table of United Kingdom Annual Sales Quotas For Zero Emission Vans6 Year SalesQuota 2024 10% 2025 16% 2026 24% 2027 34% 2028 46% 2029 58% 2030 70% 2031 76% 2032 82% 2033 88% 2034 94% 2035 100% The automakers achieved the UK’s 2024 sales quotas: Despite initial claims from carmakers last year about potential difficulties in meeting the 2024 ZEV mandate, T&E’s analysis of 2024 sales data confirms that the automotive industry has successfully complied. UK EV sales reached 19.6% in 2024. Although below the headline target of 22%, this figure exceeds the 18% required for compliance when accounting for flexibilities lobbied in by the car industry. At the individual manufacturer level, the analysis shows that all major carmakers have met the 2024 targets and Suzuki is the only carmaker which will need to purchase credits to comply due to no fully electric sales in the UK in 2024.7 The following graph shows that even automakers that claim that they cannot achieve the Canadian ZEV Regs quotas, such as Stellantis, Toyota, Ford, and Mercedes-Benz, achieved the higher 2024 sales quotas required of them in the UK:8 The tariffs that Donald Trump has imposed in 2025 have caused economic difficulties for businesses operating in the UK, as well much of the rest of the world. In response to concern that the automakers would not be able to achieve the 2025 sales quotas due to the economic chaos, the Government of the UK reviewed the UK Electric Vehicle Mandate and amended it: The changes, which reflect extensive consultation, will help the car industry by: Support for the car industry will be kept under review as the impact of new tariffs becomes clear.9 Crucially, the amendments did not change the final dates for the elimination of sales of ICE vehicles: the 2030 phase out date of new gasoline and diesel car sales was confirmed with hybrids to be sold until 2035 and small manufacturers exempt.10 In some other jurisdictions, automakers are already selling ZEVs as even greater portions of their new car sales, as this graph sets out: In 2024, ZEVs represented 30.1% of new cars sold in Quebec and 20.7% in B.C.11 Both provinces have provincial ZEV regulations with their own sales quotas, and the automakers had little trouble in achieving these sales quotas. ✉️ Make Your Submission! 1 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. 2 California Air Resources Board, “California moves to accelerate to 100% new zero-emission vehicle sales by 2035”, 25 August 2022. Retrieved from https://ww2.arb.ca.gov/news/california-moves-accelerate-100-new-zero-emission-vehicle-sales-2035 on 6 January 2023. 3 California Energy Commission, “California ZEV Sales Hold Steady to Start 2025”, 16 May 2025. Retrieved on 19 September 2025 from https://www.energy.ca.gov/news/2025-05/california-zev-sales-hold-steady-start-2025 4 “Lauren Rosenhall and Lisa Friedman, “Trump Blocks California E.V. Rules in Latest Move to Rein In the State”, New York Times, 12 June 2025. Retrieved on 19 September 2025 from https://www.nytimes.com/2025/06/12/us/california-trump-electric-vehicle-waiver.html 5 Government of the United Kingdom, “Consultation outcome Zero emission vehicle (ZEV) mandate consultation: summary of responses and joint government response”, Updated 25 October 2023. Retrieved on 19 September 2025 from https://www.gov.uk/government/consultations/a-zero-emission-vehicle-zev-mandate-and-co2-emissions-regulation-for-new-cars-and-vans-in-the-uk/outcome/zero-emission-vehicle-zev-mandate-consultation-summary-of-responses-and-joint-government-response#joint-response-to-summary-of-responses 6 Government of the United Kingdom, “Consultation outcome Zero emission vehicle (ZEV) mandate consultation: summary of responses and joint government response”, Updated 25 October 2023. Retrieved on 19 September 2025 from https://www.gov.uk/government/consultations/a-zero-emission-vehicle-zev-mandate-and-co2-emissions-regulation-for-new-cars-and-vans-in-the-uk/outcome/zero-emission-vehicle-zev-mandate-consultation-summary-of-responses-and-joint-government-response#joint-response-to-summary-of-responses 7 T&E, “Mission accomplished: Carmakers fulfill the 2024 ZEV mandate”, 21 January 2025. Retrieved on 19 September 2025 from https://www.transportenvironment.org/te-united-kingdom/articles/mission-accomplished-carmakers-fulfill-the-2024-zev-mandate 8 T&E, “Mission accomplished: Carmakers fulfill the 2024 ZEV mandate”, 21 January 2025. Retrieved on 19 September 2025 from https://www.transportenvironment.org/te-united-kingdom/articles/mission-accomplished-carmakers-fulfill-the-2024-zev-mandate 9 Government of the United Kingdom, Press release: “Backing British business: Prime Minister unveils plan to support carmakers”, 6 April 2025. Retrieved on 19 September 2025 from https://www.gov.uk/government/news/backing-british-business-prime-minister-unveils-plan-to-support-carmakers 10 Government of the United Kingdom, Press release: “Backing British business: Prime Minister unveils plan to support carmakers”, 6 April 2025. Retrieved on 19 September 2025 from https://www.gov.uk/government/news/backing-british-business-prime-minister-unveils-plan-to-support-carmakers 11 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.
F. The Automakers Will Still Make Profits With a 100% ZEV Sales Quota
Last Updated: October 4, 2025The automakers may make less profit with a 100% ZEV sales quota than they would with no sales quotas, but they will still make profits. Jonn Axsen and Chandan Bhardwaj, two professors from the School of Resource and Environmental Management, Simon Fraser University, Burnaby, British Columbia, used the AUtomaker-consumer Model (AUM) to compare policy impacts on ZEV sales, GHG mitigation, vehicle markups and prices, and automaker profits from 2023 to 2035. They determined: The ZEV standard scenario has the… effect [of] decreasing 2023−2035 cumulative profits by 7.5% relative to the baseline. These profit reductions are due to changes in automaker practices relative to the baseline. These include added R&D investment costs, fewer new vehicle sales (due to own-price elasticity), and lower profit margins for ZEVs (in initial years). Interestingly, automaker profits per year still increase by 15% from 2023 to 2035, mainly driven by our assumptions of increasing population that lead to an overall increase in new vehicle sales (even with own-price elasticities).1 The government must not permit the automakers to make the maximum profits that they can when they are doing so at the expense of the climate. ✉️ Make Your Submission! 1 Axsen, John 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, p. 1938. 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
G. Canada’s 20% Sales Quota for 2026 Could Be Achieved If Not Hindered by Changes in Government Policy
Last Updated: October 4, 2025According to S&P Global Mobility, in December 2024, Canadian ZEV sales reached 18.9%.1 Had government policy and the automakers’ cooperation remained the same, it is very difficult not to believe that the 20% sales quota for 2026 would be achieved. However, both factors changed. The federal government had been providing rebates of up to $5,000 on new ZEVs, which was on top of any rebates offered by the province where the vehicle was sold. (For example, in 2024, the Government of Quebec was giving rebates of up to $7,000.) However, the federal government temporarily “paused” its own rebate program on 23 January 2025 because its funds were depleted earlier than expected.2 The federal rebate has not returned. On 17 June 2025, Environment and Climate Change Minister Julie Dabrusin said that a new ZEV rebate “is something being worked on”, but she would not say when it would be introduced.3 To state that a new ZEV rebate will be introduced has the effect of dampening current consumer demand for ZEVs: Potential buyers are motivated to delay their ZEV purchase until the federal ZEV rebate is back. A survey commissioned by Clean Energy Canada and released on 19 September 2025 asked respondents about the federal government ending the ZEV rebate, but also stating that it would bring it back: Respondents were asked how they think this situation would influence them as a buyer if they were on the market for an EV, and the vast majority of those open to buying one say they would simply wait for an update (41%) rather than purchase an EV today (14%). Another 36% say they would not buy an EV regardless of incentives, with 9% uncertain.4 For the federal government, this is the policy equivalent of an “own goal”. Because of it, they must discount the automakers’ claims that they cannot achieve the sales quotas. ✉️ Make Your Submission! 1 Emma Jarratt, “Canada ZEV adoption rate hit 18.9 per cent in Q4 2024: S&P”, Electric Autonomy Canada, 28 February 2025. Retrieved on 19 September 2025 from https://electricautonomy.ca/data-trackers/ev-sales-data/2025-02-28/s-p-q4-2024-canada-zev-adoption/ 2 Jil McIntosh, “Canada’s ZEV adoption rate fell by almost 30% in January 2025”, Driving, 28 February 2025. Retrieved on 19 September 2025 from https://driving.ca/auto-news/industry/canadas-zev-adoption-rate-fell-january-2025#:~:text=That’s%20according%20to%20data%20analytics,had%20been%20in%20December%202024. 3 Nick Murray, “New EV rebate program in the works, environment minister says”, CBC News, 17 June 2025. Retrieved on 19 September 2025 from https://www.cbc.ca/news/canada/windsor/ev-program-environment-minister-1.7563965 4 Clean Energy Canada, Media Release: “Poll: Two-thirds of Canadians support keeping EV mandate, though many want adjustments, as EV rebate pause causes would-be buyers to wait”, 19 September 2025. Retrieved on 24 September 2025 from “https://cleanenergycanada.org/poll-two-thirds-of-canadians-support-keeping-ev-mandate-though-many-want-adjustments-as-ev-rebate-pause-causes-would-be-buyers-to-wait/”
H. Canada’s 20% Sales Quota for 2026 Could Be Achieved But for the Automakers’ Intransigence
Last Updated: October 9, 2025As for the automakers, between 2018 and 2023, while claiming that they could not transition to 100% ZEVs in the United States and Canada because it would cost too much, Ford, GM, Stellantis, Toyota, and Honda: Major Automaker Profits, 2018 to 20232 Profit ($B USD) 2018 2019 2020 2021 2022 2023 Grand Total Ford $3.68 $0.05 -$1.28 $17.94 -$1.98 $4.35 $22.7 General Motors $8.01 $6.73 $6.43 $10.02 $9.93 $10.13 $51.3 Stellantis n/a $3.6 $2.5 $16.8 $17.8 $20.1 $60.8 Honda $5.5 $4.2 $6.2 $6.4 $5.0 $6.2 $33.5 Toyota $17.6 $19.1 $20.4 $21.7 $17.4 $28.1 $124.5 Total $34.9 $33.6 $34.2 $72.9 $48.2 $68.9 $292.7 Major Automaker Revenue, 2018 to 20233 Revenue ($B USD) 2018 2019 2020 2021 2022 2023 Grand Total Ford $160.34 $155.90 $127.14 $136.34 $158.06 $136.19 $914.0 General Motors $147.05 $137.24 $122.49 $127.00 $156.74 $171.84 $862.5 Stellantis n/a $66.1 $54.3 $176.6 $190.9 $205.1 $693.0 Honda $143.9 $137.0 $123.4 $132.5 $128.9 $106.7 $772.5 Toyota $282.2 $280.1 $247.8 $239.3 $264.4 $242.1 $1,557.0 Total $743.5 $776.3 $657.2 $811.7 $899.0 $902.0 $4,798.8 Major Automaker Dividend Payments, 2018 to 20234 Dividends ($B USD) 2018 2019 2020 2021 2022 2023 Grand Total Ford $2.9 $2.4 $0.6 $0.4 $2.0 $5.0 $13.3 General Motors $2.2 $2.4 $0.7 $0.2 $0.4 $0.6 $13.7 Stellantis n/a $0.7 $0.0 $5.0 $3.6 $4.6 $13.7 Honda $1.8 $1.8 $1.4 $1.7 $1.6 $1.7 $10.0 Toyota $6.0 $5.8 $5.7 $5.4 $5.2 $6.3 $34.4 Total $12.9 $13.0 $8.3 $12.7 $12.8 $18.2 $77.9 Major Automaker Stock Buybacks, 2018 to 20235, 6 Buybacks ($B USD) 2018 2019 2020 2021 2022 2023 Grand Total Ford $0.2 $0.2 $0.0 $0.0 $0.5 $0.3 $1.2 General Motors $0.2 $0.0 $0.1 $0.0 $2.5 $11.1 $13.9 Stellantis n/a $0.0 $0.2 $0.0 $1.0 $2.6 $3.8 Honda $0.6 $0.9 $0.0 $3.1 $3.1 $1.4 $4.7 Toyota $5.2 $4.5 $0.0 $3.1 $3.1 $1.4 $17.2 Total $6.1 $5.6 $0.3 $3.7 $8.2 $17.0 $40.8 With nearly $293 billion in combined profits on nearly $4.8 trillion in combined revenue, having paid shareholders nearly $78 billion in combined dividends and having purchased nearly $41 billion of their own stock between 2018 and 2023, the automakers’ argument that they cannot transition over 10 years to a 100% ZEV sales quota must be seen for what it is: false. Despite these levels of profits, dividends, and stock buybacks, the automakers spent 22% less marketing electric vehicles on linear TV in the first 11 months of 2024 than they did in the same period of 2023. Their ads also generated approximately 34% fewer impressions in the same period in 2024 compared to 2023, meaning fewer people saw the ads proportionally. Nissan spent an estimated $129.2 million USD in the first 11 months of 2023, but only $31.4 million USD in the same period of 2024, a decrease of 121%. Ford spent an estimated $101 million marketing ZEVs in the first 11 months of 2023 (from $136.91 Billion USD of annual revenue – See Revenue Table Above), but only $55 million in the first 11 months of 2024, a drop of 45%.7 In the context of advertising by automakers, Professor Martin Olszynski of the University of Calgary Faculty of Law handily rebutted the automakers’ claim that consumers determine the composition of the vehicles on our roads: It is untenable…for the sector to claim that it was merely satisfying consumer demand and that it “can’t control consumer tastes.” The top five manufacturers (General Motors, Ford, Toyota, Fiat Chrysler and Honda) spent roughly $10 billion on advertising in 2019. That is an inordinate amount of money to spend on something that the industry claims to not be able to control.8 The absence of advertisements for ZEVs is glaringly obvious, and more so with the plethora of ads for gasoline pickup trucks and gasoline SUVs. The situation has at least the appearance of the automakers’ engineering low sales rates of ZEVs in recent months to justify their claim that they cannot achieve the sales quotas for 2026 and future years. Had the federal government not paused the ZEV rebate and had the automakers actually made a good faith effort to produce and market their ZEVs, it is highly likely that the sales quotas in 2026–and even beyond–would be met. ✉️ Make Your Submission! 1 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, pp. 16-17 (PDF Version). Retrieved on 20 September 2025 from https://www.citizen.org/article/stuck-in-neutral/ 2 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, p. 17 (PDF Version). Retrieved on 20 September 2025 from https://www.citizen.org/article/stuck-in-neutral/ 3 Ibid. 4 Ibid., p. 18 (PDF Version). 5 Ibid. p. 18 (PDF Version). 6 The data for the automakers’ profits, revenue, dividend payouts, and share buybacks was compiled by researchers at the NGO Public Citizen. This is their note on their methodology: “Notes on all financial tables: Honda and Toyota use a fiscal year that ends on March 31, while Ford, General Motors and Stellantis use calendar-year financials. To compare Honda and Toyota financials with the other companies we used fiscal 2019 through fiscal 2024 data for Toyota and Honda and calendar year data for the other three companies. As such, financial figures for 2023 reflect the entire year for GM, Ford and Stellantis, and the first three quarters of fiscal 2024 for Toyota and Honda. We converted figures in Euro (Stellantis) and Yen (Toyota/Honda) to U.S. dollars based on the average exchange rate for the calendar year reported. Stellantis was formed by the 2021 merger of FiatChrysler and Groupe PSA and has reported combined financials dating back to 2019 Full data is available here: Public Citizen analysis of Securities and Exchange Commission filings and company statements.” 7 Francis Scialabba, “Data: Automakers rein in EV ad spend”, Marketing Brew, 12 December 2024. Retrieved on 19 September 2025 from https://www.marketingbrew.com/stories/2024/12/12/automakers-ev-advertising-spend-slowdown 8 Martin Olszynski, Submission to the Standing Committee on Environment and Sustainable Development, 2 November 2020, p. 6.
I. Canadian ZEV Sales Are Depressed By Limited Selection
Last Updated: October 4, 2025One of the reasons that Canadians are not buying more ZEVs is because their selection is very limited. For example, the legacy automakers are selling ZEVs in Europe that they are not offering in Canada (or in the United States). In Europe, six Ford ZEVs are currently available for purchase, and two of them are available in different versions. The Mustang Mach E is a ZEV version of the Ford Mustang. The Ford Explorer EV, which has nothing in common with the ICE model sold in North America, is a ZEV Sports Utility Vehicle. The Ford Capri is a mid-sized ZEV sedan. The Ford E-Tourneo Courier is a ZEV that looks like a cross between a larger Sport Utility Vehicle and a van. Ford sells three different variations of it. Ford also sells two variations of the E-Transit, which looks more like a ZEV version of a van.1 Of these six ZEVs (plus variations of two of them), only the Mustang Mach E is readily available in Canada, although Ford also sells a ZEV pickup truck called the Ford F-150 Lightning. If Canadians had a wider selection of ZEVs to choose from, they would be more likely to find a ZEV that meets their needs, leading to an increase in ZEV sales. Demand is not the problem: Automakers are not offering the affordable ZEVs Canadians want to buy Not everyone wants a luxury car loaded with features. If you have the impression that ZEVs are expensive, you’re not wrong. But it doesn’t have to be this way! It turns out there are lots of affordably-priced ZEVs on the market – just not in Canada. Clean Energy Canada recently called attention to the issue, noting that, “Europe enjoys 21 electric vehicles selling for less than $40,000 Canadian. Only one of them is available in Canada.”2 The $40,000 price point is an important number because a recent survey showed that, “only 27% of respondents are willing to spend more than $40,000 on a new EV, whereas a car coming in under $40,000 drastically increases the pool of potential buyers to roughly half the population (49%).”3 Price remains the biggest barrier dissuading people from buying a new EV, with costs cited by 64% of respondents to a recent poll.4 Of the 21 affordable EVs available in Europe, seven are from Chinese automakers, 10 are European, three are Japanese, and one is South Korean. American automakers also sell EVs in Europe that they do not offer in Canada, though they sell for more than $40,000. For example, Ford sells an Explorer EV (which has little in common with the gas-powered model sold in North America) and a new Capri mid-sized sedan will be offered soon. Reportedly, “battery powered versions of the Puma crossover and Tourneo Courier van are also in the works.”5 Canadians overwhelmingly support a more open market with more affordable EV options, with 70% saying that Canada should allow vehicles approved in Europe to be sold here.6 Some are calling on the federal government to ease regulations to accept European vehicle standards, noting that a free trade agreement already exists between Canada and the European Union. 7 ✉️ Make Your Submission! 1 Ford of Europe, Ford Media Centre. Retrieved on 22 September 2025 from https://media.ford.com/content/fordmedia/feu/en/products.html 2 Clean Energy Canada, “Missing Out”, September 2025. Retrieved on 20 September 2025 from: https://cleanenergycanada.org/wp-content/uploads/2025/09/MissingOut-V5.pdf. 3 Clean Energy Canada, “Missing Out”, September 2025. Retrieved on 20 September 2025 from: https://cleanenergycanada.org/wp-content/uploads/2025/09/MissingOut-V5.pdf. 4 Little, Simon and Alissa Thibault, “Support for electric vehicle mandates softening in B.C., poll suggests”, Global News, 25 August 2025. Retrieved on 20 September 2025 from: https://globalnews.ca/news/11348970/ev-mandate-poll-bc-opposition/. 5 Dnistran, Iulian, “Ford Backs Off EV-Only Strategy In Europe By 2030: ‘It Was Too Ambitious’, Inside EVs, 19 July 2024. Retrieved on 20 September 2025 from: https://insideevs.com/news/727216/ford-ev-sales-portfolio-2030/. 6 Clean Energy Canada, “Poll: Large majority of Canadians favour more open car market with better access to affordable Chinese and European EVs”, 11 June 2025. Retrieved on 20 September 2025 from: https://cleanenergycanada.org/poll-large-majority-of-canadians-favour-more-open-car-market-with-better-access-to-affordable-chinese-and-european-evs/?trk=public_post_comment-text. 7 Murray, Nick, “EV advocates call on Ottawa to ease regulations on European vehicles”, The Canadian Press, 16 September 2025. Retrieved on 20 September 2025 from: https://www.nsnews.com/national-news/ev-advocates-call-on-ottawa-to-ease-regulations-on-european-vehicles-11219654.
J. The ZEV Regs Already Have “Compliance Flexibility” to Help Automakers
Last Updated: October 4, 2025In 2023, Canadian government officials responded to U.S. automakers’ collective opposition to the proposed regulations by introducing a set of so-called compliance flexibilities, which feature a credit mechanism. Under this mechanism, “Companies that perform better than their ZEV targets generate credits which they can bank for up to five model years or trade. Companies that do not meet their targets generate a deficit, which must be discharged within three model years. No accumulated or banked credits can be used to offset a deficit in model year 2035 and beyond.”1 Companies are allowed to generate full credits for those battery electric vehicles that are sold above the designated annual target numbers but only partial credits for certain plug-in hybrid electric vehicles (PHEVs) sold above the targets. They could opt either to bank or trade their credits for up to five model years.2 Moreover, auto manufacturers that act early are eligible to earn more rewards in this credit system, by obtaining early action credits (EACs) for ZEV sales in model years 2024 and 2025. According to the government, “To qualify, a company’s fleet must have had at least eight percent ZEVs in model year 2024 and 13 percent in model year 2025. Qualifying manufacturers can claim EACs between the annual minimum and 20 percent in both model years. EACs may not be traded and cannot be used after model year 2027. These provisions will create incentives for the sale of ZEVs in the short-term. They will also create an additional source of compliance options, which will enhance flexibility and smooth the transition of manufacturers to the new requirements.”3 In addition, automakers can earn credits for investing in fast-charging EV stations, which are in high consumer demand across Canada. Such credits can be traded, but they cannot be used after model year 2030. “Companies may generate one credit for each $20,000 invested in new fast-charging infrastructure projects that meet certain conditions,” which include having new DC fast-charging stations with at least 150 kW of rated power, opening between 1 January 2024 and 31 December 2027 and remaining in operation for at least five years, and being available to any ZEV with a compatible charging port or adapter.4 In an attempt to keep automakers from gaming the system more explicitly, the government stipulated that “the combined value of EACs and compliance units from investments in charging infrastructure [must not] exceed ten percent of a company’s ZEV target in any year.”5 Not surprisingly, though, automakers are now arguing that the credit system designed for their benefit two years ago no longer serves their financial interests. One of their expressed concerns is that, “as the targets become more stringent, there’ll be fewer credits available in the marketplace.”6 This appears to be an attempt to persuade Prime Minister Carney’s government that they are now suffering from an undue burden. ✉️ Make Your Submission! 1 Government of Canada, “Canada’s Electric Vehicle Availability Standard (regulated targets for zero-emission vehicles),” 19 December 2023. Retrieved on 21 September 2025 from https://www.canada.ca/en/environment-climate-change/news/2023/12/canadas-electric-vehicle-availability-standard-regulated-targets-for-zero-emission-vehicles.html 2 Arthur Zhang, “Debunking three myths about the ZEV mandate, 440 Megatonnes Project, 22 July 2025. Retrieved on 21 September 2025 from https://climateinstitute.ca/debunking-three-myths-about-the-zev-mandate/ 3 Government of Canada, “Canada’s Electric Vehicle Availability Standard (regulated targets for zero-emission vehicles),” 19 December 2023. Retrieved on 21 September 2025 from https://www.canada.ca/en/environment-climate-change/news/2023/12/canadas-electric-vehicle-availability-standard-regulated-targets-for-zero-emission-vehicles.html 4 Ibid. 5 Ibid. 6 Canadian Press, “Automakers could be on the hook for billions under EV mandate if sales don’t ramp up,” CTV News, 19 September 2025. Retrieved on 29 September 2025 from https://www.ctvnews.ca/canada/article/automakers-could-be-on-the-hook-for-billions-under-ev-mandate-if-sales-dont-ramp-up/
K. ZEV sales mandates work, and they work in Canada
Last Updated: October 4, 2025A 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.