What We Told Ottawa About Canada's Sustainable Development Strategy
Updated: Aug 28
A Summary of Possible by Design's Submission to Canada’s 2026–2029 Federal Sustainable Development Strategy Consultation
Every three years, the Canadian federal government publishes a Federal Sustainable Development Strategy (FSDS). This document outlines what Canada plans to do regarding environmental and social issues that shape the country's future. The current draft - for 2026 to 2029 was open for public comment until May 12. Possible by Design submitted a response.
This post summarizes our key points and the reasoning behind them. You can find the full submission here. It's more detailed and technical, but the core argument is straightforward enough to fit into a few minutes of reading.
The Gap We Identified
The draft Strategy has its strengths. It maintains Canada's legally binding commitment to net-zero emissions by 2050. It sets interim targets for 2030 and 2035. It rightly frames decarbonization as an economic opportunity, emphasizing that clean growth drives innovation, investment, and export potential in sectors like clean technology, critical minerals, and energy efficiency.
However, the draft has a significant structural gap. It repeatedly invokes "one strong Canadian economy" and "net-zero by 2050," yet offers Canadians no way to participate in the transition at the point of purchase. There is no transparency about the emissions embedded in what they buy, and the toolkit for decarbonizing the supply side is incomplete. The regulatory architecture beneath the net-zero target is flawed.
Let’s pause on that last point. Canada's net-zero target is legally binding. Yet, underneath it:
Roughly 31% of Canadian emissions sit in sectors with no federal requirement to reduce emissions at all—agriculture, much of building heat, off-road diesel, domestic aviation, marine shipping, and freight trucking.
Approximately 69% of Canadian emissions are in sectors that are regulated, but where the rules don't mandate reaching zero. This includes oil and gas, electricity, heavy industry, light-duty vehicles, and landfills.
Only 0.4% of Canadian emissions are covered by the one federal regulation that requires a sector to reach zero: the 2018 Coal-Fired Electricity Regulations.
A legally binding net-zero target, combined with regulations that—except for one narrow exception—require neither full coverage nor a zero endpoint, is not arithmetically coherent. The math simply doesn't add up. Canada is not alone in this issue. We've been mapping the same gap across several major economies, and Canada sits in the middle of the pack. An upcoming Research & Insights report on our website, along with a blog post, will share our findings.
Four Mechanisms That Close It
The good news is that closing this gap doesn't require new spending or new federal departments. We proposed four mechanisms designed as a system, building on instruments Canada already has.
We advocate for mandatory CO₂e labels on products and services, similar to how Nutrition Facts works for food and EnerGuide works for appliances. When emissions become visible, producers will compete on efficiency, and consumers will gain the ability to choose. The EU has begun mandating carbon footprint disclosure on products, starting with batteries this year and expanding across product categories through its Ecodesign for Sustainable Products Regulations. Canada has the option to lead or follow.
This mechanism includes permanent carbon removal eligible in every sector. This is the most technical of the four and also the most crucial. Some emissions are genuinely hard to eliminate, such as enteric methane from cattle and off-road diesel in remote mining. For decades, these sectors have claimed that decarbonization is technically infeasible. While they are correct that no fully-scalable solutions exist currently to eliminate these emissions, permanent carbon dioxide removal—pulling CO₂ out of the air and storing it geologically for a thousand years or more—finally makes it possible for them to address their emissions. Once permanent removal is available as a backstop solution for whatever can't be reduced, no sector can credibly claim that a path to zero is impossible.
On March 12, 2026, Canada quietly became the first country in the world to set up a standing offer to procure permanent carbon removal at this level of scientific rigor for federal operational emissions in the National Safety and Security Fleet. It's a small initial purchase, but it sets a world-leading precedent. We urged the federal government to codify that precedent and extend it across all federal departments with hard-to-decarbonize operations, and as an eligible compliance pathway in every Canadian decarbonization instrument.
This certification would apply to products whose residual emissions, after best-effort reductions, have been permanently removed. It provides first-mover Canadian producers a way to demonstrate climate quality and gives consumers a way to recognize products that have addressed their entire climate footprint.
We requested that every source of emissions be on a published, predictable, multi-decade ramp from its current state to full decarbonization by 2050. Gentle ramps are necessary where international competitiveness requires it. Permanent removal should be available as the universally accessible backstop. The key point isn't that the ramp is steep; the point is that it exists.
The Cost Question
The single most important number missing from the public conversation about climate action is this: for the vast majority of products and services, cleaning up the embedded emissions adds roughly 2% to the price.
This finding originates with Jens Burchardt at Boston Consulting Group and has been confirmed by updated analysis using current carbon footprint data and permanent removal at $200–$500 per tonne. A few products with unusually high footprints—like red meat, long-haul flights, and cement—sit outside this range. They're the exceptions, not the rule.
The 2% figure is crucial because it addresses three fears that have constrained climate policy for two decades: that the problem is unsolvable, that the cost would be ruinous, and that Canada acting alone is futile. None of these fears withstand scrutiny when faced with the actual math. Catalytic converters initially added 8–12% to vehicle costs and settled at 2–4%. CFC-free products added 3–5% and settled at near zero. Lead-free gasoline added 1–3% and eventually settled at zero. Every time we've removed a systemic harm by setting a smart standard, the steady-state cost has been small, and the benefits have been transformational. Embedded carbon is the next challenge we need to tackle.
Who This Is For
The Federal Sustainable Development Strategy commits that "no one is left behind." We urged the federal government to extend that commitment to one group whose harm from inaction is mathematically certain but who currently have no voice in the process: Canadians not yet born and Canadians who are currently young. They will live longest with the consequences of decisions made now, and they have no seat at the table where those decisions are made.
Climate harm is intergenerational by nature. Emissions today determine outcomes for people who can't yet vote, can't yet write to their MP, and can't yet shape the choice environment they'll inherit. Climate anxiety in young Canadians is now a measurable, growing burden. Research consistently finds that perceived agency—the sense that one can see a credible path forward and contribute to it—is a protective factor against this anxiety.
The four mechanisms in this submission are, among other things, mechanisms for restoring agency. They make the path forward visible and give people something to choose.
Why We Submitted
Government consultations rarely produce headlines. They produce regulations slowly, over years. However, the Strategy aligns every federal department's environmental plan for the next three years. Its specific wording matters.
Canada has held a genuine first-mover position in permanent carbon-removal purchasing and in the multilateral standards work it has been quietly leading for fifteen years. Now that the EU has formally adopted the first government-adopted certification methodologies for permanent removals, the moment calls for alignment rather than divergence. The next step is clear: work quickly together toward universal (ISO) standards so projects can serve all customers through one transparent, high-integrity system.
We submitted an FSDS response because we believe it's worth the few hours it took to write, and because the next three years matter more than the headlines suggest.
The full submission is on our website.
Thanks for joining us on this journey—both to have our voices heard and to let the Canadian government know that a vast majority of us care.
