The draft Regulation published under the Environment Quality Act proposes targeted amendments to the Regulation respecting a cap-and-trade system for greenhouse gas emission allowances (chapter Q-2, r. 46.1). The initiative is undertaken pursuant to sections 46.1, 46.5, 46.6, 46.8 to 46.16 and 95.1 of the Act, as well as section 285 of the Act to amend the Environment Quality Act to improve the environmental authorization scheme and to amend other legislative provisions, in particular to reform the governance of the Green Fund (2017, chapter 4). The amendments are administrative and terminological in nature, but they are necessary to ensure coherence within Québec’s regulatory framework governing greenhouse gas emissions and agri-environmental practices.

The primary purpose of the draft Regulation is to harmonize terminology used in the cap-and-trade regulation with new terminology proposed in the draft Regulation respecting agri-environmental practices. The draft instrument would replace the existing Agricultural Operations Regulation (chapter Q-2, r. 26), thereby updating the regulatory regime applicable to agricultural activities. As a result of this broader modernization effort, certain expressions currently embedded in the cap-and-trade regulation require adjustment to remain consistent with the revised agri-environmental lexicon.

Specifically, section 1 of the draft amending Regulation modifies the last paragraph of Division 1 of Part I of Protocol 1 of Appendix D to the cap-and-trade regulation. The amendment replaces the phrase “livestock waste with liquid manure management” with the expression “liquid livestock waste.” Although the change appears minor, it reflects a deliberate effort to standardize terminology across regulatory instruments. In technical regulatory schemes such as emissions trading systems, definitional precision is critical. Offset protocols, eligibility criteria, monitoring requirements, and verification processes often hinge on clearly defined operational categories. By aligning the terminology with that used in the forthcoming agri-environmental practices regulation, the amendment reduces interpretive ambiguity and supports consistent application by regulated entities, verifiers, and administrative authorities.

The cap-and-trade system established under Québec law forms a central component of the province’s climate policy architecture. It sets a declining cap on greenhouse gas emissions and allocates emission allowances to covered emitters, who must surrender allowances equivalent to their verified emissions. The system also recognizes certain offset credits generated through approved protocols, including agricultural and livestock-related projects. Terminological consistency in these protocols is therefore essential to maintain legal certainty, ensure environmental integrity, and facilitate regulatory oversight.

In substance, the draft Regulation does not alter emission caps, compliance obligations, or market mechanisms within the cap-and-trade system. Rather, it performs a harmonization function within a broader modernization of Québec’s environmental regulatory framework.

Quebec (Draft) February 25, 2026
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