Trade disputes disrupt canada’s sustainability

Trade disputes and uncertainty in Canada: resetting the sustainability agenda

Co-Author: Shane Thompson
Contributors: Eri Marques , Mathilde Ensminger


In brief:

  • Trade uncertainty and paused regulations in 2025 are pushing Canadian businesses to reassess their sustainability strategies.
  • Companies must navigate evolving global disclosure rules and continuously manage climate, social, and supply chain risks.
  • Despite market turbulence, embracing sustainability now will help Canadian firms stay competitive, attract capital, and access new markets for the long run.

As the world navigates the turbulence of 2025, Canadian businesses have been faced with paused sustainability disclosure regulations, escalating trade wars and shifting government policies. Are these headwinds enough to blow their sustainability efforts off course? Or will they provide a new passage to improved resilience and competitiveness?

Headwinds for sustainability 2025
1

Chapter 1

Headwinds for sustainability in 2025

1. Paused disclosure regulations

2025 has seen the temporary halt or postponement of several key sustainability disclosure regulations. In April, the Canadian Securities Administrators (CSA) paused work to make the Canadian Sustainability Disclosure Standards (CSDSs) mandatory. March saw the US Securities and Exchange Commission (SEC) pausing — effectively withdrawing — its climate change disclosure rule. And in February the European Union’s Omnibus bill delayed and lightened the application of the Corporate Sustainability Reporting Directive (CSRD).

The CSRD delays were welcomed by preparers to allow a more measured pace of change. But let’s be clear: businesses must still make a significant investment to prepare for the delayed regulation.

Additionally, investors are still demanding transparent and consistent sustainability reporting to make risk-informed decisions. Companies that hold themselves up due to a lack of clarity on regulations risk losing sight of the expectations of clients and other stakeholders, let alone their ability to drive meaningful change.

2. Trade war and supply chain redeployment

The ongoing trade war with the US has introduced new compliance and accounting risks. This affects Canadian import and export markets, creating significant uncertainty and disrupting supply chains until a new agreement is negotiated. For example, Canadian metal producers, who export 84% of their base metals valued at C$47.3 billion [1] to the US, became subject to 25% tariffs, then 50% overnight, and these tariffs remain subject to further change as negotiations progress.

 

As a response to uncertainty, businesses seek to grow or diversify their exports to expand their revenue base. They could find support in these endeavours coming from the federal government, which is attempting to redraw existing trade channels, for example between Europe and Canada, thus providing potential future opportunities for Canadian exporters.

 

However, businesses will have to navigate complex sustainability-related regulations affecting global trade to secure market access. For example, the EU’s Carbon Border Adjustment Mechanism (CBAM) adds a layer of complexity, asking EU importers to pay for the carbon emissions embedded in goods they import. This requires exporters to have emissions data readily available.

 

Likewise, Canadian businesses exporting to Asian markets must take into account evolving sustainability reporting regulations in the region. Depending on the jurisdiction, businesses may be required to disclose both financial impacts of sustainability issues and their broader environmental and social effects and prepare sustainability reports accordingly, including climate-related disclosures and greenhouse gas emissions. For example, in 2024 the Chinese Ministry of Finance issued the Basic Guidelines for Corporate Sustainability Disclosure, where the principle of double materiality would be applied. [2]

 

As trade dynamics shift constantly, Canadian businesses must be prepared not only for uncertainty around tariffs but also for the growing expectation to disclose and manage carbon emissions across their supply chains.

 

3. Policy changes

Recent elections in Canada and the US signal potential shifts in sustainability policy.

 

In the US, the Inflation Reduction Act (IRA) initially drove major clean energy investments, but its future has become increasingly uncertain. The recent enactment of the One Big Beautiful Bill Act (OBBBA) marks a significant shift in federal priorities, scaling back or eliminating many of the IRA’s clean energy tax incentives and grant programs, including over US$20 billion in climate-related funding. [3] While some changes may be phased in gradually, the OBBBA signals a move toward a more fragmented policy environment. One where sustainability strategies must be resilient enough to withstand shifting incentives and agile enough to capitalize on emerging opportunities at the state or private sector level.

 

In Canada, on the other hand, the federal government has set a clear ambition for concerted action, backed by provincial Premiers, to reduce trade barriers between provinces, encourage major infrastructure investments and make Canada an energy superpower. These developments could reshape traditional trade routes and require changes in regulatory frameworks and funding.

 

A major turning point came with the passage of Bill C-5, the One Canadian Economy Act, which grants the federal cabinet sweeping powers to fast-track large-scale infrastructure and energy projects. Framed as a response to mounting trade tensions with the US, the legislation aims to stimulate economic resilience by accelerating project approvals deemed to be in the national interest. While the government has emphasized that projects aligned with Indigenous leadership, clean growth and sustainable technologies will be prioritized, the bill’s broad scope and discretionary mechanisms raise questions about long-term regulatory certainty, environmental oversight, and the consistency of sustainability commitments.

 

With policy and sentiment in constant flux, businesses must be prepared to pivot quickly — yet keep their sustainability performance at a level that will enable, rather than hinder, future developments.

Resetting sustainability strategies for business resilience
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Chapter 2

Resetting sustainability strategies for business resilience

Amid this turbulence, one might think that sustainability has quickly become an afterthought. But the reality is that Canadian companies have an opportunity to reset their sustainability agendas to not only weather the storm, but to emerge more resilient and more productive on the other side. They can craft an adequate business response around four key strategic priorities:

  • Comply
  • Manage risks
  • Compete
  • Differentiate

Finding the right balance for these priorities will empower businesses to thrive in an increasingly complex and uncertain global market.

1. Comply

Canadian companies must obviously prioritize compliance with existing mandatory regulations such as human rights Bill S-211, a plethora of environmental, health and safety (EHS) regulations, and specific mandates like Bill C-15 respecting the rights of Indigenous Peoples, and Bill C-59, the federal Competition Act targeting greenwashing, to name but a few.

Compliance and transparent reporting are legal imperatives both in Canada and abroad, that require navigating an evolving regulatory environment. To achieve cohesive and streamlined disclosures, compliance efforts must be underpinned by a strong reporting program that effectively coordinates diverse contributors. This requires integrated systems, reliable data, and digital infrastructure to support timely and high-quality inputs, along with robust processes and controls to enhance data completeness and accuracy. Below are a few compliance focus areas applicable to most Canadian businesses.

Human rights, health and safety: Proactive compliance with human rights and EHS standards is — and will remain — foundational. EHS compliance is a non-negotiable element of doing business, and so are human rights monitoring and reporting with the implementation of Bill S-211 in Canada, or for companies in scope for CSRD reporting.

Packaging, waste and product responsibility: Canadian exporters to the EU and other markets face new sustainability compliance and data obligations for exported products across the value chain. For instance, the EU’s Ecodesign for Sustainable Products Regulation (ESPR), in effect since July 2024, introduces phased sustainability requirements across sectors.[4] Starting in July 2025, large companies must begin disclosing environmental performance for priority products such as textiles, electronics, furniture, aluminum and steel.

Similarly, several US states are proactively addressing packaging waste and associated treatment costs through their own extended producer responsibility (EPR) programs. States such as Oregon, California, Colorado, Minnesota and Maine are already encouraging producers and importers to design packaging that is easier to recycle, reuse or dispose of safely. Momentum is growing nationwide, with additional EPR bills being introduced in 2025.

 

Climate and carbon pricing regulations: As climate regulations evolve, Canadian businesses must adapt to stay competitive. With carbon pricing mechanisms such as Canada’s Output-Based Pricing System (OBPS) — technically still in place at the time of writing — and the EU’s Carbon Border Adjustment Mechanism (CBAM), as well as plans for similar carbon borders or emissions trading schemes in the UK, Australia, Japan and Mexico, companies face fees based on their emissions in Canada and on exports abroad. This necessitates investments in tracking systems to ensure compliance and mitigate costs.

 

Canadian Sustainability Standards Board (CSSB) alignment and Bill C-59: While the CSSB reporting standards are in effect in Canada, their use is not yet mandated by the securities regulators and is in fact paused. This does not diminish the fact that the global momentum towards mandatory sustainability disclosures is growing strong. More than 30 jurisdictions are either implementing or considering the ISSB standards requiring companies to disclose how sustainability matters might impact cash flow, financing and the cost of capital.

 

With jurisdictions representing almost 60% of global GDP adopting or considering ISSB standards, businesses face growing pressure from regulators and investors to deliver this data. It’s only a matter of time until such sustainability disclosures are widely mandated. As is the case for the EU CSRD, these can lead to mandatory reporting by a Canadian parent company. Companies anticipating this will be ahead and better plan for the significant demands such mandates place on management’s time.

 

To add to the already complex regulatory landscape, Bill C-59 directly targets greenwashing by requiring companies to substantiate environmental and social claims made in promotional material with verifiable data and reference internationally recognized methodologies. In response, we have seen several businesses withdraw or scale back voluntary sustainability commitments and disclosures to avoid potential legal or reputational risks related to unsupported claims. For those maintaining such commitments, the bar is now higher: claims must be backed by robust evidence. This level of scrutiny signals a shift, where transparency isn’t just encouraged, it’s enforceable.

2. Manage risks

In today’s turbulent business environment, sustainability risk management is still essential for companies’ operational success and business resilience. Sustainability-related risks have not gone away and remain very much on top of the list of enterprise risks for virtually every organization anywhere on the planet.

These risks include:

Environmental risks: Improper management of environmental aspects leads to noncompliance, resulting in contamination of air, water and soil. This can result in regulatory penalties and damage to a company’s reputation. While many companies still underestimate these risks, stakeholders are paying increasing attention to environmental risk impacts to the business, such as water risk or biodiversity dependencies. By adopting sound environmental management systems, businesses can not only mitigate these risks comply with environmental regulations and achieve their sustainability goals, they can also enhance operational efficiency, productivity and reduce long-term costs.

Social risks and dependencies: There are countless impacts organizations may have on society, such as labour rights violations, their impact on communities, direct and indirect health impacts, affordability and unequal access to products or services. At the same time, most businesses depend on the availability of a healthy and skilled workforce, as well as functioning social services and communities. Effective management of social risks can lead to improved worker satisfaction, improved brand reputation and consumer loyalty and overall business resilience.

Physical climate risks: Businesses must assess how climate-related risks such as extreme weather events translate to financial risk and may result in asset degradation, operational interruptions and reduced infrastructure resilience. 2024 was the fifth year in a row with global insured losses greater than US$100b, while Canada saw record insured losses exceeding C$8.5 billion across the country. For instance, companies in the agriculture sector may face challenges related to chronic changes in weather patterns that affect crop yields, while manufacturers or resource companies may encounter disruptions in supply chains due to acute impacts of natural disasters; think flooding and wildfires in Canada. Climate risks are projected to continue escalating, which will require robust adaptation and business resilience strategies.

Transition risks: As the world continues to shift towards a low-carbon economy, however indirect the course, businesses still need to navigate the implications of changing consumer demand, regulatory pressures, new technology and market dynamics. A disorderly transition — which many would argue we are experiencing — may lead to oversupply or shortages in different areas of the economy or country that could be very costly. Companies that fail to adapt may find themselves at a competitive disadvantage. 

3. Compete

Strong sustainability management provides a competitive edge because many sustainability initiatives present a positive ROI, often in the form of attracting capital, accessing new markets or realizing cost savings. Companies that focus on the right sustainability programs enhance their top line, margins and ability to compete in the market.

Attracting capital through transparent disclosures: Investor focus on sustainability remains strong, not as a trend, but as a lens for evaluating long-term risk and opportunity. Investors monitor sustainability ratings and nonfinancial performance, channelling capital towards companies that manage their sustainability risks.

This is especially true for European LP investors, who require incremental sustainability information — but not only that. As of 2025, 88% of institutional investors factor sustainability data into their analysis, particularly around resilience, regulatory exposure and supply chain risk.

In Canada, where foreign direct investment and export-driven growth are priorities, access to this data is critical for demonstrating resilience and removing regulatory barriers.[5]

For companies now looking to compete for global capital, demonstrating how they manage material sustainability risks is no longer optional, it’s expected.

Accessing new markets: With many businesses looking to access new markets, sustainability performance is becoming a prerequisite for global trade.

The EU’s Carbon Border Adjustment Mechanism (CBAM), now in its transitional phase, requires importers to report on embedded emissions in carbon-intensive goods. By 2026, Canadian exporters will need to provide verified emissions data to avoid penalties. Companies aiming to expand into the EU should also keep both the Corporate Sustainability Reporting Directive (CSRD) and the EU Deforestation Regulation top of mind.

Likewise, Canadian businesses eyeing the United Kingdom should anticipate the future adoption of Sustainability Reporting Standards aligned with the ISSB framework.

In Asia, Japan and South Korea are implementing mandatory climate-related financial disclosures aligned with the ISSB standards starting in 2025, which will affect listed companies and their supply chains and extend requirements to foreign suppliers. Canadian exporters targeting these markets may need to consider alignment with these frameworks to remain competitive, meet buyer expectations and access new markets amid tariffs.

Simple actions that can save money: Businesses that invest in sustainable practices often find that the initial costs are offset by savings and improved operational efficiency. For example, implementing energy efficiency measures typically presents an attractive payback — sometimes less than five years — for initiatives such as cogeneration, fuel switching, building energy efficiency, and even electrification of processes and transportation, especially in industries such as oil and gas, and manufacturing. These initiatives have become even more attractive due to federal and provincial funding programs such as investment tax credits, which are expected to continue, perhaps even increase in Canada under the new government.

Organizations are also paying greater attention to their power purchase agreements (PPAs) when evaluating energy use and efficiency measures to boost both cost savings and decarbonization objectives. Waste minimization can also help reduce businesses’ third-party waste management bills and product waste, and optimize for eco-fees and packaging costs in the very short term.

4. Differentiate

To thrive in today’s turbulent landscape, meaningful sustainability actions can further help companies differentiate their brand, products and services in the market. However, many organizations find themselves in need of “resetting” their strategic priorities with respect to sustainability objectives. Whether they are quietly continuing their sustainability programs under the radar of the public eye or ramping up their data analytics to stand by their sustainability claims, progress towards improved sustainability is continuing.

Canada as the epitome of tomorrow’s resource economy: In an era of renewed political interest and major capital spend on large-scale energy, transportation and resource projects, Canadian businesses are faced with a generational opportunity to showcase what tomorrow’s resource economy needs to look like. There is probably no better place in the world than Canada to demonstrate what the mine of the future looks like, what responsible energy is made of or how regenerative agriculture can feed the world, for example.

Responding to procurement shifts: Procurement teams, especially in government and large enterprise sectors, are embedding sustainability criteria into supplier evaluations. Examples include low-carbon concrete and steel in government infrastructure projects. Businesses that can demonstrate strong sustainability credentials are gaining a competitive edge in RFPs and long-term contracts.

Product innovation and market fit: Meeting evolving expectations also means innovating to meet emerging client needs, whether through new business models, refined value propositions, or advancements in product materials and technologies. Consumers continue to prioritize sustainability in their purchasing decisions, even amid growing economic pressures. This can be a simple focus to buy local, or to focus on reducing individual and household waste — signalling a clear demand for products that align with environmental values.

To differentiate themselves, companies embed sustainability into product development as a core strategy, for example through circular design or low-impact materials. Business models are also evolving towards servicing models — think car sharing — further responding to market shifts. Focusing on evolving expectations helps align with client values and positions businesses not just to respond to consumer expectations, but to shape them.

Value chain transformation: Businesses must review their entire value chain for risks and opportunities such as optimization of manufacturing processes, circularity, strategic energy management and value-based capital stewardship.

As a simple example, airports have a role to play to make sustainable aviation fuels available to their clients, even if they won’t use them. Similarly, ports need to provide the right infrastructure to electrify shipping operations.

In those contexts, companies that want to differentiate themselves will collaborate with partners in their value chain and benefit from optimized digital infrastructure that removes key barriers — like limited visibility across value chains, fragmented data collection and inconsistent input formats across operations.

AI and digitalization: As data demands intensify, businesses are turning to AI to manage complexity, improve accuracy and unlock new efficiencies. From automating emissions tracking to forecasting climate risks and optimizing resource use, AI is helping companies move from reactive compliance to proactive performance. It also plays a critical role in navigating and tracking global regulatory requirements, enabling organizations to stay ahead of evolving disclosure obligations.[6], [7]

EY’s Global Smarter networks, greener planet report, in collaboration with Liberty, has explored a wide range of case studies where businesses are using AI to support their sustainability objectives.

Sustainability for long-term resilience
3

Chapter 3

Sustainability for long-term resilience

Canadian businesses stand at a crucial crossroads, where the complexities of trade conflicts and political shifts present both challenges and unprecedented opportunities. Whichever direction Canadian businesses take, sustainability is not just a tick-the-box response to regulatory pressures or market fads, it is a powerful catalyst for innovation and resilience in the face of uncertainty.

ESG has been politicized and is now under scrutiny in some circles. However sustainability is here to stay as a business imperative that will continue to be driven by various expectations from regulators, markets, consumers and investors.

Rather than retreating, this is a time for Canadian businesses to reset sustainability strategies — anchoring them in compliance, risk management, competitiveness and differentiation. Business leaders must act decisively to futureproof their business models and thrive in a more complex, sustainability-challenged and climate-conscious global economy.


Summary:

Despite ongoing trade uncertainty and regulatory shifts, sustainability remains a critical priority for Canadian businesses. Rather than retreat, companies must reset their strategies—focusing on compliance, risk management, competitiveness, and differentiation. Those that act decisively can futureproof operations, enhance resilience, and unlock growth in a fast-evolving global economy.


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