Banks Avocats Newsletter

Hi there,

One question is dominating business conversations this week: what do you actually do about the 50% US tariffs that took effect Wednesday, August 19? We’ve got the full picture, plus two Quebec files worth your attention while everyone stares south: the enterprise registry striking off non-compliant companies, and a new legal warranty that will land on your price tags October 5. Five minutes, coffee in hand.

Quebec

1. 50% tariffs took effect August 19 — here’s how to tap Quebec’s response now

As of Wednesday, August 19, Section 338 tariffs jumped to 50% on a wide range of Canadian goods — baking mixes, electronics, plywood, clothing, manufactured and industrial products. Here’s the twist: CUSMA compliance no longer shields you. Goods that used to qualify for duty-free treatment under the trade deal are fully exposed under this measure. (Energy, potash, fish, critical minerals, and steel/aluminum are carved out, already covered by other tariffs.) This stacks on top of the 10% tariffs imposed July 24 over alleged forced labour in supply chains. Quebec has rolled out several levers in response: Panorama for export market diversification, Chantier productivité (ESSOR) for productivity-boosting investments, up to $20M for workforce training in affected sectors, and a 25% penalty on US bidders without a Quebec establishment in public procurement.

Do this week: Run the quick test — are your products on the 50% tariff list? If yes, call Investissement Québec (1-844-474-6367) for a program pre-qualification, and have your lawyer review your export contracts for tariff-liability and force majeure clauses.

2. The enterprise registry has started striking off companies — and it’s not an idle threat

Since June 2026, the Registraire des entreprises du Québec (REQ) has been actively deregistering companies that still haven’t declared their ultimate beneficiaries — an obligation in force since 2023. Deregistration means losing your Quebec business number (NEQ), being unable to file any declaration, and paying administrative fees just to get reinstated — on top of banking headaches and disqualification from public contracts. One detail that trips people up: only the owner or an authorized administrator can file the declaration. Your accountant can’t do it for you.

Do this week: Log into ClicSÉQUR and confirm your ultimate beneficiary declaration (full name, address, ownership percentage, date of birth) is current. Don’t assume “someone else is handling it.”

3. New legal warranty on appliances and used vehicles — starting October 5

The countdown is on: starting October 5, 2026, a new “warranty of proper functioning” is being added to Quebec’s Consumer Protection Act to fight planned obsolescence. Manufacturers and merchants will have to guarantee a minimum functional lifespan for new appliances and electronics — up to 6 years for stoves, fridges, freezers, and heat pumps, 5 years for dishwashers and washer-dryers, 4 years for TVs, 3 years for computers, tablets, phones, and game consoles — plus a proportional warranty on used vehicles and motorcycles based on mileage and age. The warranty follows the good: it also covers subsequent buyers, not just the original purchaser.

Do this week: If you sell, lease, or manufacture these product categories in Quebec, review your warranty terms, price displays, and sales forms before October 5. Warranty length has to be disclosed “clearly and plainly,” and a separate written notice will be required before selling an extended warranty.

Rest of Canada

4. New federal foreign-influence registry — fines up to $1 million

Since August 4, 2026, the Foreign Influence Transparency and Accountability Act is in force, with a new public registry. Any business or individual entering an arrangement with a “foreign principal” — a foreign state, state-owned entity, sovereign wealth fund, state media, state energy company, or anyone acting on their behalf — must register within 14 days if the arrangement is meant to influence a government process (communicating with officials, spreading political content, transferring money or benefits). A 60-day grace period applies to arrangements struck before August 4. Administrative fines run $250 to $1 million, with criminal penalties up to $5 million (or $200,000 on summary conviction) plus possible imprisonment.

Why it matters: If your business has investors, partners, or clients tied to a foreign government — even indirectly — get your arrangements reviewed before the grace period runs out.

International

5. The 50% US tariffs took effect August 19 — with no CUSMA exemption

This is THE international story of the week, and it lands squarely on Quebec: Washington imposed 50% “Section 338” tariffs on a broad range of Canadian goods starting August 19, citing what it calls discriminatory treatment of US dairy, alcohol, and auto exports. The notable part: goods that normally qualify for CUSMA protection get no exemption under this measure. It stacks on top of the 10% “Section 301” tariffs imposed July 24 over alleged forced labour in supply chains.

Why it matters: Check your export contracts — who eats the tariff, you or your customer? A well-drafted adjustment or force majeure clause could matter a lot in the coming weeks. (See brief #1 for the Quebec-side support available.)

Business for sale? (Or shopping for one?)

The best deals are prepared months in advance — and a clean corporate file (ultimate beneficiaries included — see brief #2!) is worth its weight in gold at the negotiating table. Write to us in full confidence at contact@banksavocats.com to start the conversation.

About the author

Jade Banks is a lawyer and the founder of Banks Avocats. She advises entrepreneurs and executives in Quebec and across Canada on business law: incorporations, buying and selling businesses, commercial contracts, and compliance (Law 25, the Charter of the French Language). Her approach: plain language, practical advice, and real attention to your business goals. She and her team write this newsletter every Wednesday.

Banks Avocats