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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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E. The Automakers Have Met 2024 and Earlier Sales Quotas in Canada and Other Jurisdictions

The 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

YearSales Quota
202422%
202528%
202633%
202738%
202852%
202966%
203080%
203184%
203288%
203392%
203496%
2035100%

Table of United Kingdom Annual Sales Quotas For Zero Emission Vans6

YearSalesQuota
202410%
202516%
202624%
202734%
202846%
202958%
203070%
203176%
203282%
203388%
203494%
2035100%

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:

  • increasing flexibility of the mandate for manufacturers up to 2030, so that more cars can be sold in later years when demand is higher
  • allowing hybrid cars – like the Toyota Prius and Nissan e-Power – to be sold until 2035 to help ease the transition and give industry more time to prepare
  • continuing to boost demand for electric vehicles, on top of the £2.3 billion we’re already spending on boosting British manufacturing and improving charging infrastructure – with a new charge-point popping up every half an hour
  • pressing on with tax breaks worth hundreds of millions of pounds to help people switch to electric vehicles

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.

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