The draft regulation under Québec’s Petroleum Products Act proposes an amendment to the framework governing how low-carbon fuel content is measured within gasoline and diesel. The amendment refines the Ministerial Order that sets out the approved methods and tools used to quantify carbon intensity for fuels blended or produced under the province’s clean fuel requirements. The objective is to better accommodate emerging industrial practices—specifically, co-processing—while reinforcing the broader policy goal of reducing greenhouse gas emissions.

Co-processing refers to the simultaneous processing of conventional fossil feedstocks and low-carbon inputs—such as bio-based materials—within existing refinery infrastructure. This approach allows fuel producers to integrate cleaner inputs without building entirely new production systems, offering a cost-effective pathway to decarbonization. However, until now, Québec’s regulatory framework has lacked explicit provisions for how to calculate the carbon intensity of fuels produced through such hybrid processes. This has created uncertainty for industry participants and limited the ability of regulators to fully recognize emissions reductions achieved through co-processing.

The proposed amendment addresses this gap by introducing a formal mechanism for calculating carbon intensity in co-processing scenarios. Specifically, it allows manufacturers to submit an application to the Minister seeking approval to use operational data derived from co-processing activities. This data must meet defined methodological standards: it must cover minimum periods of one week and rely on a comparative analytical framework. That framework requires a side-by-side assessment of two operational scenarios—a baseline case representing standard fossil fuel processing and a co-processing case in which low-carbon inputs are integrated—under otherwise similar operating conditions.

This comparative approach is critical from a regulatory standpoint. By isolating the variable of co-processing while holding other operational factors constant, it enables a more accurate estimation of emissions reductions attributable to the use of low-carbon inputs. In effect, the regulation is introducing a quasi-experimental methodology into compliance measurement, which strengthens both the credibility and verifiability of reported carbon intensity values. It also aligns Québec’s approach more closely with best practices seen in other low-carbon fuel standards, where lifecycle analysis and comparative baselining are commonly used.

Manufacturers cannot unilaterally adopt these alternative measurement methods; they must first obtain approval through a formal application process. This ensures consistency, prevents methodological manipulation, and allows the government to maintain control over how emissions reductions are quantified across the sector. It also creates an administrative checkpoint where technical assumptions, data integrity, and methodological rigor can be scrutinized before acceptance.

Quebec (Draft) March 18, 2024
Disclaimer: Insights are for informational purposes only and does not reflect RRI’s official position or constitute legal opinion.