On July 16, 2025, the Québec government unveiled the latest phase of draft regulations under Bill 29, An Act to protect consumers from planned obsolescence and to promote the durability, repairability, and maintenance of goods, which received royal assent on October 5, 2023.
This most recent draft regulation focuses specifically on a key pillar of the legislation: the warranty of good working order.
A recap of Bill 29
As a reminder, Bill 29 significantly bolsters the protections afforded to Québec consumers under the province's Consumer Protection Act ("CPA"). As we previously reported, Bill 29 covers a broad spectrum of consumer protection issues—from lemon laws for defective automobiles to new restrictions aimed at curbing planned obsolescence in consumer goods.
While the legislation establishes important new rights and obligations, many of the practical implementation details were deferred to future regulations. This means that while the overarching policy intent is now clear, several operational questions remain open pending the release of these supporting regulatory instruments.
The regulations are being published in successive stages. The most recent—the proposed Regulation to amend the Regulation respecting the application of the Consumer Protection Act (the "Draft Regulations")—outlines the framework for the Warranty of Good Working Order, which will apply to certain prescribed categories of new consumer goods offered for sale or lease.
Key highlights of the new Draft Regulations
This mandatory warrant —which will cover both parts and labour—will be accompanied by specific disclosure requirements for both manufacturers and merchants. It is important to note that while the concept of a 'Warranty of Good Working Order' was not explicitly defined in the parliamentary debates surrounding Bill 29, the Québec government did express that the concept is distinct from the prescribed statutory warranty of durability (whereby goods must be durable in normal use for a reasonable length of time).
Warranty duration
The Draft Regulations specify the duration of the Warranty of Good Working Order for the following prescribed category of goods:
|
Duration of the Warranty of Good Working Order |
Items |
|
6 years |
Range Refrigerator Freezer Air conditioner Heat pump |
|
5 years |
Dishwasher Washing machine Dryer |
|
4 years |
Television set |
|
3 years |
Desktop computer Laptop computer Electronic pad Cell phone Video game console |
Online disclosure
Pursuant to Bill 29, manufacturers of goods covered by a Warranty of Good Working Order will be subject to specific online disclosure requirements, as set out in the Draft Regulations, regarding both the content and manner of disclosure.
Post-contractual disclosure
Bill 29 also requires that, following the conclusion of a contract of sale or long-term lease for a good covered by a Warranty of Good Working Order, the merchant must provide the consumer with the information relating to the warranty, in the manner and under the conditions prescribed in the Draft Regulations. Specifically, it states that the merchant must provide the consumer with a written document with prescribed mandatory clauses "immediately after the contract has been entered into."
Used automobiles and motorcycles
Used automobiles and used motorcycles have long been subject to Warranties of Good Working Order under the CPA, even prior to Bill 29. Under Bill 29, the warranty applicable to used automobiles was modified slightly: whereas it used to apply to vehicles up to five years old (on condition that they met certain mileage requirements), vehicles up to seven years old can now be covered in some cases.
Under the Draft Regulations, prior to offering to sell an additional warranty on a used automobile or motorcycle that benefits from this Warranty, merchants will now have to provide consumers with requisite disclosure.
Coming into force date
The requirements established by the Draft Regulations are set to enter into force on October 5, 2026, at the same time as the provisions in the Consumer Protection Act enacting the Warranty of Good Working Order.
As mentioned above, the Regulation is currently in draft form. A 45-day public consultation period will run from July 16, 2025 until August 30, 2025, during which members of the public may submit comments on the Draft Regulations.
This article was co-authored with Inès Maarouf.
Read the original article on GowlingWLG.com
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