Provincial Updates – Extended Producer Responsibility and Right-to-Repair

Members may be interested in two updates on provincial issues that are of interest to the HVACR industry. 

We are pleased to enjoy involvement from many HRAI members in working groups that meet occasionally to review these topics. If you or any colleagues would be interested in getting involved, or have any questions or suggestions, please reach out to HRAI’s Director of Regulatory Affairs, Perry Chao at pchao@hrai.ca.  

British Columbia – Extended Producer Responsibility 

In early 2025, BC’s Ministry of Environment and Climate Change notified industry stakeholders of their intention to include heat pumps as “large air treatment” equipment in their Recycling Regulation.  

A working group of HRAI members has met regularly to discuss options for the industry to meet the Ministry’s request. 

BC’s Regulation requires producers selling or distributing what it calls “large air treatment” equipment in British Columbia to:  

  • Create and submit an Extended Producer Responsibility (EPR) Plan  

  • Manage an EPR Program and submit annual reports on the plan’s performance and targets  

  • Establish a new agency or join an existing EPR agency to assume regulatory obligations as a producer, and submit an EPR Plan on each company’s behalf 

HRAI working group member have suggested that HRAI staff work with industry partners to survey the types of HVACR equipment and brands that are finding their way into BC municipal waste facilities. That work will be underway over the summer of 2025, and will inform a draft proposal to assist the HVACR industry’s efforts to meet BC’s regulatory requirements.  

The next steps for the working group will be to review this proposal, likely in Fall 2025. 

Quebec – Consumer Protection Act Regulations: Right-to-Repair and Warranty of Good Working Order 

Quebec’s provincial government has posted two proposals Consumer Protection Act regulations that may impact the HRAI members operating in the province. HRAI is grateful for working group members who will be discussing comments that the industry can submit on these proposals.  

  1. Regulation on repairs/replacement parts, and techniques that prevent repair – revised regulation 

The Ministry has made revisions to its proposed regulations for sections related to: 

  • availability of repairs and replacement parts (section 79) and  

  • techniques that inhibit repair (section 91). 

Members have raised concerns that the proposed regulations are not suitable to the HVACR industry’s supply chain, which operates differently from retail supply chains, and that the regulation could be interpreted as encouraging non-certified individuals to perform repair and replacement work on their own HVACR systems. 

Comments for this revised regulation are open until August 8. The revised regulation is available though this link: 

  1. Duration of the warranty of good working order 

The Ministry’s second regulatory proposal defines the duration for the “warranty of good working order” that became a requirement in section 38 of the Quebec Consumer Protection Act.  

The duration of the “warranty of good working” order provided for in section 38.1 of the Act is defined as six years for a refrigerator, a freezer, an air conditioner and a heat pump. The regulation also requires the manufacturer to disclose, online, the duration of the warranty of good working order covering the goods in a prominent and comprehensible manner.  

The merchant would be required to provide the consumer with a written document prominently displaying the following compulsory clause.  

The manufacturer and/or the merchant are required to repair the goods free of charge. 

Comments for this revised regulation are open until September 1st. 

Text for this proposed regulation is available through this link:  

For more information on either of these issues, please contact: 

Perry Chao 

Director of Regulatory Affairs 

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