On October 5, 2026, the final amendments to the Regulation amending the Regulation respecting the application of the Consumer Protection Act (the “Regulation“) are expected to come into force, completing the implementation of the new “good working order” warranty in the province of Quebec.
When this warranty applies, the merchant or manufacturer will be required to repair the product or cover the cost of the repair. Merchants will also be required to disclose the duration and terms of the good working order warranty before the purchase or long-term lease of a product, and after the contract is concluded, notably with written notices containing mandatory information.
The Good Working Order Warranty
The good working order warranty applies to specific new goods covered by the Consumer Protection Act (the “CPA“) that are sold or leased under a long-term lease. The duration of the warranty is established by Regulation as follows:
Household appliances and electronic devices:
- 6 years: stove, refrigerator, freezer, air conditioner, heat pump;
- 5 years: dishwasher, washing machine, dryer;
- 4 years: television;
- 3 years: desktop computer, laptop, tablet, cellphone, video game console.
Automobiles:
- 6 months or 10,000 km, whichever term occurs first: vehicles with fewer than 80,000 km and first marketed no more than 4 years earlier;
- 3 months or 5,000 km: vehicles with fewer than 100,000 km and first marketed no more than 5 years earlier;
- 1 month or 1,700 km: vehicles with fewer than 120,000 km and first marketed no more than 7 years earlier.
Motocycles:
- 2 months: motocycles first marketed no more than 2 years earlier;
- 1 month: motocycles first marketed no more than 3 years earlier.
The good working order warranty covers both parts and labour and takes effect upon delivery of the product. However, it does not cover routine maintenance, the replacement of parts required as part of normal maintenance, or damage resulting from misuse of the product by the consumer.
When repairs are required under the good working order warranty, the manufacturer or merchant must either perform the repairs or pay for them. The manufacturer or merchant must also bear the transportation costs associated with the repairs.
The CPA also specifically provides that this warranty is enforceable by subsequent purchasers of the product.
Disclosure Obligations
As of October 5, 2026, manufacturers and merchants must clearly and understandably disclose the duration of the good working order warranty online. The warranty period must also be displayed next to the product’s price or, in the case of leased goods, in a clearly visible location.
Before offering an extended warranty for an additional fee, merchants must also provide consumers with a paper notice setting out the terms and conditions of the good working order warranty, including its duration.
Position of the Retail Council of Canada
Following the publication of the Regulation, the Retail Council of Canada (RCC) expressed significant concerns about the new good working order warranty in a statement released in December 2025.
According to the RCC, the new warranty requirements could result in price increases of approximately 20% to 30% for the affected products.
Conclusion
With the introduction of the good working order warranty, the Quebec Minister of Justice sought to position the province as a leader in consumer protection in North America1.
This reform represents one of the most significant amendments to the CPA in recent years. Its purpose is to strengthen consumer protection by establishing minimum periods during which certain durable consumer goods must function properly and by reinforcing the disclosure obligations imposed on merchants and manufacturers.
Information relating to the good working order warranty will now be considered material information, and failing to disclose it will constitute a prohibited practice under the CPA.
It remains to be seen how the Courts will interpret and apply these new obligations as case law develops.
1See : Office de la protection du consommateur, « Une nouvelle garantie sur plusieurs biens – Les Québécois bientôt mieux protégés en cas de bris d’un de leurs biens », press release, December 17, 2025, Simon Jolin-Barrette, Minister of Justice, Attorney General of Québec and Minister Responsible for Consumer Protection, online <https://www.opc.gouv.qc.ca/en/actualite/communiques/article/les-quebecois-bientot-mieux-proteges-en-cas-de-bris-dun-de-leurs-biens>.
