This bill adds a new Part V.1 to the Consumer Protection Act, 2023 to establish a statutory ‘‘right to repair’’ for a range of products: electronic products, household appliances, agricultural equipment, motor vehicles, motorized mobility aids and recreational motorized vehicles manufactured after the act comes into force. Suppliers (including manufacturers) must provide, on request, the documentation, parts, tools and software necessary to diagnose, maintain and repair covered products; they must also make vehicle and mobility aid data available to consumers or repair businesses.
The measure aims to reduce waste, lower repair costs and support independent repair businesses by removing supplier practices that lock repairs to authorized channels. The bill creates detailed rules on availability, timing, cost allocation, confidentiality, and limits (for example, medical devices and certain industrial equipment are excluded), plus remedies ranging from replacement or refund to court-ordered compliance and damages.
At a Glance
What It Does
The bill requires suppliers to provide, on request, the documentation, parts, tools and embedded‑software updates needed to diagnose, maintain or repair covered products, and to make product data available for motor vehicles, mobility aids and recreational motorized vehicles. It prohibits software pairing or mechanisms that prevent otherwise functional replacement parts from working and preserves warranty coverage for third‑party repairs.
Who It Affects
Manufacturers and suppliers of covered products, independent repair businesses, dealerships and service networks, and Ontario consumers who purchase or lease the specified product categories. It also affects fleet operators, farmers and owners of motorized mobility aids who rely on third‑party repair access.
Why It Matters
The bill shifts market leverage toward consumers and independent repairers by limiting manufacturers’ ability to lock parts, tools and software behind proprietary barriers. That will change product support practices, inventory and documentation retention requirements, software distribution processes, and may raise compliance and IP management costs for suppliers.
More articles like this one.
A weekly email with all the latest developments on this topic.
What This Bill Actually Does
The Right to Repair Act creates a permission structure: an Ontario consumer or an independent repair business can request from the supplier the exact items the supplier uses for diagnosis, maintenance or repair. Those items include service manuals, wiring diagrams, training materials, part numbers, replacement parts (new or used), calibration tools and the software or utilities that provision, pair or calibrate components.
For motor vehicles, recreational motorized vehicles and motorized mobility aids the supplier must, on request, also provide access to product data to facilitate repairs.
Timing and availability are explicit operational obligations. Suppliers must provide requested items within a reasonable time and no later than 30 days; they must retain the materials for a minimum period after production stops (the bill sets a baseline retention period) so repair options don’t evaporate as models age.
The bill sets cost rules: documentation is free when provided electronically (paper copies may carry a cost limited to printing), suppliers may charge for parts, tools and software subject to rules that prevent discriminatory or bundled pricing, and embedded‑software updates to fix bugs must be provided at no charge.The bill bars technical workarounds that frustrate repair: manufacturers may not use pairing or unique identifiers to prevent functional replacement parts from being installed or to degrade functionality when a non‑approved part is present; they may not use deceptive warnings about parts or repairs. Where a digital lock must be deactivated for repair, suppliers must provide, on reasonable terms, the special documentation or tools needed — but a repair business may need written permission from the product owner to receive lock‑reset items.Enforcement sits with consumers in the first instance: a consumer who is refused or where the supplier cannot comply may request a replacement or refund and may sue.
Courts can order compliance, award damages to consumers or affected repair businesses, and in the vehicle context can declare a motor vehicle ‘‘seriously defective’’ and order repurchase, replacement, or lease termination if statutory thresholds are met. The Act also protects successor owners (except buyers who acquire products for resale or predominant business use) and preserves suppliers’ protection for legitimately confidential business information and security‑sensitive measures.
The Five Things You Need to Know
Suppliers must deliver requested repair documentation, parts, tools or software within a maximum of 30 days after a consumer or repair business requests them.
Suppliers must retain repair materials (documentation, parts list, tools) for at least seven years after production of a product model or type stops.
For motor vehicles, recreational motorized vehicles and motorized mobility aids, suppliers must provide access to product data on request and retain repair data for at least 10 years after production ends.
The bill forbids software pairing or other mechanisms that prevent otherwise functional replacement parts from operating, and it prohibits suppliers from charging for embedded‑software updates whose purpose is to fix bugs.
If a supplier refuses or cannot comply, a consumer may demand a free replacement or a refund and may sue; for motor vehicles a court can declare a vehicle ‘‘seriously defective’’ and order repurchase or replacement when statutory repair‑attempt thresholds are met.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Key definitions that set the boundaries
This section defines the terms that control scope and obligations—‘supplier’ (including manufacturers), ‘consumer’ (Ontario resident with specific purchase/lease rules), ‘‘Part V.1 product’’ categories, ‘embedded software’, ‘repair business’ and types of covered goods (e.g., agricultural equipment, motorized mobility aids). Two practical consequences: (1) suppliers are broadly captured because branding or manufacture qualifies, and (2) the definition of consumer ties protections to Ontario residents and to where the product was purchased or leased, shaping cross‑border and secondary‑market claims.
Scope, applicability date and explicit exclusions
The Part applies only to products first manufactured and supplied on or after the bill’s commencement, so legacy inventories and older models generally fall outside its reach. It carves out product classes—medical devices, heavy industrial/mining/construction equipment, public utility‑installed systems, marine vessels and aircraft, emergency communications gear, certain ISP‑distributed set‑top or modem devices and life‑safety systems—where repair access raises distinct safety, regulatory or service considerations. Those exclusions narrow compliance obligations and signal the legislature’s safety and operational priorities.
Substantive right to repair: what suppliers must provide
This is the operational core: suppliers must provide any documentation, parts or tools they use for diagnosis, maintenance or repair (explicitly listing manuals, schematics, part numbers, boardviews, security codes, training material, and the software/tools that provision or calibrate parts). Documentation must be provided free electronically (printing costs may be charged), parts and tools can be charged for but only under non‑discriminatory terms, and embedded‑software updates to correct bugs must be free. The section allows suppliers to require confidentiality agreements where disclosure would reveal genuine confidential business information.
Technical controls, digital locks and vehicle data
The bill prohibits suppliers from using software pairing or other mechanisms to prevent a functional replacement part from operating, to degrade part performance, to present misleading alerts, to impose future repair surcharges, or to restrict who can buy parts or repair. Where a lock must be deactivated to repair, suppliers must provide the necessary documentation or tools on reasonable terms (repair businesses need owner permission for lock‑reset items). For motor vehicles and similar products, suppliers must provide repair data on request and retain repair data for at least 10 years, creating a long‑term record useful to owners and independent shops.
Remedies when suppliers fail to comply
If a supplier refuses or cannot comply, the consumer may demand that the supplier replace the product at no cost or refund the purchase/lease price. Consumers may sue; courts can order compliance, award damages to consumers or affected repair businesses and impose other remedies. The section removes privity as a defense and protects consumers from costs for bringing or defending actions unless claims are frivolous, lowering the barrier to enforcement.
Seriously defective motor vehicles regime
This section creates a vehicle‑specific path for relief: a ‘‘seriously defective’’ designation is available where prescribed repair‑attempt thresholds are met (multiple unsuccessful warranty repairs within a defined time/odometer window or repeated unrelated defects) and the defect substantially impairs use or safety. Courts can order repurchase, replacement or lease termination; declared vehicles must carry labels and disclosure, affecting resale markets and dealer obligations.
Limitations: confidentiality, damage liability and unavailable parts
The bill balances access with limits: suppliers need not disclose confidential business information beyond what’s necessary for repair; they aren’t liable for repair damage unless the damage stems from a design or manufacturing defect; they aren’t required to provide items that would disable owner security without owner permission; they need not provide parts that are no longer available; and suppliers remain barred from supplying service materials whose use is illegal. These carve‑outs contain the scope of practical obligations.
This bill is one of many.
Codify tracks hundreds of bills on this topic across all five countries.
Explore this topic in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Independent repair businesses — gain statutory access to the same manuals, diagnostic tools, parts lists and software suppliers use, enabling more repairs locally and reducing dependence on manufacturer authorizations.
- Rural and small‑community consumers, farmers and owners of mobility aids — improved local repairability where OEM dealerships are sparse and faster, lower‑cost repairs reduce downtime and operating costs for essential equipment.
- Owners and subsequent private buyers — access to repair data and preserved warranty rules (the bill prevents voiding warranties solely for third‑party repairs) increases product longevity and resale transparency, especially for motor vehicles declared seriously defective.
Who Bears the Cost
- Manufacturers and suppliers — must maintain and distribute documentation, inventory parts and provide software/tools under controlled but accessible terms; these obligations will require administrative, logistical and potential IT changes and could increase costs for product support.
- Authorized dealer and OEM service networks — face increased competition from independent repairers and may see reduced capture of post‑sale revenue from exclusive parts or service contracts.
- Provincial courts and enforcement bodies — expect new litigation and declaratory actions (e.g., ‘‘seriously defective’’ vehicle cases), producing potential resource pressures and the need to interpret technical compliance disputes and confidentiality claims.
Key Issues
The Core Tension
The central dilemma: the law forces open access to repair information and parts to benefit consumers, independent repairers and sustainability, but doing so risks exposing commercially sensitive information and creating security or safety vulnerabilities; the statute trades off manufacturers’ control over post‑sale functionality and IP protection against consumers’ ability to repair and reuse products, and the implementation choices to resolve that trade‑off are legally and technically messy.
The bill resolves some questions in favor of repair access but leaves hard implementation choices. ‘‘Reasonable time’’ is bounded by a 30‑day maximum, but what constitutes reasonable provision of specialized tools or cloud‑hosted diagnostic interfaces is unresolved—suppliers could interpret ‘‘provide’’ as remote access rather than physical issuance, raising latency and data‑sovereignty questions. The confidentiality carve‑out permits NDAs for genuinely secret information, but the statute does not set standards for what must be redacted versus disclosed, so suppliers and repairers will likely litigate the line between trade secrets and repair‑critical information.
Security and anti‑theft concerns create another practical tension. The bill requires suppliers to make lock‑reset items available on reasonable terms but conditions access for repair businesses on owner permission; that protects owners but can slow repairs for owners who cannot easily provide written consent (e.g., a farm hand repairing equipment remotely).
Similarly, the outright ban on pairing mechanisms closes one common OEM technique for enforcing parts exclusivity, but suppliers can respond with design changes (proprietary cloud‑based services, remote feature control, or legal licensing regimes) that achieve similar commercial effects while complying in form. Finally, enforcement will be fact‑intensive: courts must assess whether suppliers were ‘‘unable’’ to comply (parts shortages, supply‑chain disruptions) and whether fees are ‘‘reasonable’’ and non‑discriminatory, creating litigation risk and uncertainty for both sides.
There's more to this law than the bill.
Codify Laws traces every connection across the legislative lifecycle.