29 January 2026 • 4 minute read
Quebec establishes the duration of the legal warranty of good working order for specific consumer goods
On 17 December 2025, the Government of Quebec published the Regulation to amend the Regulation respecting the application of the Consumer Protection Act (order-in-council 1459-2025), which amends the Regulation respecting the application of the Consumer Protection Act (RCPA) and clarifies the scope of the legal warranty of good working order. The new provisions will come into force on October 5, 2026, at the same time as certain amendments to the Consumer Protection Act (CPA) on the same subject. As a reminder, these amendments stem from the adoption of Bill 29 in 2023, which aims to address planned obsolescence by promoting the durability, repairability, and maintenance of consumer goods.
At the outset, it is useful to recall that the legal warranty of good working order is not new to the CPA: it has already applied to used automobiles and motorcycles for several years. However, the amendments to the CPA and RCPA will extend this warranty to other categories of goods.
In this article, we will provide an overview of how the legal warranty of good working order will apply to the new goods covered by the CPA, as well as the related obligations of merchants and manufacturers.
Scope of the legal warranty of good working order
Under the CPA, the legal warranty of good working order guarantees that consumers are entitled to the free repair of certain goods purchased or leased in the event of malfunction for a specified period of time. This warranty, however, excludes damages resulting from abusive use of the goods by the consumers, as well as routine maintenance of the good, and the replacement of parts resulting from such maintenance.
The legal warranty of good working order takes effect upon delivery of the goods and is transferable to subsequent acquirers. Provided the consumer invokes this warranty within the applicable period, the merchant or manufacturer concerned must cover both the cost of replacement parts and labour to repair the goods, as well as reasonable transportation or shipping costs necessary for the repair.
As of October 5, 2026, the legal warranty of good working order will apply to the following new goods: a range, a refrigerator, a freezer, a dishwasher, a washing machine, a dryer, a television set, a desktop computer, a laptop computer, an electronic pad, a cellular telephone, a video game console, an air conditioner, and a heat pump.
As of the date of this article, the above list is complete, subject to any additions that the Government of Quebec may subsequently make.
Duration of the legal warranty of good working order
The starting point for the legal warranty of good working order is the date at which the goods are delivered, and its total duration will vary depending on the goods delivered, as follows:
|
Goods |
Duration of the warranty of good working order |
|
6 years |
|
5 years |
|
4 years |
|
3 years |
Disclosure obligations of merchants and manufacturers regarding the legal warranty of good working order
As of October 5, 2026, the duration of the warranty of good working order for the new goods mentioned above must be disclosed by the manufacturer online, clearly and prominently, before the contract is concluded with the consumer.
Similarly, the merchant will be required to indicate the duration of the warranty of good working order in an obvious manner and near the price of the goods sold or leased, and must also disclose this duration before concluding a distance contract with the consumer, as applicable, for the purchase or lease of the goods.
The information relating to this warranty must also be provided after the parties enter into a contract to purchase or lease the goods.
Disclosure obligations of merchants prior to selling additional warranties
If a merchant wishes to offer the consumer the option to purchase an additional warranty, it must first inform the consumer of the existence of the warranty of good working order applicable to the new goods mentioned above. To do so, unless an exception applies and in accordance with the provisions of the CPA and the RCPA, the merchant must provide the consumer with a document that exclusively contains the mandatory notice provided for in the RCPA. This notice aims to inform the consumer of their rights related to the legal warranties offered by the CPA, including the warranty of good working order, and to specify the duration of the warranty of good working order applicable to the good in question. In certain cases, the merchant must also verbally inform the consumer of specific information contained in the mandatory notice. The merchant’s obligations to inform the consumer about other applicable warranties, as well as the period for rescinding such a contract, continue to apply.
If the merchant fails to comply with the disclosure obligations regarding the warranty of good working order, the consumer may, during the first year of the contract, cancel the additional warranty contract without fees or penalties, and all amounts collected by the merchant under the contract must be returned to the consumer without delay. Additionally, failure to disclose information required by the CPA constitutes a prohibited practice and may give rise to compensatory and punitive damages.
Conclusion
Merchants and manufacturers that sell or lease the goods mentioned above should begin preparing now for the new requirements coming into force on October 5, 2026. Implementing this warranty and the resulting obligations could entail significant costs for your business, notably in terms of resources, administrative expenses, and logistics. We recommend early preparation to manage the operational impact of these changes and to reduce the risks of non-compliance and the associated costs.
For any questions regarding these requirements or your legal obligations as a merchant or manufacturer, do not hesitate to contact us.
The information contained in this website is provided for informational purposes only, and should not be construed as legal advice on any matter. The full disclaimer is available here.