What We Told Ottawa About Canada's Sustainable Development Strategy
- Lori Guetre
- May 14
- 6 min read
Updated: May 20
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): a high-level statement of what Canada plans to do, by when, on the 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 what we said and why. The full submission is available here. It's longer and more technical, but the core argument is straightforward enough to fit in a few minutes of reading.
The gap we identified
The draft Strategy does many things well. 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 - highlighting that clean growth drives innovation, investment, and export potential in sectors like clean technology, critical minerals, and energy efficiency.
But the draft has a structural gap. The Strategy invokes "one strong Canadian economy" and "net-zero by 2050" repeatedly - and then offers Canadians no way to participate in the transition at the point of purchase, no transparency about the emissions embedded in what they buy, an incomplete toolkit for decarbonizing the supply side, and a regulatory architecture beneath the net-zero target where the math doesn’t add up.
That last point is worth pausing on. Canada's net-zero target is legally binding. But 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, freight trucking, smaller methane sources.
Roughly 69% of Canadian emissions sit in sectors that are regulated, but where the rules don't require the sector to reach zero. Oil and gas, electricity, heavy industry, light-duty vehicles, landfills.
Approximately 0.4% of Canadian emissions are covered by the one federal regulation that does require a sector to reach zero: the 2018 Coal-Fired Electricity Regulations.
A legally binding net-zero target combined with regulations that - with one narrow exception - require neither full coverage nor a zero endpoint is not arithmetically coherent. The math doesn't add up. And Canada is far from alone in this. We've been mapping the same gap across a number of major economies, and Canada sits in the middle of the pack. An upcoming Research & Insights report on our website (+ blog post) will share what we've found.
Four mechanisms that close it
The good news is that closing the gap doesn't require new spending or new federal departments. We proposed four mechanisms - designed as a system, building on instruments Canada already has.
1. Climate Footprint Labels. Mandatory CO₂e labels on products and services, the same way Nutrition Facts works for food and EnerGuide works for appliances. When emissions become visible, producers compete on efficiency and consumers 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.
2. Abatement Pathway Standards - with permanent carbon removal eligible in every sector. This is the most technical of the four, and also the most important. Some emissions are genuinely hard to eliminate - enteric methane from cattle, off-road diesel in remote mining, certain industrial processes. For decades, those sectors have argued that decarbonization is technically infeasible for them. They are correct that no fully-scalable solutions exist currently to eliminate these emissions, but 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 rigour, 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.
3. Geo Zero Product Certification. A federal certification for products whose residual emissions, after best-effort reductions, have been permanently removed. This gives first-mover Canadian producers a way to demonstrate climate quality, and gives consumers a way to recognize products that have addressed their whole climate footprint.
4. A Universal Ramp to Regulate All Emissions. We asked for every source of emissions to be on a published, predictable, multi-decade ramp from its current state to fully decarbonized by 2050. Gentle ramps where international competitiveness requires it. Permanent removal available as the universally available backstop. The 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 - red meat, long-haul flights, cement - sit outside this range. They're the exceptions, not the rule.
The 2% number matters because it answers the three fears that have constrained climate policy for two decades: that the problem is unsolvable, that the cost would be ruinous, that Canada acting alone is futile. None of these fears survive contact with the actual math. Catalytic converters added 8–12% to vehicle costs initially and settled at 2–4%. CFC-free products added 3–5% and settled at near zero. Lead-free gasoline added 1–3% and 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 benefit transformational. Embedded carbon is the next entry in this sequence.
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 construction. Emissions today determine outcomes for people who can't yet vote, can't yet write to their MP, 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 for this anxiety.
The four mechanisms in this submission are, among other things, mechanisms for restoring agency. They make the path forward visible. They give people something to choose.
Why we submitted
Government consultations rarely produce headlines. They produce regulations, slowly, over years. But the Strategy is the document that aligns every federal department's environmental plan for the next three years. Its specific words matter.
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 think 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.
