Canada's Clean Fuel Regulation (CFR) is the youngest of North America's major clean fuel programs — and one of the fastest-moving. In Rimba's recent webinar, "Fuel the Future: Navigating Canada's Clean Fuel Regulation," we sat down with Jermin Hsiesh, Manager, Renewable Gas Compliance & Reporting at FortisBC, for a practical tour of how the CFR works and what producers should be planning for. Here are the key takeaways.

01Why the CFR exists: tackling transportation emissions upstream

Transportation is one of the largest slices of the emissions pie in any developed economy, and the policy tools built to address it fall into two broad camps. Downstream measures — EV mandates and rebates — are the ones most visible to the public. But a great deal of carbon is embedded in everything that happens before fuel reaches a vehicle's tank: feedstock production, processing, refining, and distribution.

Upstream regulations like Canada's CFR (and the U.S. Renewable Fuel Standard) target exactly those emissions, so the transportation sector is addressed holistically from both ends.

02Fuel mandate vs. clean fuel standard: two different designs

Jermin Hsiesh drew a useful distinction between the two dominant regulatory models:

The two LCFS programs date back to 2010; the CFR came into force in June 2022, making it the newest of the three. Like its predecessors, its targets are designed around a 2030 horizon.

03Who participates, and how credits are created

Two groups drive the CFR market. Primary fuel suppliers are the obligated parties: they must meet emissions-reduction requirements either by lowering the carbon intensity of their own fuel or by acquiring CFR credits generated elsewhere. Voluntary credit creators aren't obligated under the regulation but opt in by producing or importing low-carbon-intensity fuels and bringing them to use in Canada — then selling the resulting credits to obligated parties.

04Behind the 400% surge in registered RNG volumes

RNG volumes registered under the CFR jumped more than 400% between the 2023 and 2024 compliance periods. Jermin Hsiesh attributed the surge to two converging factors — noting that because CFR activities lag the compliance period, the work behind the 2024 numbers largely happened in 2025.

05How carbon intensity works under the CFR

Feedstock eligibility is a defining feature of the CFR. For RNG, feedstocks must be biogenic — free of fossil-derived material — and the regulation takes a firm position on the food-versus-fuel question: purpose-grown crops are not eligible. In practice, the dominant RNG feedstocks are wastes: byproducts from industrial food manufacturing, green bin organics from curbside collection programs, hard-to-process streams like packaged waste requiring depackaging, and a broad range of manures, from dairy to beef cattle.

Carbon intensity itself is measured in grams of CO₂-equivalent per megajoule of fuel, summed across the full life cycle — feedstock sourcing, plant operations, and transportation of the fuel to its end use.

One of the most consequential refinements in the 2024 Fuel LCA specification is guidance on avoided emissions. A producer depackaging contaminated waste that would otherwise go to landfill can now claim credit for that diversion — potentially earning a significantly more favorable CI score. But the bar is high: the regulation requires a well-substantiated case for what would have happened to that waste otherwise.

Jermin Hsiesh also flagged a notable cross-program difference. California's LCFS has produced deeply negative carbon intensities for dairy manure RNG — outcomes not seen under the CFR or the BC LCFS. Much of the divergence comes down to secondary data: the default values baked into each program's CI model. BC's LCFS uses GHGenius, California's LCFS uses the GREET model, and the CFR uses an openLCA-based Fuel LCA Model — each with its own defaults, and each producing different results for the same project.

06Approval timelines: from sluggish to manageable

With CFR credits trading around CA$300–320, developer interest is high — which makes the pathway approval timeline a critical planning question.

Jermin Hsiesh was candid about the program's early growing pains. The CFR launched in 2022 as a nationwide program covering an unusually wide range of fuels — RNG, ethanol, biodiesel, and hydrogen, but also specialty fuels like renewable propane. That inclusiveness was a double-edged sword: it left Environment and Climate Change Canada (ECCC) with an enormous amount to manage, and heavy volumes of information requests bogged the system down. Historically, getting a carbon intensity approved could take one to one and a half years.

Those timelines are shrinking. The Fuel LCA framework is clearer, consultants and verification bodies have climbed the learning curve, more auditors are available, and ECCC has become notably better at triaging applications — prioritizing projects with genuine timing urgency where delays would mean lost credit-generation opportunity. The message to developers: historical timelines are no longer representative, and the process today is far more manageable.

07Where the CFR goes from here

The CFR's targets run to 2030 — which, as Jermin Hsiesh noted, is just around the corner. Given how long regulatory consultation takes, consultations on the post-2030 framework will likely need to begin within the next 12 to 18 months, and those consultations will offer the clearest signal of the program's direction.

The prevailing industry view is that continuity is likely. Substantial investment has been made on both the obligated-supplier and voluntary-credit sides, and walking the program back would undercut that capital.

"Don't put your eggs in one basket. The CFR is one side of things — utilize everything that's out there."

Jermin Hsiesh · FortisBC — advice to project developers

Credit prices are strong today, but next year's market is unknowable, and uncertainty exists both within the current CFR and beyond 2030. Developers should stack every mechanism available — the CFR alongside U.S. tax credits and other programs — rather than building a business case on a single regulation.