Updates on Regulatory Issues in Quebec
Members should be aware of several regulatory issues in the province of Quebec that will have an impact on the HVACR industry.
On December 16, 2024, HRAI convened a meeting of members to discuss several regulatory issues affecting members active in Quebec. Charles Bernard from Impact Public Affairs guided HRAI Members through several important issues of interest to the HVACR industry.
Working groups have been formed on each of these three topics and will be meeting throughout 2025. If you would be interested in joining any of these working groups, please contact Perry Chao pchao@hrai.ca.
Right-to-Repair, Availability of Parts and Repair Services
In 2023, the government of Quebec put in place changes to the province’s Consumer Protection Act in Bill 29 with new requirements for a legal warranty of good working order, availability of replacement parts and repair services on some new products, while prohibiting planned obsolescence. The legislation also gives the government the power to determine technical or manufacturing standards for goods. Air conditioners and heat pumps are included in the regulation, but not water heaters.
The requirements for the warranty of good working order are scheduled to come into force on October 5, 2026. Requirements for the warranty of the availability of replacement parts, repair services and the information necessary to repair or maintain goods will come into force on October 5, 2025.
Extended Producer Responsibility (EPR) / End-of-Life
Members discussed Quebec’s expected requirements for extended producer responsibility (EPR), the responsibility of producers and importers of HVACR equipment for the management and cost of end-of-life programs addressing equipment dropped off at municipal waste or recycling facilities.
French-language Requirements
Members also discussed Quebec’s 2022 language legislation (Bill 96) that imposed many new requirements on businesses providing services or goods to Quebec residents. The new legislation provides new requirements for public signs, advertising, and the products themselves. Recent regulations did not include requirements for inscriptions necessary for the use of a product to be in French, even when engraved, riveted, welded or embossed, but could be added at a later time.
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