Summary#
Bill 91, the Right to Repair Act, 2025, would amend Ontario’s Consumer Protection Act, 2023 by adding a new Part V.1. Its stated goal is to make repair more affordable and accessible and reduce waste; those are goals, not guaranteed results.
- Suppliers, including manufacturers, would have to provide consumers or repair businesses with repair information, parts and tools they use or provide to others, on request. Covered products are certain electronics, household appliances, agricultural equipment, motor vehicles, motorized mobility aids and recreational motorized vehicles.
- Suppliers would generally have up to 30 days to provide the items and would have to retain them for at least seven years after the product model or type was last made. Access to documentation would be free, though suppliers could charge limited fees for printed documents, parts, software and tools. Embedded software updates would be free.
- Suppliers could not use parts-pairing mechanisms to block or reduce a product’s function, create certain false or misleading repair warnings, raise future repair prices, or limit who can buy parts or repair products. They could not void a warranty solely because a consumer or repair business did the repair or used unauthorized parts.
- For motor vehicles, recreational motorized vehicles and motorized mobility aids, suppliers would have to provide requested repair data as soon as possible and retain that data for at least 10 years after the model or type was last made.
- A consumer could ask for a no-cost replacement or refund if a supplier refuses or cannot meet the repair requirements. The bill also creates court remedies and a separate process for courts to declare some seriously defective motor vehicles eligible for repurchase, replacement or lease termination.
- The rules would apply only to products first manufactured and supplied on or after the Act takes effect. The Act would start one year after the later of two dates: when section 2 of the Consumer Protection Act, 2023 takes effect, or when this bill receives Royal Assent.
What it means for you#
- Consumers: If you meet the bill’s definition of consumer and have a covered product, you could request repair materials from its supplier. Some products are excluded, including medical devices, industrial and construction equipment, airplanes and marine vessels. The bill does not cover products first manufactured or supplied before it takes effect.
- Repair businesses: You could request the same repair materials, subject to the bill’s limits. For certain security locks, the supplier would need the owner’s written permission before giving a repair business the materials to access and reset the lock.
- Motor vehicle owners and long-term lessees: A court could declare a vehicle seriously defective if the bill’s repair-attempt, timing, mileage and usefulness tests are met. For a purchased or financed vehicle, the court could order repurchase with a mileage adjustment or a comparable or better replacement. For a leased vehicle, it could end the lease without penalty. A vehicle later offered for sale or long-term lease would have to disclose the declaration and display a label.
- Suppliers and manufacturers: They would have to meet the supply, retention, data and parts-pairing rules. A consumer could sue for non-compliance; a court could order compliance or damages, including damages for an affected repair business.
- People who later acquire a covered product: They would generally be treated as consumers under the bill, except if they acquire it for resale or predominantly for business use.
Money#
No cost information is in the available material.
- Suppliers could charge for parts, embedded software and tools only under conditions set out in the bill; they could charge only a reasonable estimated printing cost for paper documentation.
- Suppliers would have to provide access to documentation at no charge and provide embedded software updates free.
- The bill would require suppliers to retain repair materials and certain product data, but gives no estimate of those costs or of any public administration or court costs.
What is unclear#
- The supplied material does not include the current Consumer Protection Act, 2023, so I could not verify what consumer protections, remedies or enforcement powers already exist or how the new Part would interact with them.
- The bill does not set out a request form, a dispute process, an appeal process, or reporting requirements. It says items must be provided within a “reasonable time,” capped at 30 days, but does not define “reasonable.”
- The bill does not explain how its refund-or-replacement remedy would work alongside the exceptions and limits on required parts and information.
- The rules depend on terms such as “reasonable” fees and “substantial” restrictions that the bill does not define.
- The bill does not specify the staffing, funding or oversight needed to administer the new rules.
Case for#
- The bill appears intended to address consumers’ lack of access to repair information, parts and tools, which can limit their repair choices.
- Requiring suppliers to provide materials they already use or provide to others could give consumers and independent repair businesses a way to repair products without relying only on the supplier.
- Limits on parts pairing and warranty cancellation could prevent some repair barriers, while still allowing fees under stated conditions.
- The bill’s specific remedies for seriously defective vehicles could give eligible consumers a court-ordered solution after repeated repair failures.
Case against#
- The duties to provide materials and retain them could impose costs on suppliers; the bill provides no cost estimate or funding plan.
- The bill’s broad disclosure requirements could raise concerns about confidential business information, even though it limits disclosure to what is necessary for repair.
- The bill does not clearly set out how disputes over requests, fees or compliance would be resolved before a court action.
- Coverage is limited by product type and by when a product was made and supplied, so owners of older products or excluded products would not receive these new rights.