Motor Vehicle Exemption Labelling Changes

Summary#

The final rule, Regulations Amending the Motor Vehicle Safety Regulations (Vehicle Exemptions) — SOR/2023-222, updates how exemptions from Canada’s vehicle safety rules are identified on cars and other vehicles. It shortens what must appear on the permanent compliance label and gives manufacturers more flexible options for the temporary (window) label. The changes took effect when published on November 8, 2023.

What it does#

• Changes the permanent compliance or information label requirement so it only needs to show the words "Exemption/Dispense [identifier]" (an alphanumeric code for the exemption).
• Makes the Minister, rather than the Governor in Council, the authority who issues vehicle exemption orders (to match recent changes to the Motor Vehicle Safety Act).
• Removes the old exemption route based on substantial financial hardship (repeals subsection 13(2) of the Motor Vehicle Safety Regulations).
• Updates the wording that describes valid reasons for exemptions to align with the Motor Vehicle Safety Act (applications related to new or equivalent safety features, or new types of vehicles, technologies, systems or components).
• Keeps a requirement that each exempted vehicle model carry a label describing the exemption, but:
  • requires that label to identify the vehicle features and the exemptions, and show the exemption short title and identifier; and
  • allows the temporary label to be placed on any readily accessible external surface readable from outside the vehicle if there is no windshield or side window (for example, for motorcycles).

Who's affected#

• Companies that make, import or distribute motor vehicles in Canada — manufacturers, importers and distributors.
• An estimated 1,400 stakeholders in Canada are likely to notice the change.
• Vehicle owners, buyers and others who may want to know which safety standards an exempted vehicle does not meet.
• Small businesses are not expected to be affected in practice (historically they have not requested exemptions).

Why it matters#

• It makes it easier for manufacturers to fit exemption information on small compliance labels and to place temporary labels on vehicles that lack windshields or side windows.
• It reduces a potential barrier to testing and deploying new vehicle technologies by simplifying exemption labelling and aligning the regulations with the updated exemption process in the Motor Vehicle Safety Act.
• Consumers and other interested people will still be able to find full details of any exemption because the Minister publishes exemption orders; the label will provide a compact identifier that points to that published information.