- with readers working within the Securities & Investment industries
- with Senior Company Executives, HR and Finance and Tax Executives
On September 3, 2025, a Draft Regulation (the "Draft Regulation") was published in the Gazette officielle du Québec1, with a view to reforming the Special Road Train Operating Permits Regulation (the "Regulation").2 If the Draft Regulation is adopted, a "satisfactory" safety rating will now be required in order to obtain a special permit for the operation of a road train.
As a reminder, a road train consists of a combination of road vehicles comprising a tractor, a semi-trailer, and one of the following vehicles: a dolly, a semi-trailer or a trailer. Large road trains are road trains that exceed the normally permitted dimensions and require a special permit to operate. In short, large road trains allow for the transport of large quantities of low-weight goods and look like this:
Québec regulates the operation of large road trains via the Regulation, administered by the Ministère des Transports et de la Mobilité durable (the "Ministère"). Even when a carrier is only transiting through the province, it must hold a valid permit.
The special operating permit applies to a single road train and not to an operator's entire fleet. The permit is required for at least one of the vehicles that make up the road train and is a separate formality from the registration of each vehicle and registration as a carrier. However, a single permit is sufficient for the entire road train. In other words, the operator can obtain a permit for a dolly, which allows them to use a Type A or C road train (as applicable) with any semi-trailers.
Current Steps for Obtaining a Permit
To obtain a special permit under the Regulation, the carrier must submit an online application to the Ministère, accompanied by the following information:3
- The carrier's contact information and required identification numbers (registration number in the register of owners and operators of heavy vehicles or proof of registration in another province or U.S. state);
- The contact information of the person responsible for the customer account;
- The licence plate or identification number of a vehicle of the road train;
- The desired period for which the permit is applied for.
Safety Rating: A Secondary Issue Until Now
As you probably already know if you have read this far, any carrier whose heavy vehicle is registered in Québec, and any American carrier wishing to operate a heavy vehicle in Québec, must register with the Commission des transports du Québec ("CTQ") to obtain a Register Identification Number ("RIN") in the Register of Owners and Operators of Heavy Vehicles (Registre des propriétaires et des exploitants de véhicules lourds or "RPEVL").4 The CTQ assigns each carrier a safety rating: "satisfactory", "conditional", or "unsatisfactory". For its part, the Société de l'assurance automobile du Québec (the "SAAQ") maintains a file on each carrier and monitors its conduct to ensure compliance with applicable laws and standards. The file reflects the carrier's compliance with the Heavy Vehicle Owner and Operator Assessment Policy5 and may be heavily impacted by violations of the Highway Safety Code, including those related to the operation of large road trains. The accumulation of events such as at-fault accidents, non-compliant inspections, and regulatory violations can eventually lead to the CTQ modifying the carrier's safety rating.
However, the Regulation in its current form does not take this rating into account in respect of granting or renewing a special permit for operating a road train. Officials have no discretion in this matter. In other words, a Ministère official who receives an application for a special permit from an operator with a RIN, but with an "unsatisfactory" safety rating, must issue the special permit.
Ongoing Regulatory Reform
The Draft Regulation aims to amend the Regulation and the Vehicle Load and Size Limits Regulation (" Regulation R-31"),6 with a view to harmonizing Québec regulations with two Memoranda of Understanding to which Québec is a signatory;7 simplifying the regulatory framework; incorporating new safety standards; and facilitating the application of applicable rules.
New Safety Requirements
The Draft Regulation introduces several technical standards relating to road trains into Regulation R-31, including:
- maximum trailer device setback;
- minimum wheelbase for semi-trailers;
- effective rear overhang;
- minimum axle spread in a tandem or tridem axle group;
- damper type pintle hook hitch with a secondary locking mechanism;
- maximum position of the fifth wheel.
In addition to these technical standards, the Draft Regulation introduces into the Regulation a provision mandating that obtaining or renewing a special permit will now be conditional on the CTQ issuing a "satisfactory" safety rating under the RPEVL (for Québec and US carriers), or on the carrier's holding a recognized safety fitness certificate.8Accordingly, the CTQ's assignment of a "conditional" or "unsatisfactory" rating to a carrier automatically results in the rejection of the application for a special road train operating permit.
Coming into force
The Draft Regulation was published in the Gazette officielle du Québec on September 3, 2025. As per the Regulations Act.9 the government has 45 days following this publication to enact it by order, which it had not yet done as of November 14, 2025. The Regulation will come into force 15 days after the publication of the order enacting it.10
Certain transitional provisions are enacted, in particular to allow the industry to adjust to the new requirements and standards set out in Regulation R-31, but none of these transitional measures address the new requirement relating to safety ratings.
Footnotes
1.Special Road Train Operating Permits Regulation, Draft Regulation No. 36 (presentation – September 3, 2025), Vol. 157 [Draft Regulation].
2. Special Road Train Operating Permits Regulation, CQLR, c. C-24.2, r. 36 [Regulation].
3. Draft Regulation, Section 4.
4. A carrier operating a heavy vehicle in Quebec that is registered in another Canadian province must be registered in that other province, and such registration is recognized by Quebec under a system of interprovincial agreements that is too complex to be discussed in a blog post.
5. Société de l'assurance automobile, Conduct Review Policy for Heavy Vehicle Owners and Operators, Bibliothèque et Archives nationales du Québec, https://saaq.gouv.qc.ca/blob/saaq/documents/publications/conduct-review-policy-hvoo.pdf, 2024.
6. Vehicle Load and Size Limits Regulation, CQLR, c. C-24.2, r. 31 [Regulation R-31].
7. These are the Federal-Provincial-Territorial Memorandum of Understanding on Interprovincial Weights and Dimensions and the Memorandum of Understanding on the Harmonization of Special Permit Conditions for Operation of Long Combination Vehicles in Eastern Canada: Ministère des Transports et de la Mobilité durable, Analyse d'impact réglementaire: Règlement réformant le Règlement sur les normes de charges et de dimensions applicables aux véhicules routiers et aux ensembles de véhicules routiers et le Règlement sur le permis spécial de circulation d'un train routier, February 2025.
8. Regulations, Sections 8 and 16.
9. RLRQ, c. R-18.1.
10. Regulation, Section 36.
To view the original article click here
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
