Thank you, Mr. Chair.
Thank you, members of the committee, for the opportunity to speak to you today on behalf of the 16 member companies of the Global Automakers of Canada.
The Global Automakers of Canada is a national trade association representing the Canadian interests of 16 of the world's most significant automakers. Our members are collectively responsible for more than 62% of the sales in Canada, and our two manufacturing members, Toyota and Honda, are Canada's largest and second-largest vehicle producers, representing, through the end of September, 75.5% of Canadian light-duty vehicle production. Additionally, GAC member Volkswagen and their partner PowerCo remain in the process of building up the $7-billion factory in St. Thomas, Ontario, which is slated to employ up to 3,000 people directly.
Importantly, the members directly and indirectly employ more than 216,000 people, contribute almost $25 billion to Canada's GDP and generate more than $10.5 billion in government revenues.
With respect to electric vehicles, GAC members have been at the forefront of their introduction into the Canadian marketplace, with the Nissan LEAF and the Mitsubishi i-MiEV being introduced in Canada in 2011. Since then, GAC members have gone on to make 63% of the 120 model variants of ZEVs available in Canada, with more to come.
I want to be clear at the outset that the members of the GAC are fully committed to decarbonizing their products. Our challenge with the government has always been the tools deployed to attempt to drive that decarbonization and the time frame over which that decarbonization should take place.
The EVAS is a technology-specific tool. The rules, as currently constructed under the EVAS, establish targets that are not achievable by the entire industry. We believe that both industry and government want achievable, durable regulatory certainty. To that end, we appreciated the government's response to pause the application of the EVAS for the 2026 model year.
We want to offer additional specific recommendations.
First, the review should be extended beyond the initial 60-day period in order to develop realistic regulation for automakers that keeps Canada competitive with Europe and the United States. We currently do not know what the regulatory environments will be in these jurisdictions, and we need to know that in order to develop a credible and competitive climate policy.
Second, we believe the government should pause the application of the EVAS for the 2027 and 2028 model years as well, for which our members are currently finalizing product planning without knowing what the regulations will be moving forward. This additional pause could be undertaken while still incentivizing automakers with early action credits as they continue to bring zero-emission vehicles to market.
Third, the membership of the Global Automakers of Canada is diverse, with smaller and larger manufacturers. Some have full product lineups, while others have limited product lineups. If EVAS is to remain, it must be flexible, and maximum flexibility is required. In our view, such flexibility would contemplate providing automakers with the option of complying with either GHG emissions regulations or a revised, achievable ZEV mandate. Under such a scenario, if a company met the provisions of one regulation, it would be deemed to have met the provisions of the other. This approach would assist industry by allowing each company to adopt the regulatory framework that would work best for that company's needs while ensuring that the goal of emissions reduction is achieved. This flexibility is key, especially with the current supply chain disruptions and the unprecedented tariff situation, which have put a strain on companies' financial liquidity. Importantly, such flexibility would avoid product constraint for consumers and retain maximum choice.
Fourth, British Columbia's and Quebec's respective ZEV mandates are a significant internal trade barrier for automakers in Canada. They distort the internal market and present compliance liabilities for automakers. The Government of Canada must work with both jurisdictions to ensure alignment with the federal government's policy approach. At the very least, it should secure agreement from both provinces for a “deemed to comply” clause within their regulations, which recognizes EVAS compliance as an effective compliance with their own provincial mandate.
Finally, the collapse of consumer demand for ZEVs demonstrates that the government cannot reasonably set targets for ZEV adoption without complementary and established demand-side policies, such as addressing price parity for consumers and supporting access to reliable and affordable charging infrastructure.
At the end of the day, if we're not crystal clear on the goal of the regulation, it's very difficult to know if we have achieved it.
The current situation is that we have more ZEV models available than ever before. What the industry doesn’t have is customers, or at least not enough of them to meet the regulatory targets for next year. What customers don’t have are the incentives that were put in place to encourage them to purchase ZEVs.