Robot warranty service in Canada: provincial law, right to repair, privacy and French

Short answer: A robot maker running warranty and repair service in Canada has to work within four sets of rules. Each applies in different situations. Provincial consumer law (BC's BPCPA, Ontario's Consumer Protection Act, 2002, Quebec's Consumer Protection Act) protects only individuals buying for personal, family or household use. A robot sold to a business is generally outside it, so for commercial robots the warranty is mostly a matter of contract and provincial sale of goods law. Home robots get the full consumer rules. The federal right-to-repair amendment (Bill C-244, in force since November 7, 2024) lets anyone, including a third-party repairer working for the owner, get around a software lock to diagnose, maintain or repair a product. It does not allow selling unlock services or unlock tools. Privacy law applies to commercial robots too. Camera footage, maps and logs that identify people are personal information under PIPEDA, BC's PIPA and Quebec's Law 25, including when they are sent back to the factory. Quebec's French-language rules cover labels, manuals, warranty certificates, software and standard-form contracts for anything sold there.

This page is for robot makers, especially makers based outside North America, setting up after-sales service in Canada. The contract side of warranty (when the clock starts, who pays for a no-fault-found visit, advance replacement) is covered clause by clause in robot warranty and RMA in North America. This page covers the lines the law draws around those contracts.

KeepRobots is a robot field service company in Vancouver, not a law firm. The rules below summarise official texts (federal and provincial statute databases, the Office of the Privacy Commissioner, the Office québécois de la langue française) checked on 2026-10-29 and listed at the end. Provincial rules differ, and we checked three provinces only: British Columbia, Ontario and Quebec. This is not legal advice. Have Canadian counsel review your warranty terms, labels and data handling.

Robot warranty service in Canada at a glance

1. Provincial consumer law: it is mostly about home robots

All three provinces define the protected buyer narrowly:

• British Columbia, Business Practices and Consumer Protection Act (BPCPA): a consumer transaction is a supply of goods or services to a consumer "for purposes that are primarily personal, family or household".
• Ontario, Consumer Protection Act, 2002: a consumer is "an individual acting for personal, family or household purposes and does not include a person who is acting for business purposes".
• Quebec, Consumer Protection Act: a consumer is a natural person, "except a merchant who obtains goods or services for the purposes of his business".

So cleaning, delivery and service robots sold to hotels, restaurants, property managers and warehouses are generally outside these Acts. Robot vacuums, lawn robots, companion robots, and humanoids or quadrupeds bought by individuals are inside them. The points that matter for repair:

Repair estimates

• BC has no general repair-estimate part for goods. BPCPA s.4 does list two relevant deceptive acts: telling a consumer that a service, part, replacement or repair is needed when it is not, and giving an estimate "materially less than the price subsequently determined" unless the consumer expressly agreed to the higher price before the work. Under s.5, the supplier carries the burden of proving it did not act deceptively.
• Ontario: CPA s.10 says a supplier that gives an estimate in a consumer agreement cannot charge more than 10 per cent above it. Part VI (repairs: estimates, estimate fees, a 90-day repair warranty) applies to "vehicles or other prescribed goods". In the regulation, O. Reg. 17/05, we found requirements for motor vehicles only. For a home robot, the 10 per cent rule in s.10 and the deemed "reasonably acceptable quality" warranty for services in s.9 are what apply.
• Ontario passed a new Consumer Protection Act, 2023. As of 2026-10-29, the official e-Laws page still says "This Act is not yet in force". It takes effect on a date to be proclaimed, and the 2002 Act remains the law.

Implied warranties you cannot write out of a consumer sale

• BC Sale of Goods Act s.18 implies that goods are fit for a purpose the buyer made known, of merchantable quality, and, specific to BC, "durable for a reasonable period of time". Under s.20, in a retail sale of new goods, a term that tries to exclude or reduce these conditions is void. A "retail sale" does not include a sale to a buyer using the goods primarily for business purposes, or to a corporation or commercial enterprise. For those sales, s.69 allows the implied terms to be excluded or varied by express agreement.
• Ontario CPA s.9: the Sale of Goods Act implied conditions apply to goods supplied under a consumer agreement, and any term that tries to negate or vary them is void.
• In practice: a consumer warranty card that says "this warranty replaces all other warranties" has no effect against a BC or Ontario consumer. In a B2B contract you can limit implied terms, but write it expressly and have the customer sign it.

Quebec: parts, repair services and repair information (since October 5, 2025)

Quebec's planned-obsolescence law (Bill 29, S.Q. 2023, c. 21) added sections 39 to 39.7 to the Consumer Protection Act, in force October 5, 2025. For goods sold to consumers:

• replacement parts, repair services and the information needed to maintain or repair the goods, "including, where applicable, any diagnostic software and its updates", must be available for a reasonable time after the sale;
• repair information must be available in French; parts must be installable with commonly available tools and without irreversible damage;
• parts and services must be offered at a reasonable price, and repair information provided on a technological medium must be free;
• a merchant or manufacturer can opt out by warning the consumer in writing before the contract that it does not supply them, unless a regulation removes that option.

If you plan to sell a home robot in Quebec, decide before launch how many years of parts you will stock, how repairers get service documents and diagnostic tools, and who writes the French versions.

2. Right to repair: third parties may get around software locks, but cannot sell unlocking

Two private member's bills received Royal Assent on November 7, 2024. Neither has a commencement clause, so both took effect that day (Interpretation Act s.5(2)):

• Bill C-244 (S.C. 2024, c. 26; diagnosis, maintenance and repair) added section 41.121 to the Copyright Act. Circumventing a technological protection measure (TPM) "for the sole purpose of maintaining or repairing a product, including any related diagnosing" no longer breaches s.41.1(1)(a), where the protected program forms part of the product. Subsection (2) says this also applies to a person who does it for another person, which covers a third-party repairer working for the owner. Subsection (3) removes the exception for anyone who also infringes copyright, for example by copying or distributing your firmware.
• Bill C-294 (S.C. 2024, c. 27; interoperability) rewrote s.41.12. Circumvention is now allowed to make a program, or a device in which it is embedded, interoperable with another program, device or component, and to obtain the information needed for that. That information may be shared for the same purpose. For interoperability, the Act already had exceptions for services and tools.

Where the line is: the repair exception switches off only the ban on the act of circumventing. The bans in s.41.1(1)(b), on offering services primarily for circumvention, and s.41.1(1)(c), on making, importing or selling circumvention tools, are not lifted for repair. Knowingly contravening s.41.1 for commercial purposes is an offence under s.42(3.1): up to C$1,000,000 or five years on indictment, up to C$25,000 on summary conviction. Our reading: getting around a lock while repairing a robot is allowed; selling an "unlock service" or an unlock tool is not.

What this means for a robot maker: in Canada a software lock no longer keeps third parties out of repair. A better plan is to decide how you authorise service providers and license diagnostic tools (see OEM authorized service provider networks), and to state in the warranty which kinds of opening or modification affect coverage. How far you can tie warranty coverage to using authorised repairers is a question for counsel, province by province. We do not cover it here.

3. Privacy: cameras, maps and logs sent home

Privacy law applies whether the robot is sold to a household or a business. Guests filmed by a service robot in a hotel corridor, a map a delivery robot builds inside a hospital, a live camera view opened during remote support: if a person can be identified, it is personal information.

Which law

• PIPEDA (federal) covers personal information collected, used or disclosed in the course of commercial activities. Alberta, BC and Quebec have private-sector laws the federal government has found "substantially similar". Collection and use inside those provinces generally falls under the provincial law instead. The Office of the Privacy Commissioner (OPC) adds: "When more than one law applies, you must comply with both."
• BC PIPA applies to every organization not covered by the federal Act. Section 34 requires "reasonable security arrangements". The consolidated text, current to 2026-10-27, has no mandatory breach notification; BC's privacy commissioner recommends reporting breaches anyway, as best practice.
• Quebec Law 25 (S.Q. 2021, c. 25) came into force in stages from 2022 to 2024. The highest authority in the business is the person in charge of protecting personal information, unless that role is delegated in writing, and the title and contact information go on the website (s.3.1). Confidentiality incidents that present a risk of serious injury must be reported promptly to the Commission d'accès à l'information (CAI) and to the people affected (s.3.5). Acquiring, developing or overhauling an information system that handles personal information requires a privacy impact assessment (PIA) (s.3.3). So does communicating personal information outside Quebec, which also needs a written agreement (s.17). The CAI also says technology products offered to the public must ship with the most privacy-protective settings by default.

What to do in after-sales

• Logs and footage sent to the factory: under PIPEDA Schedule 1, principle 4.1.3, you stay responsible for information you transfer to a third party for processing, and must use contractual or other means to protect it. The OPC's 2009 cross-border guidelines treat a transfer for processing as a "use", not a disclosure. They expect you to tell customers that their information may be processed in another country and may be accessed there by courts, law enforcement and national security authorities. For Quebec, do the PIA before the data leaves the province.
• Breaches: PIPEDA s.10.1 requires reporting to the Commissioner, and notifying the individual, as soon as feasible when a breach creates "a real risk of significant harm".
• Your field service partner: when the partner's technicians log in with your tools, copy logs or take photos, they handle personal information for you. The service agreement should say what they may access, how long they keep it, how they delete it and how fast they tell you about an incident.
• Cameras: we found no OPC guidance specific to robots. The OPC's 2008 guidance on overt video surveillance by businesses is written for fixed cameras: tell people, post signs, store recordings securely and destroy them when no longer needed. It is a reasonable model for robots. Switch off recording you do not need, blur where you can, and explain camera use in the manual.

4. Quebec French: labels, manuals, warranty certificates, software, contracts

These rules apply to any product sold in Quebec, home or commercial:

• Product and documents: according to the OQLF, information on a product, its packaging and the documents that come with it, including the user manual and the warranty certificate, must be in French. Other languages may appear too, but not more prominently than the French, and not on more favourable terms.
• Software: Charter of the French language s.52.1 requires all computer software, including operating systems, to be available in French unless no French version exists, with the French version available on terms no less favourable. Think robot touchscreens, companion apps and fleet dashboards.
• Trademarks (since June 1, 2025): a registered trademark may stay in another language, but generic or descriptive words in it must appear in French on the product or on a medium permanently attached to it. If a French version of the trademark is registered, that version must be used. Products made before June 1, 2025, with no French trademark filed by June 26, 2024, can be sold until June 1, 2027.
• Standard-form contracts (since June 1, 2023): a contract of adhesion, such as a standard service agreement or warranty terms, must be given in French first. The parties may be bound by another language only if the other party then expressly chooses it, and you cannot charge for the French version. Contracts with people or businesses outside Quebec are exempt.

Federally, ISED requires the regulatory notices in a radio device's manual in both English and French; see robot certification in Canada.

A compliance checklist before launch

Common mistakes

• Applying consumer rules to a commercial customer, or the reverse. A cleaning robot sold to a hotel runs on the contract. The same model sold to an individual runs on consumer law.
• Reusing a warranty card from another market. A clause excluding implied warranties has no effect against BC or Ontario consumers, and Quebec needs a French version.
• Remote support that opens the robot's camera at a customer site without telling the customer or agreeing on it in writing.
• English and Chinese only. In Quebec, labels, software and contracts need French. Adding it late often means reprinting labels and shipping a new software release.
• Assuming a software lock keeps third parties out. Since November 2024, getting around a lock to repair a product is lawful in Canada.

What KeepRobots can do

KeepRobots is a robot field service company in Vancouver, serving Canada and the United States in English and Mandarin. We can be your local after-sales point: on-site diagnosis and repair, preventive maintenance, deployment, and storage of spare parts and demo units. On the compliance side, we work to your warranty policy and estimate process: a written estimate first, and a stop for your and the customer's approval if a job will go over it. We put data access, retention, deletion and incident notice into the service agreement. Work-order records (serial numbers, fault codes, parts replaced, photos) come back to you for warranty and recall handling. We are not a law firm; take legal questions to Canadian counsel.

Current rates, before tax: diagnostic C$200 per robot, per visit in Canada (US$200 in the US), credited if you approve the repair; C$100 call-out in the Greater Vancouver core zone; on-site labour C$150/hour in Canada or US$150/hour in the US. Travel outside the core zone and for US projects is quoted per project. See robot after-sales and field service in Canada, the North America expansion guide and how to write a robot service SLA.

FAQ

Does Canadian consumer protection law cover robots sold to businesses?

Generally no. BC's Business Practices and Consumer Protection Act covers transactions for purposes that are primarily personal, family or household; Ontario's Consumer Protection Act, 2002 excludes people acting for business purposes; Quebec's Consumer Protection Act excludes merchants buying for their business. Warranty on a commercial robot is governed mainly by the contract and provincial sale of goods law. Home robots sold to individuals are covered.

Can a B2B robot warranty exclude implied warranties in Canada?

In British Columbia, yes. Sale of Goods Act s.20 voids exclusions only in retail sales of new goods, and a retail sale does not include a buyer using goods primarily for business purposes or a corporation; s.69 allows implied terms to be excluded or varied by express agreement. In consumer sales they cannot be excluded, and Ontario's Consumer Protection Act s.9 likewise voids such terms.

When did Bill C-244 take effect, and can third-party repairers bypass a robot's software lock?

Bill C-244 (S.C. 2024, c. 26) received Royal Assent on November 7, 2024 and, having no commencement clause, took effect that day. It added s.41.121 to the Copyright Act: circumventing a technological protection measure solely to maintain or repair a product, including diagnosis, does not breach s.41.1(1)(a), and this applies to someone doing it for another person. It does not lift the bans on offering circumvention services or selling circumvention tools, and it does not protect copyright infringement.

What privacy rules apply when robot logs and camera footage go back to the manufacturer?

If people can be identified, it is personal information. Under PIPEDA you remain responsible for information transferred to a third party for processing and must protect it by contract; the OPC's cross-border guidelines expect you to tell customers it may be processed abroad and accessed by foreign authorities. Quebec's Law 25 also requires a privacy impact assessment and a written agreement before personal information leaves Quebec.

What must be in French for a robot sold in Quebec?

According to the OQLF, information on the product, its packaging and accompanying documents, including the user manual and warranty certificate. Software, including operating systems, must be available in French if a French version exists (Charter s.52.1). Since June 1, 2025, generic or descriptive words in trademarks must appear in French on the product. Standard-form contracts must be offered in French first. Home robots also need French repair information under the Consumer Protection Act.

What can KeepRobots do for robot warranty service in Canada, and what does it cost?

On-site diagnosis and repair, preventive maintenance, deployment, and parts and demo-unit storage, in English and Mandarin, following your warranty policy and estimate process. Rates before tax: diagnostic C$200 per robot, per visit in Canada or US$200 in the US, credited if you approve the repair; C$100 call-out in the Greater Vancouver core zone; on-site labour C$150/hour in Canada or US$150/hour in the US; travel outside the core zone and for US projects quoted per project. We are not a law firm.

Sources (checked 2026-10-29)

• BC Business Practices and Consumer Protection Act, SBC 2004, c. 2, ss. 1, 3, 4, 5 (current to 2026-10-27): bclaws.gov.bc.ca
• BC Sale of Goods Act, RSBC 1996, c. 410, ss. 18, 20, 69: bclaws.gov.bc.ca
• Ontario Consumer Protection Act, 2002, ss. 1, 9, 10 and Part VI (e-Laws currency date 2026-10-26): ontario.ca/laws
• Ontario O. Reg. 17/05, Part VI (motor vehicle repairs): ontario.ca/laws
• Ontario Consumer Protection Act, 2023 (status: not yet in force): ontario.ca/laws
• Quebec Consumer Protection Act, CQLR c. P-40.1, ss. 1, 39–39.7: legisquebec.gouv.qc.ca
• Quebec S.Q. 2023, c. 21 (Bill 29), s. 37 coming-into-force: publicationsduquebec.gouv.qc.ca
• Copyright Act, R.S.C. 1985, c. C-42, ss. 41, 41.1, 41.12, 41.121, 42 (current to 2026-09-30): laws-lois.justice.gc.ca
• S.C. 2024, c. 26 (Bill C-244): laws-lois.justice.gc.ca; LEGISinfo: parl.ca
• S.C. 2024, c. 27 (Bill C-294): laws-lois.justice.gc.ca
• Interpretation Act, s. 5(2): laws-lois.justice.gc.ca
• PIPEDA, S.C. 2000, c. 5, ss. 2, 4, 10.1 and Schedule 1: laws-lois.justice.gc.ca
• OPC, Provincial laws that may apply instead of PIPEDA: priv.gc.ca
• OPC, Guidelines for processing personal data across borders (2009): priv.gc.ca
• OPC, Guidelines for overt video surveillance in the private sector (2008): priv.gc.ca
• BC Personal Information Protection Act, SBC 2003, c. 63, ss. 3, 34: bclaws.gov.bc.ca; OIPC BC, breach reporting: oipc.bc.ca
• Quebec S.Q. 2021, c. 25 (Law 25), enacting P-39.1 ss. 3.1, 3.3, 3.5, 17, and coming-into-force: publicationsduquebec.gouv.qc.ca; CAI summary: cai.gouv.qc.ca
• OQLF, trademarks and products: oqlf.gouv.qc.ca; contracts of adhesion: oqlf.gouv.qc.ca
• Quebec S.Q. 2022, c. 14 (Bill 96): publicationsduquebec.gouv.qc.ca; S.Q. 1997, c. 24 (Charter s. 52.1): publicationsduquebec.gouv.qc.ca

This page summarises public legal texts for orientation only, as of 2026-10-29. It is not legal advice. For Quebec's Law 25, Bill 96 and Charter s.52.1 we relied on the officially published annual statutes and CAI/OQLF guidance, because the consolidated LégisQuébec texts could not be opened that day. "The repair exception does not cover unlock services or tools" and "O. Reg. 17/05 prescribes motor vehicles only" are our readings of the texts. Only BC, Ontario and Quebec consumer law were checked. Rates are KeepRobots' current published rates, before tax, and may change.