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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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H. Canada’s 20% Sales Quota for 2026 Could Be Achieved But for the Automakers’ Intransigence

As 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:

  • earned nearly $293 billion in profits combined on nearly $4.8 trillion in revenue;
  • paid shareholders nearly $78 billion in dividends; and
  • purchased nearly $41 billion of their own stock.1

Major Automaker Profits, 2018 to 20232

Profit
($Billions 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
Stellantisn/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
($Billions USD)
201820192020202120222023Grand 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
Stellantisn/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
($Billions USD)
201820192020202120222023Grand 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
Stellantisn/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
($Billions USD)
201820192020202120222023Grand 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
Stellantisn/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.

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