Ontario Publishes Documentation Requirements For Exempt HVAC Door-To-Door Transactions

Recently, we wrote about new provisions of the Ontario Consumer Protection Act (CPA) that will prohibit a range of door-to door consumer transactions. The new rules, which come into effect on March 1, 2018, will make unsolicited "direct agreements" unenforceable for HVAC equipment and other items such as water heaters, air cleaners and water treatment equipment ("prescribed goods and services"). There are some exceptions to the overall ban on direct agreements for prescribed goods and services. Generally, if the consumer initiates contact with the supplier and asks the supplier to come to the consumer's home, then the supplier is permitted to solicit and/or complete a direct agreement for prescribed goods and services at the consumer's home. Such transactions are exempt from the general prohibition against direct agreements for prescribed goods and services.