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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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G. Canada’s 20% Sales Quota for 2026 Could Be Achieved If Not Hindered by Changes in Government Policy

According 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/”

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