Mr. Chair and committee members, thank you for the invitation to appear today as part of your study of the electric vehicle availability standard, the EVAS.
The members of the Canadian Vehicle Manufacturers' Association are committed to electrification. In fact, they are leading the transition to electric in Canada. Ford and General Motors are the zero-emission vehicles sales-market leaders through the second quarter of this year. Stellantis is the only automaker in Canada manufacturing batteries and assembling a light-duty zero-emission vehicle.
Over the past decade, the number of zero-emission vehicles available for sale to Canadians has increased by 400%. Today, there are 115 models on the market in every size and segment to meet the transportation needs of all Canadians. Despite these investments into electrification, ZEV sales have collapsed. There were 17,192 new ZEVs sold in September 2025. That's a decrease of 43.3% from the same month the previous year. It should be clear to everyone now that federally mandated ZEV sales targets established in the EVAS are unrealistic and unachievable. To meet the 23% sales target for 2027, ZEV sales would need to increase by 256% immediately. Achieving 60% ZEV sales by the 2030 model year is even more unrealistic. It would require a compound annual growth rate of over 48%.
We recommend that the government fully repeal the EVAS and instead focus on building out the supports that Canadians need to go electric. This includes incentives for Canadians to purchase ZEVs and a rapid build-out of charging infrastructure. According to the federal government's own numbers as of October 2025, there are only 37,000 public charging ports in operation. That is far short of the 100,000 needed this year and the 410,000 required by 2035. To support this charging infrastructure, Canada needs to invest in clean electricity generation and grid capacity. NRCan estimates that the grid upgrades required to meet ZEV demand, including generation, transmission and distribution, will cost up to $294 billion over the next 15 years.
Repealing the EVAS does not jeopardize Canada's emissions reduction goals. The EVAS duplicates our existing greenhouse gas emission standards, adding an unnecessary burden without any additional environmental benefit. Canada's GHG emission regulations have already driven significant reductions in vehicle emissions—49.8% for passenger cars and 30.7% for light trucks since 2011. These are outcomes-based, technology-neutral standards that are far superior to the EVAS. They provide flexibility. They support innovation, and they do not distort the market. Persisting with the expensive, duplicative and ineffective EVAS risks inflicting lasting harm on automakers at precisely the wrong moment.
Automakers are under intense pressure due to tariffs and trade disruptions that put the sector and the hundreds of thousands of jobs it supports at risk. To comply with this regulation, automakers are forced to restrict sales of internal combustion engine vehicles and to purchase credits from foreign manufacturers that do not build cars in Canada. If the regulation is not repealed, automakers will have to remove between 700,000 and 900,000 gas-powered and fuel-efficient hybrid vehicle sales from this market starting this year, and they will have to purchase over $3 billion in compliance credits. Of the 1.3 million vehicles built in Canada last year, 95% will be prohibited for sale in this country because of the EVAS. This would be devastating for the auto industry, dealerships and the Canadian economy.
Canadians will ultimately bear the brunt of this regulation in the form of job losses, higher vehicle prices and less availability as vehicle restrictions limit inventories. According to Environment Canada's own assessment of the regulation, the EVAS will have a disproportionate impact on low-income Canadians, rural Canadians and northern communities that are going to face higher vehicle prices and have limited access to charging infrastructure. That is in Environment Canada's own assessment of this regulation.
As the Prime Minister has said, “In the face of a changing global landscape, we [must focus] on what we can control”. Repealing the EVAS is the most effective way to protect this critical industry and ensure that Canadians are spared from the damaging effects of this regulation.
Thank you.