ARTICLE
12 August 2025

Québec's Warranty Of Good Working Order: A New Draft Regulation Sets Out Its Duration And Mandates Specific Disclosures From Merchants And Manufacturers

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Torys LLP

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On July 16, 2025, the Government of Québec published a draft regulation (the Draft Regulation) to amend the Regulation respecting the application of the Consumer Protection Act...
Canada Quebec Consumer Protection

On July 16, 2025, the Government of Québec published a draft regulation (the Draft Regulation) to amend the Regulation respecting the application of the Consumer Protection Act1 that sets out the duration of the warranty of good working order applicable to certain goods. This follows the adoption of An Act to protect consumers from planned obsolescence and to promote the durability, repairability and maintenance of goods2 (the Act) on October 5, 2023, which we review in our previous bulletin, "Bill No. 29: Measures against planned obsolescence adopted by Québec", summarizing the amendments to the Consumer Protection Act (CPA) introduced by the Act.

What you need to know

  • This new warranty comes into effect on October 5, 2026, and establishes a "floor" period of good working order during which the merchants and manufacturers of certain commonly used goods must assume the goods' repair costs (parts and labour).
  • In addition to setting out the duration of this new legal warranty and specifying the disclosures required from merchants and manufacturers, the Draft Regulation sets out certain obligations for merchants before they offer consumers to purchase a contract that includes an additional warranty on goods already covered by the warranty of good working order.

Duration of the warranty of good working order for certain goods

As of October 5, 2026, the Draft Regulation introduces the following timelines for the warranty of good working order applicable to certain goods:

  • 6 years for a range, a refrigerator, a freezer, an air conditioner and a heat pump;
  • 5 years for a dishwasher, a washing machine and a dryer;
  • 4 years for a television set; and
  • 3 years for a desktop computer, a laptop computer, an electronic pad, a cellular telephone and a video game console.

In the event of malfunction of the goods under the above-mentioned warranty, merchants and manufacturers are required to repair the goods free of charge.

Although only certain goods are currently covered by the warranty of good working order, the Act allows the Government to add, by regulation, other goods that would also be covered.

Obligation to disclose the warranty of good working order before and after the purchase

The Draft Regulation also sets out the way in which merchants offering goods covered by the warranty of good working order must inform consumers before and after entering into a purchase contract.

Before entering into a purchase contract

While the CPA requires, as of October 5, 2026, that merchants disclose the duration of a good's warranty of good working order near its advertised price3, the Draft Regulation requires manufacturers of a good covered by the warranty of good working order to disclose the duration of the warranty in a prominent and comprehensible manner on their website.

In addition, before offering consumers to purchase an additional warranty on goods, merchants will be required to provide consumers with a document in paper form informing them of the legal warranty of good working order, as set out in the Draft Regulation.

After entering into a purchase contract

Immediately after entering into a purchase contract, merchants will be required to provide consumers with a written document prominently displaying a disclosure of the legal warranty of good working order, including the merchant's and the manufacturer's obligations in the event of malfunction of the goods under the warranty.

Conclusion

In accordance with the Regulations Act, the Draft Regulation may be enacted by the Government in September 2025. The new provisions will come into force on October 5, 2026.

Footnotes

1. See, Regulation to amend the Regulation respecting the application of the Consumer Protection Act, (2025) 157 G.O.Q. II, No 29, 2879.

2. See, An Act to protect consumers from planned obsolescence and to promote the durability, repairability and maintenance of goods (2023, chapter 21).

3. Section 38.8 CPA.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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