Québec consumer protection reforms: Five changes businesses need to know

Québec has recently enacted a series of significant consumer protection reforms that will affect how businesses design, market, sell and support products and services in the province. From right-to-repair obligations and mandatory product warranties to “click-to-cancel” requirements and restrictions on AI-generated endorsements, the changes reflect a clear regulatory shift toward greater product durability, transparency and consumer empowerment.

Importantly, the changes introduce a number of practical considerations. Businesses may need to update their product information, advertising, e-commerce interfaces, warranty procedures and after-sales support.

In this article, we highlight five developments that every organization doing business in Québec should watch out for. The table below summarizes the key reforms, implementation dates and practical compliance considerations for businesses operating in Québec.

Québec “click-to-cancel” and promotional pricing rules for online subscriptions (Bill 10)

Bill 10, An Act to protect consumers against abusive practices in ticket reselling and online subscription renewal targets recurring subscription models and introduces new consumer cancellation rights. Effective September 12, 2026, businesses offering eligible online subscriptions must provide consumers with a simple and easily accessible online cancellation mechanism, effectively creating a “click-to-cancel” regime.

The legislation also targets subscription practices that may catch consumers by surprise. Businesses must provide written notice to the consumer between two and ten days before the end of any free trial, introductory offer or discounted period if the contract will automatically continue at a higher price.

In addition, businesses advertising recurring fees for services sold online must clearly disclose any non-recurring charges required to obtain the service, such as activation, setup or similar one-time fees. These charges must be displayed prominently alongside the advertised instalment or subscription price.

Businesses offering subscription-based products and services should review their customer journey, cancellation flows, renewal notices and pricing disclosures to ensure they comply with the new requirements.

Right to repair requirements under Bill 29

On October 5, 2023, Québec assented to Bill 29, An Act to protect consumers from planned obsolescence and to promote the durability, repairability and maintenance of goods. The legislation introduced several amendments to Québec’s Consumer Protection Act aimed at:

• prohibiting planned obsolescence;
• significantly enhancing the legal warranty of good working order; and
• giving consumers a right to repair goods that are of a nature that requires maintenance.

Since October 5, 2023, merchants and manufacturers are required to guarantee, for a reasonable period after the transaction, the availability of replacement parts, repair services and information necessary to maintain or repair goods that are of a nature that requires maintenance. In practical terms, this effectively allows consumers to repair their goods themselves, provided they have access to the necessary parts, tools and information.

This includes, where applicable, diagnostic software and its updates. A merchant or manufacturer may be released from this obligation by providing written notice to the consumer before the contract is entered into; however, Bill 29 also provides that a regulation may determine the replacement parts and repair information in respect of which no merchant or manufacturer may be released from their repairability-related obligations.

At present, the regulations remain silent on this point, so there is currently no absolute requirement that merchants and manufacturers must make certain replacement parts available; however, this remains subject to change if legislators decide to carve out the replacement parts and information which cannot be excluded by disclosure.

Important details are set out in the Regulation to amend the Regulation respecting the application of the Consumer Protection Act (the “Regulation”), including requirements relating to the use of commonly available tools for installing replacement parts and the disclosures required where a business seeks to opt out of the right-to-repair guarantee regime.

For further details, see our earlier publications on this subject:

• Draft Regulations Clarify Warranty and Repair Obligations Under Québec’s Bill 29 on Planned Obsolescence
• Québec Releases Final Regulations on Repair and Replacement Obligations Under the Consumer Protection Act.

New warranty of good working order: covered products and warranty periods (Bill 29)

Bill 29 also introduced a legal warranty of good working order for a finite list of household appliances and electronic devices. The warranty will apply to covered goods purchased or leased new from a merchant as of October 5, 2026.

Importantly, the warranty period is not the same for every product. It will apply for:

• 6 years to stoves, refrigerators, freezers, air conditioners and heat pumps;
• 5 years to washing machines, dryers and dishwashers;
• 4 years to televisions; and
• 3 years to laptop and desktop computers, video game consoles, cellphones and tablets.

The warranty applies automatically and free of charge to such products, with the timer beginning on the date the product is delivered to the consumer. If the product malfunctions during the applicable period, the merchant or manufacturer must arrange and pay for the repair, including reasonable transportation or shipping costs associated with performing the warranty. Merchants and manufacturers are unable to opt-out of this warranty.

Importantly, merchants will also be required to indicate the applicable warranty period prominently near the advertised price. Manufacturers must disclose the duration online in a prominent and comprehensible manner. Before proposing an additional warranty, merchants must provide the specifically prescribed paper notice to consumers and inform them of the existence and duration of the applicable legal warranty.

Businesses selling covered products should embark on a thorough review and updating of product pages, shelf labels, advertising, extended-warranty materials and internal claims procedures before October 5, 2026.

For additional background, see Publication of Draft Bill 29 Regulations Setting Out Prescribed Durations of Warranties for Specific Categories of Goods.

AI-generated endorsements and deepfakes (Bill 24)

As businesses increasingly incorporate generative AI into marketing and advertising, Québec has introduced new protections aimed at preventing misleading uses of a person's identity or likeness. Bill 24, An Act to protect consumers against the misleading or fraudulent use of a person’s identity or image, which came into force on June 12, 2026, prohibits the use of a person's identity or image, without their consent, to make representations to consumers.

The prohibition is broad. It extends beyond traditional photographs and endorsements to include modified images, lookalikes, synthetic content and audio or video recordings that appear to depict a real person. As a result, AI-generated images, audio, or video portraying a celebrity, influencer or other individual as endorsing a product or service without their consent could contravene the legislation.

The new rules are not limited to AI-generated content, and the drafting is general enough to potentially create an avenue for complaints to the regulator in instances where an endorsement by an individual is implied without their consent, even where no generative AI is involved. However, given that the stated intention of the legislators was to address new risks arising from deepfakes and synthetic media in commercial advertising, it will be interesting to see how and if the regulator intends to address misleading endorsements not involving AI.

New restrictions on energy drinks in Québec (Bill 9)

Bill 9, An Act to prevent the harmful effects of energy drinks on the health of young people, is another example of Québec's increasingly interventionist approach to consumer protection, this time focusing on youth. Effective December 11, 2026, businesses will generally be prohibited from selling energy drinks to individuals under 16 years of age, as well as to anyone purchasing the product on behalf of a person under 16.

For the purposes of Bill 9, an energy drink is generally defined as a beverage containing at least 150 milligrams of caffeine per litre, together with certain other ingredients, such as taurine, vitamins or minerals. Coffee, tea and certain natural health products are generally excluded from the definition of an "energy drink." However, the government retains the ability to prescribe additional exclusions by regulation, meaning the scope of the legislation may evolve over time.

Bill 9 also contemplates future restrictions on online sales, vending-machine sales and other transactions where a seller is not physically present to verify the purchaser's age. Those restrictions will not come into force until the government adopts regulations setting out the permitted sales methods, age-verification requirements and any applicable exceptions.

Businesses involved in the manufacture, distribution or retail sale of energy drinks should begin assessing whether changes to age-verification procedures, point-of-sale systems, employee training and e-commerce platforms will be required ahead of the legislation's implementation.

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Taken together, these reforms reflect Québec's continued expansion of its consumer protection framework. From right-to-repair obligations and mandatory warranties to subscription cancellations, AI-generated advertising and energy drink restrictions, businesses face growing expectations around transparency, durability and consumer choice. Organizations operating in Québec should assess now whether their disclosures, marketing practices, customer journeys, warranty programs and after-sales support processes are ready for the new regulatory landscape.

McCarthy Tétrault’s regulatory team is here to help your business in navigating this evolving regulatory landscape, ensuring that your practices are compliant with applicable laws and industry requirements, and providing strategic guidance on engaging with regulators.

To learn more about how we can support you, please contact Véronique Wattiez Larose, Evie Bouras, Vino Wijeyasuriyar, or Elizabeth Yu,

Sources and Further Reading

• Bill 29, S.Q. 2023, c. 21
• Québec Releases Final Regulations on Repair and Replacement Obligations Under the Consumer Protection Act
• Draft Regulations Clarify Warranty and Repair Obligations Under Québec’s Bill 29 on Planned Obsolescence
• Publication of Draft Bill 29 Regulations Setting Out Prescribed Durations of Warranties for Specific Categories of Goods
• Bill 10, S.Q. 2026, c. 16
• Bill 24, S.Q. 2026, c. 20
• Bill 9, S.Q. 2026, c. 11