While a dishwasher from the 1980s can still run smoothly, many newer models seem to break down after just a few cycles!
The 2023 adoption of the Act to Protect Consumers Against Planned Obsolescence and to Promote the Durability, Repairability and Maintenance of Goods1 (hereinafter the “Anti-Obsolescence Act“), which modified the Consumer Protection Act2 (the “C.P.A.“), aimed specifically to address this very phenomenon of planned obsolescence.
The new provisions introduced by the Act impose a range of obligations on manufacturers and merchants regarding the maintenance and repair of goods.
Starting October 5, 2025, the Regulation amending theRegulation respecting the application of the Consumer Protection Act3 (the “Regulation“) will officially come into force, bringing significant changes to how manufacturers and merchants operate—with substantial fines for non-compliance4.
Reminder of the New Principles
The Anti-Obsolescence Act focuses on ensuring that consumers have easy access to four key elements related to the maintenance and repair of goods5:
- Replacement parts;
- Repair services;
- Information necessary for the maintenance and repair of a good that may require servicing; and
- Tools needed to install replacement parts.
New Regulatory Provisions in Force as of October 5, 2025
1) “Tool”
Under the Act, tools required for the installation of replacement parts must be “commonly available”6 to consumers.
The Regulation7 now clarifies that:
a) The tool must be provided free of charge no later than upon the consumer taking possession of the good; or
b) It must be available at a reasonable price and within a reasonable time frame, through a remote contract (i.e., an online transaction).
2) Disclosure of Information by Manufacturers
Under the Act, manufacturers must inform consumers about the availability of replacement parts and repair services, and provide the information required for the maintenance or repair of goods whose availability they guarantee8.
The Regulation further specifies that full, partial, or no availability of these elements must be disclosed online, in a clear and intelligible manner9.
If a manufacturer only partially guarantees the availability of any such element, they must also specify online—again, in a clear and intelligible manner—which elements are not fully guaranteed10.
This information must be presented in a way that allows it to be easily printed or saved, and must also be included in the user and maintenance manuals for the goods11.
3) Disclosure of Information by Merchants
Merchants are subject to the same disclosure obligations as manufacturers regarding the full, partial, or absent guarantee of availability for replacement parts, repair services, and maintenance/repair information—but must provide this information “in writing”12.
The Regulation also specifies, as it does for manufacturers, that if any of these elements is only partially guaranteed, the merchant must indicate in writing which elements are not fully guaranteed13.
In addition, merchants must publish, “near that information”, a hyperlink leading directly to the manufacturer’s published information14.
Based on our interpretation of the Regulation, if merchants publish all required information online in a clear and understandable format that allows consumers to easily print or save it, they are not obligated to provide it on physical media15.
Conclusion
Manufacturers and merchants will need to work closely together to ensure compliance with the new mandatory disclosure requirements on maintenance and repair, starting October 5, 2025. It will also be interesting to see how tools required for repairs will be made accessible to consumers and if manufacturers do in fact modify their user manuals on time.
On September 16, 2025, the Retail Council of Canada (RCC) and the Canadian Federation of Independent Business (CFIB) publicly opposed the Regulation, calling its implementation “impossible” for Quebec merchants16.
It will indeed be interesting to observe how these new obligations will be enforced by manufacturers and merchants, and what impact they will have on consumer practices in Quebec.
The changes for merchants aren’t stopping there! Starting next year17, a new guarantee of “good working order” will apply to certain new goods—such as household appliances and cellphones—sold or leased under long-term contracts18. Additionally, new obligations will be introduced regarding promotional displays and labeling requirements, including information about the duration and details of the warranty, through an upcoming regulation19.
We’ll continue to monitor all developments and keep you updated!
1 https://www.rsslex.com/en/bulletins-en/1-2-3-and-the-dishwasher-goes/; AnAct to Protect Consumers Against Planned Obsolescence and to Promote the Durability, Repairability and Maintenance of Goods, Bill 29 (presentation-June, 1st, 2023), 1er sess., 43e légiste. (QC). [Anti-Obsolescence Act]
2 Consumer Protection Act, RLRQ, c. P-40.1. [C.P.A.]
3 Regulation amending theRegulation respecting the application of the Consumer Protection Act, D. 800-2025 (G.O. II). [Regulation]
4 Fines of up to $3,500 per day of non-compliance may be imposed on legal persons. See: C.P.A., art. 276.1.
5 Anti-Obsolescence Act, art. 4.
6 Regulation, art. 79.17.
7 Regulation, art. 79.17.
8 Regulation, art. 79.17; L.p.c., art. 39.1.
9 Regulation, art. 79.18, al. 1; L.p.c., art. 39.1.
10 Regulation, art. 79.18, al. 2; L.p.c., art. 39.1.
11 Regulation, art. 79.18, al. 3; L.p.c., art. 39.1.
12 Regulation, art. 79.19, al. 1; L.p.c., art. 39.2.
13 Regulation, art. 79.19, al. 2; L.p.c., art. 39.2.
14 Regulation, art. 79.19, al. 3; L.p.c., art. 39.2.
15 Regulation, art. 79.20; L.p.c., art. 39.2.
16 Fédération canadienne de l’entreprise indépendante, salle de presse, Garantie de réparabilité : « des règles impossibles à appliquer », en ligne : <https://www.cfib-fcei.ca/fr/medias/garantie-de-rparabilite-des-regles-impossibles-appliquera>.
17 October 5, 2026
18 C.P.A., art. 38.1.
19 C.P.A., art. 38.8 and 38.9.
