HRAI Comments on Québec “Right to Repair” Act and Proposed Regulations

HRAI was recently invited to comment on proposed regulations supporting the Province of Quebec’s Law Protecting Consumers Against Planned Obsolescence and Promoting Durability, Repairability, and Maintenance of Goods.  The legislation, passed on October 5, 2023, amends the Consumer Protection Act or Loi sur la protection du consommateur (LPC)The law created new powers for the government but stipulated that certain measures would be specified in regulation.  This legislation was designed to protect consumers in the province from “planned obsolescence” practices of some manufacturers of appliances and consumer electronics goods but included in the identified products “air conditioners and heat pumps.” 

The consultation process invited manufacturers to comment on a variety of proposed regulations that would provide “guarantees of good working order” and guarantees of availability of parts, among other things.  HRAI commented in earlier discussions that products sold and installed by the HVAC industry should be exempt because the practices of concern are almost non-existent in the sector and because HVAC products are in a class of installed systems that are (and ought to be) maintained by trained professionals. 

Following the guidance of manufacturer members, HRAI made some comments in response to the consultation document but also included a letter once again requesting an exemption for a variety of reasons. 

To review HRAI’s submissions, click on the following links: 
HRAI’s cover letter requesting exemption (English)

For more information, contact Martin Luymes at 1-800-267-2231 ext. 235 or email 

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