On April 15, 2016, the Ontario Ministry of Government and Consumer Services announced that Ontario Energy Group and its Director have been charged with over 100 offences under the Consumer Protection Act (CPA). Ontario Energy Group supplies (sells or leases) water heaters and HVAC equipment through door-to-door sales. The charges relate to false and misleading practices, failure to provide valid contracts in accordance with the CPA, and failure to deliver refunds as required by the CPA. The charges could result in substantial fines, and up to two years in prison.

The fact that the Ministry of Government and Consumer Services widely publicized these charges may signal a commitment to more strongly enforcing the prescriptive requirements for door-to-door sales (“direct agreements”) that are set out in the CPA. As we have previously described, recent legislative changes have outlawed door-to-door sales of electricity contracts (see here) and have added onerous new requirements for door-to-door water heater contracts (see here). Recent news stories (see here and here) indicate that councillors in Mississauga and Markham are pushing the province to ban a wider range of door-to-door sales. In all of these circumstances, it will be interesting to see whether efforts to further regulate or police door-to-door sales (which often involve energy services products) are ramped up in the coming months and years.