According 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:
- Chronic exposure to PM2.5 air pollution contributed to 8.0% of all-cause nonaccidental mortality among Canadians over 25 years of age, equivalent to 10,000 deaths per year or 27 deaths per 100,000 population.
- Acute exposure to NO2 air pollution contributed to 0.9% of all-cause nonaccidental mortality among Canadians of all ages, equivalent to 1,300 deaths per year or 4 deaths per 100,000 population.
- Acute exposure to ozone was associated with 2.7% of all-cause nonaccidental mortality among Canadians of all ages, equivalent to 2,800 deaths per year or 8 deaths per 100,000 population. This estimate was derived using the annual average of daily 1-h maximum ozone concentrations.
- Chronic exposure to ozone was associated with 10% of respiratory-related mortality among Canadians over 30 years of age, equivalent to 1,300 deaths per year or 4 deaths per 100,000 population. This estimate was derived using the summer average of daily 1-h maximum ozone concentrations.
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.
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