Docs Category: II. SUGGESTIONS FOR IMPROVING OR "FIXING" 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
Last Updated: October 4, 2025It is vital that the government maintain the final sales quota in the ZEV Regs that requires 100% of new light duty vehicle sales be ZEVs in 2035 and each year thereafter. In the RIAS for the ZEV Regs, Environment and Climate Change Canada states light duty vehicles have an estimated life expectancy of 15 years.1 At the Paris Agreement in 2015, Canada, along with most of the rest of the countries of the world, committed to achieving net-zero emissions by 2050. Canada subsequently enacted this as domestic law in the Canadian Net-Zero Emissions Accountability Act.2 If Canada permits the sale of any light duty ICE vehicles in 2035 or thereafter, those ICE vehicles will still be emitting GHGs in 2050. There is no viable Carbon Capture Utilization and Storage (CCUS) system for light duty vehicles. ✉️ Make Your Submission! 1 RIAS, pp. 4043-4044. 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 Canadian Net-Zero Emissions Accountability Act, (S.C. 2021, c. 22), s. 6. Retrieved on 28 September 2025 from https://laws-lois.justice.gc.ca/eng/acts/c-19.3/fulltext.html
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
Last Updated: October 4, 2025Although the government has cancelled the 20% sales quota for 2026, it should maintain the 23% sales quota for 2027 and the sales quotas for each subsequent year. If the automakers made a legitimate effort, they could readily achieve these quotas. Furthermore (and as noted above), the ZEV Regs already contain “compliance flexibility mechanisms” that make it easier for the automakers to achieve the sales quotas. One of these is the early ZEV credits: Early ZEV credits The [ZEV Regs] will allow a company to earn early ZEV credits for selling ZEVs in model years 2024 and 2025 within a specific threshold. Companies only earn early ZEV credits for the ZEV portion of their fleet offered for sale that is both below the 2026 target (20%) and above 8% in 2024 and 13% in 2025. The latter percentages were established based on analysis of current ZEV adoption trends in Canada and provincial ZEV regulatory requirements in 2024 and 2025. These credits are earned at the same rate as if they were sold in model year 2026, except there is no limit on the contribution of PHEVs towards the overall early ZEV credit allowance. In addition, only regulatees in a deficit can use early ZEV credits, and they can only use them to offset their own deficits in model years 2026 and 2027, meaning they cannot be traded to other manufacturers. However, the combined contribution of early ZEV credits and ZEV charging station credits… that can be used to meet a company’s compliance obligation is capped at 10% per model year.1 The federal government should amend the ZEV Regs so the early credit compliance flexibility mechanism includes 2026 and so the benefit of it is extended into 2028. ✉️ Make Your Submission! 1 RIAS, p. 4001. 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
C. Provide extra credit for selling ZEVs at a price below $40,000 CDN
Last Updated: October 4, 2025Clean 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/