Interprovincial direct-to-consumer alcohol sales allow a licensed Canadian producer to sell beverage alcohol directly to an individual consumer located in another province or territory and arrange delivery to that consumer’s home or other permitted address.

For example, a direct-to-consumer, or DTC, framework may allow:

an Ontario brewery to ship beer directly to a consumer in Nova Scotia;
a British Columbia winery to ship wine directly to a consumer in Alberta;
a Saskatchewan distillery to sell spirits directly to a consumer in Ontario; or
a Nova Scotia cidery to accept an online order from a consumer in Manitoba.

Historically, Canada’s provincial liquor monopolies, importation rules and separate provincial licensing systems made these transactions difficult or unlawful unless the product moved through the destination province’s liquor authority.

That system is changing rapidly.

Ontario and several other provinces have now entered into bilateral and multilateral arrangements intended to permit interprovincial DTC sales of Canadian beer, wine, cider, spirits, coolers and other alcoholic beverages. However, DTC does not mean that a producer may simply begin shipping anywhere in Canada. The producer may still require authorization in the destination province and may have to collect and remit provincial mark-ups, fees, taxes and other charges.

Are Interprovincial Alcohol Sales Legal in Canada?

Interprovincial DTC alcohol sales are legal only where the laws and administrative systems of both the producer’s home province and the consumer’s destination province permit the transaction.

A producer must generally determine:

whether its own manufacturer’s licence authorizes the sale;
whether the destination province participates in a DTC arrangement;
whether an out-of-province authorization or registration is required;
which products may be shipped;
whether cross-selling is permitted;
which provincial mark-ups, fees and taxes apply;
what sales reports must be filed;
whether minimum-pricing rules apply;
how the consumer’s age must be verified; and
which delivery requirements must be followed.

The existence of a political agreement or memorandum of understanding does not necessarily mean that every producer can immediately ship into every participating province. Implementing legislation, regulations, authorizations and administrative systems remain important.

Why Has Interprovincial Alcohol Trade Been So Restricted?

Canadian beverage alcohol regulation has traditionally been organized province by province.

Each province or territory generally controls:

who may manufacture alcohol;
who may import it into the jurisdiction;
who may sell it;
where and how it may be sold;
the role of the provincial liquor authority;
product registration or listing;
provincial mark-ups;
minimum prices;
taxes and environmental charges;
responsible-sale requirements; and
delivery to consumers.

This structure made it possible for a consumer to visit a winery in another province and personally transport a permitted quantity home while preventing that same winery from later shipping an online order directly to the consumer.

Federal restrictions under the Importation of Intoxicating Liquors Act also historically reinforced provincial control over interprovincial liquor movement. The federal government has since taken steps to remove federal restrictions, but provincial and territorial liquor laws remain central. Removing a federal barrier does not itself compel a province to authorize private DTC shipments. (Canada)

Ontario’s Bill 2 and the DTC Alcohol Framework

Ontario’s Bill 2, Protect Ontario Through Free Trade Within Canada Act, 2025, created the legislative foundation for Ontario to participate in interprovincial DTC alcohol arrangements.

The Ontario government described the legislation as part of a broader effort to reduce internal trade barriers. Its technical briefing expressly identified an interprovincial DTC model as a measure intended to let Ontario producers sell more easily to consumers in other provinces and let Ontario consumers purchase directly from out-of-province producers.

Bill 2 did not simply declare unrestricted alcohol shipping lawful. Instead, it amended Ontario’s liquor legislation so that the government, the LCBO and other participating jurisdictions could establish and administer a controlled framework.

Amendment to the Liquor Control Board of Ontario Act, 2019

Bill 2 amended the Liquor Control Board of Ontario Act, 2019 to require the LCBO, when directed by the Minister, to implement a framework facilitating the sale of liquor from a manufacturer in one Canadian province or territory to a consumer in another.

The LCBO must comply with ministerial directives respecting that framework.

This is significant because the LCBO traditionally controls the importation and wholesale distribution of liquor in Ontario. The amendment allows the LCBO to create an authorized channel through which an out-of-province producer may sell directly to an Ontario consumer without following the conventional product-listing and warehouse-distribution model.

The provision is enabling legislation. The operational rules still depend on ministerial direction, intergovernmental agreements and the administrative requirements imposed by the LCBO.

Amendment to the Liquor Licence and Control Act, 2019

Bill 2 also added section 77.1 to the Liquor Licence and Control Act, 2019.

The new provision supports agreements between Ontario’s Minister of Finance, or another member of Ontario’s Executive Council, and another Canadian jurisdiction to facilitate sales from a manufacturer in one province or territory to a consumer in another.

Subsection 78(1) was also amended to authorize regulations concerning:

implementation of those agreements; and
sales of liquor contemplated by those agreements.

Together, these amendments permit Ontario to negotiate reciprocal arrangements and establish the licensing, registration, pricing, reporting, delivery and enforcement rules needed to implement them.

The Ontario legislation should therefore be understood as creating the machinery for DTC—not as eliminating all regulation of interprovincial alcohol sales.

Ontario and Nova Scotia’s 2026 Bilateral Agreement

Ontario and Nova Scotia signed a bilateral DTC alcohol agreement on March 2, 2026.

The agreement allowed eligible Ontario and Nova Scotia manufacturers to obtain authorization to sell their products directly to consumers in the other province. It covered Canadian-made beverage alcohol rather than wine alone, including products made by breweries, wineries, cideries and distilleries. (Ontario Newsroom)

Before the agreement, Ontario consumers generally obtained alcohol from another province through one of the following methods:

purchasing a product listed by the LCBO;
using the LCBO’s Private Ordering Program; or
personally purchasing alcohol in another province and transporting it to Ontario for personal use.

The bilateral arrangement introduced an authorized online DTC channel. Eligible Nova Scotia producers could seek authorization to ship directly to Ontario consumers, and Ontario producers could obtain reciprocal access to Nova Scotia consumers.

The provinces also implemented a mark-up structure intended to preserve comparable provincial revenue treatment between DTC products and products sold through domestic channels. Ontario stated that its DTC mark-up structure aligned with existing domestic tax rates.

The 2025 Pan-Canadian DTC Memorandum of Understanding

In 2025, eleven provinces and territories signed a memorandum of understanding committing to work toward DTC sales of alcoholic beverages made by Canadian producers.

The signatories identified in the later operating agreement were:

Alberta;
British Columbia;
Manitoba;
New Brunswick;
Newfoundland and Labrador;
Nova Scotia;
Ontario;
Prince Edward Island;
Québec;
Saskatchewan; and
Yukon.

The MOU contemplated allowing consumers to order Canadian wine, beer, cider, spirits and other alcoholic beverages directly from producers in participating jurisdictions. It set a target of May 2026 for jurisdictions to negotiate operating agreements or develop their own implementation frameworks. (Canada)

An MOU expresses a governmental commitment, but it does not automatically create a producer’s legal authority to ship. That requires operational rules in both the origin and destination jurisdictions.

The July 21, 2026 Multilateral DTC Operating Agreement

On July 21, 2026, nine provinces signed the Operating Agreement on Direct-to-Consumer Sales of Alcoholic Beverages:

Alberta;
British Columbia;
Manitoba;
New Brunswick;
Newfoundland and Labrador;
Nova Scotia;
Ontario;
Prince Edward Island; and
Saskatchewan.

Ontario and Saskatchewan co-led the arrangement. Québec and Yukon had signed the earlier MOU but were not among the nine original parties to the July 2026 operating agreement. The agreement remains open to other Canadian jurisdictions willing to accept its terms.

The Ontario government stated that the agreement took effect immediately and built upon the earlier Ontario–Nova Scotia bilateral arrangement. British Columbia committed to have its all-alcohol implementation system operating in February 2027.

What Products Does the Multilateral Agreement Cover?

The agreement defines “Beverage Alcohol” broadly to include:

beer;
wine;
cider;
refreshment beverages;
spirits; and
other beverages containing ethanol.

This is broader than earlier arrangements focused only on wine.

The agreement applies to a sale in which:

a consumer places an order directly with a producer;
the producer fills the order using eligible beverage alcohol made in the producer’s home province; and
the product is delivered directly to the consumer by the producer or a third-party delivery service.

The consumer must be a natural person purchasing for personal use. An enterprise, reseller, restaurant, retailer or other commercial buyer is not a DTC consumer under the agreement.

The Product Must Be Made in the Origin Province

The producer may generally sell only beverage alcohol:

manufactured within the producer’s home province; and
which the producer is authorized to sell under its home-province manufacturer’s authorization.

Merely bottling an alcohol product in a province is not necessarily enough. The agreement provides that a product is not treated as manufactured in the origin province when the seller is engaged solely in bottling it there and the beverage alcohol was otherwise manufactured outside that province.

This requirement is designed to make DTC a market-access tool for Canadian producers rather than a way for retailers or bottlers to bypass provincial liquor distribution systems.

What Is Cross-Selling?

Cross-selling occurs when one producer sells beverage alcohol manufactured by another producer.

For example, cross-selling may occur where:

a winery sells beer produced by an unrelated brewery;
a distillery includes another producer’s cider in a mixed case; or
an online producer marketplace accepts orders for products made by several manufacturers.

The agreement generally permits a destination province to refuse cross-selling if that province does not allow producers to cross-sell within its own domestic market.

However, alcohol made under contract for the producer making the sale is excluded from the agreement’s definition of cross-selling.

Under the original Schedule A:

Alberta permits cross-selling;
British Columbia permits cross-selling;
Manitoba permits cross-selling;
New Brunswick permits cross-selling;
Nova Scotia permits cross-selling;
Ontario permits cross-selling;
Prince Edward Island permits cross-selling;
Saskatchewan permits cross-selling; and
Newfoundland and Labrador does not permit cross-selling.

Nova Scotia separately announced reforms allowing local producers to sell one another’s locally manufactured products, supporting its participation in a broader cross-selling model. (Nova Scotia News)

DTC Does Not Eliminate Destination-Province Regulation

Each destination province retains the right to regulate alcohol shipped to consumers within its territory.

The operating agreement expressly preserves provincial authority over:

minimum purchasing and drinking ages;
identity and age verification;
minimum prices;
prohibited or restricted geographic regions;
permitted delivery times and locations;
licensing and registration;
provincial fees and mark-ups;
taxes;
environmental and social-responsibility charges;
reporting;
data collection; and
compliance and enforcement.

A producer therefore cannot rely only on its home-province licence.

The destination province may require the producer to obtain a separate registration or authorization before accepting orders from consumers located there. It may also require the producer to collect and remit provincial charges and submit transaction-level sales reports.

Provincial Authorization Requirements

The July 2026 agreement identifies the following initial authorization models.

Alberta

Eligible Alberta producers must hold the appropriate Class E manufacturer licence and Class D manufacturer’s off-sales authorization.

Out-of-province producers must register through the Alberta Gaming, Liquor and Cannabis Commission’s DTC program. The registration process includes an acknowledgment and undertaking, monthly reporting, and remittance of applicable fees and charges.

Alberta permits cross-selling.

British Columbia

Eligible British Columbia producers must hold a manufacturer’s licence.

An out-of-province producer shipping into British Columbia must obtain an Out of Province Direct to Consumer Authorization from the British Columbia Liquor Distribution Branch.

British Columbia permits cross-selling but committed to implementing its expanded all-alcohol DTC system in February 2027. Until implementation is complete, producers should not assume the multilateral agreement alone authorizes immediate shipment of every product into British Columbia.

Manitoba

Eligible producers must hold the applicable authorization under Manitoba’s liquor legislation.

The original Schedule A states that Manitoba does not require a separate out-of-province DTC authorization.

Manitoba permits cross-selling.

New Brunswick

A producer must hold the applicable manufacturer’s licence in its home province.

The original Schedule A states that New Brunswick does not require a separate DTC authorization.

New Brunswick permits cross-selling.

Newfoundland and Labrador

Eligible producers include licensed brewers, wineries and distilleries.

An out-of-province producer must obtain a Direct to Consumer Authorization from the Newfoundland and Labrador Liquor Corporation.

Newfoundland and Labrador does not permit cross-selling under the original Schedule A.

Nova Scotia

Eligible producers must hold a manufacturer’s permit.

An out-of-province producer must obtain an Out of Province Direct to Consumer Authorization from the Nova Scotia Liquor Corporation.

Nova Scotia permits cross-selling.

Ontario

Eligible Ontario producers must hold a manufacturer’s licence to sell under the Liquor Licence and Control Act, 2019.

An out-of-province producer must obtain an Out of Province Direct to Consumer Authorization from the LCBO before selling directly to Ontario consumers.

Ontario permits cross-selling.

Prince Edward Island

Eligible producers include licensed microbreweries, distillers and wineries.

Out-of-province producers require authorization from the Prince Edward Island Liquor Control Commission.

Prince Edward Island permits cross-selling.

Saskatchewan

Eligible producers must hold a manufacturer’s permit authorizing them to manufacture and sell beverage alcohol.

The original Schedule A states that Saskatchewan does not require a separate out-of-province DTC authorization.

Saskatchewan permits cross-selling.

These entries may be amended by each province through written notice. Producers should check the current regulator requirements before launching sales because registration processes, charges and implementation dates may change.

The Existing British Columbia–Alberta Wine Arrangement

The 2026 multilateral system was not Canada’s first interprovincial DTC arrangement.

British Columbia wineries had historically sold and shipped wine directly to Alberta consumers. A dispute arose when Alberta sought to ensure that provincial mark-ups were properly collected, resulting in a temporary disruption to those sales.

In July 2024, Alberta and British Columbia signed an MOU reopening direct sales of British Columbia wine to Alberta consumers. The arrangement also allowed Alberta wineries reciprocal access to consumers in British Columbia. (BC Gov News)

The arrangement used a “virtual warehouse” structure. A physical shipment did not necessarily have to pass through an Alberta warehouse, but the sale was recorded and treated through Alberta’s liquor system so the province could collect the usual mark-ups and fees.

The agreement initially focused on wine rather than all types of beverage alcohol. It demonstrated that DTC could be structured without eliminating provincial revenue collection and helped provide a model for later pan-Canadian negotiations.

British Columbia reported that product movement across the Alberta–British Columbia border increased approximately sevenfold following the arrangement. (BC Gov News)

Earlier British Columbia, Ontario and Québec Wine Cooperation

Interprovincial efforts also predate the Alberta–British Columbia arrangement.

In 2016, British Columbia, Ontario and Québec announced an agreement intended to improve the flow and availability of Canadian wine among the three provinces. The arrangement focused largely on making wines available through provincial distribution and retail channels rather than establishing today’s producer-to-consumer home-delivery model. (BC Gov News)

It was nevertheless an important precursor because it recognized the need for provincial cooperation to expand access to Canadian wine.

Modern DTC arrangements go further by authorizing the producer to contract directly with the consumer and arrange delivery, subject to destination-province regulation.

What About Québec and Yukon?

Québec and Yukon were signatories to the 2025 DTC MOU but were not among the nine original signatories to the July 21, 2026 operating agreement.

Their participation in the MOU indicated an intention to work toward DTC sales, but producers should not assume that this creates an immediate right to ship into either jurisdiction.

A jurisdiction may:

join the multilateral operating agreement later;
enter separate bilateral agreements;
create its own DTC framework; or
continue developing implementing legislation and administrative systems.

The operating agreement permits another Canadian Free Trade Agreement party to join by accepting its terms and completing its Schedule A entry.

What About the Northwest Territories and Nunavut?

The Northwest Territories and Nunavut were not listed as parties to the 2025 MOU or the July 2026 operating agreement described above.

Sales into those territories remain governed by their existing liquor legislation and liquor authorities unless and until a separate DTC arrangement or legal authorization applies.

Businesses should not interpret the phrase “Canada-wide” as meaning that every province and territory currently operates the same DTC system.

Can a Retailer Use the DTC Framework?

The agreement is principally designed for licensed producers, not ordinary liquor retailers or online marketplaces.

A qualifying seller must hold the relevant manufacturer’s authorization. The agreement does not generally permit a retailer to acquire products from multiple manufacturers and ship them across Canada as if provincial liquor-distribution rules no longer existed.

A platform may also create regulatory risk where it:

acts as the actual seller;
receives the customer’s payment as principal;
sets retail prices;
controls inventory;
chooses which producer fulfils the order;
combines products from unrelated manufacturers;
imports alcohol into the destination province; or
markets itself as an interprovincial liquor retailer.

A technology platform that only provides software or marketing services may have a different regulatory position, but its contracts, payment flows, checkout process and representations should be reviewed carefully.

Can Restaurants and Retail Stores Order Through DTC?

No. The multilateral agreement defines the consumer as a natural person buying for personal use.

It excludes:

businesses;
retailers;
restaurants;
bars;
distributors; and
individuals purchasing for resale or another commercial purpose.

Wholesale and licensed-establishment sales remain subject to the ordinary provincial liquor-distribution and wholesale systems.

A producer should therefore incorporate controls preventing purchasers from using a consumer DTC account for commercial inventory.

Provincial Mark-Ups and Taxes Still Apply

DTC is not necessarily a tax-free or mark-up-free sale.

A destination province may impose:

liquor-board mark-ups;
administrative fees;
environmental charges;
social-responsibility charges;
provincial sales tax;
GST or HST;
container deposits; and
other consumption taxes or charges.

The destination province may require the producer to calculate, collect and remit these amounts.

This can create significant pricing and accounting complexity for a producer shipping into several provinces. A national checkout system may need to identify the consumer’s province and calculate the applicable destination-specific charges before the sale is completed.

Minimum Pricing Requirements

A destination province may apply its minimum retail or social-reference price to a DTC sale.

A producer should not assume that it can use its home-province retail price in every participating province. Discounts, wine-club pricing, subscriptions, mixed cases, free shipping and promotional credits may need to be tested against the destination province’s minimum-pricing rules.

An order may be compliant in the origin province but non-compliant in the destination province if the final selling price falls below the applicable provincial minimum.

Age Verification and Delivery

Alcohol may only be delivered to a person legally entitled to receive it.

A compliant DTC system may require:

age confirmation during checkout;
collection of the purchaser’s date of birth;
age-restricted delivery instructions;
government-issued identification at delivery;
an adult signature;
refusal to leave alcohol unattended;
refusal to deliver to an intoxicated person;
approved delivery hours; and
delivery records.

Merely requiring a customer to click “I am of legal drinking age” may not satisfy all destination-province requirements.

Contracts with couriers should allocate responsibility for identification checks, delivery refusals, record retention, returned products and regulatory cooperation.

Product Labelling and Packaging

DTC products remain subject to applicable federal and provincial requirements concerning:

product composition;
alcohol content;
common names;
net quantity;
allergen and sulphite declarations;
bilingual information;
excise stamps where applicable;
container deposits;
health or pregnancy warnings where required;
packaging integrity; and
misleading claims.

A product lawfully sold in the producer’s home province may still require review before it is marketed into another jurisdiction.

The operating agreement reduces a market-access barrier; it does not create an exemption from federal food, labelling, excise or packaging laws.

Advertising and Electronic Marketing

A producer advertising interprovincial DTC sales must comply with both alcohol-advertising rules and general marketing laws.

Relevant issues may include:

restrictions on appealing primarily to minors;
prohibited lifestyle or consumption claims;
irresponsible-use representations;
influencer marketing;
contests and inducements;
provincial price-advertising rules;
the Competition Act;
provincial consumer-protection legislation; and
Canada’s Anti-Spam Legislation for email and SMS campaigns.

A producer should also avoid advertising shipment into a province before its required authorization is effective.

Sales and Regulatory Reporting

Destination provinces may require product and sales data concerning DTC transactions.

Reports may include:

producer identification;
product names and categories;
package sizes;
alcohol strength;
units sold;
sales value;
consumer destination;
applicable mark-ups and taxes;
shipment dates;
returns and refunds; and
remittances.

The operating agreement requires data demands to be limited to information reasonably necessary for regulatory compliance, but producers should expect each province to administer its own reporting system.

Enforcement of DTC Rules

Each province retains authority to investigate and enforce its DTC requirements.

Potential consequences may include:

warnings;
monetary assessments;
unpaid mark-ups and tax liability;
suspension or cancellation of a DTC authorization;
suspension or cancellation of a manufacturer’s licence;
seizure or detention of shipments;
restrictions on future deliveries;
proceedings under provincial liquor legislation; and
information sharing between provincial regulators.

The operating agreement contemplates cooperation among provincial authorities concerning producer compliance.

A producer’s home province may therefore learn about non-compliant conduct occurring in a destination province.

Is the 2026 Operating Agreement Legally Binding?

The agreement states that it records the parties’ understanding and does not itself create legally enforceable rights or obligations.

This does not mean that the DTC rules are optional.

The binding requirements arise from:

provincial statutes;
regulations;
liquor-board policies;
manufacturer’s licences;
out-of-province DTC authorizations;
acknowledgments and undertakings;
pricing and remittance rules; and
other conditions imposed by the participating province.

A producer generally cannot sue to compel market access solely because a province signed the operating agreement. The agreement expressly preserves the authority of provincial liquor regulators to grant, withhold, vary or cancel individual authorizations.

Is DTC Now Available Across All of Canada?

Not yet in a completely uniform sense.

As of July 2026:

nine provinces had signed the multilateral operating agreement;
Ontario and Nova Scotia had already implemented a bilateral arrangement;
Alberta and British Columbia had an earlier bilateral wine arrangement;
British Columbia had committed to implementing its broader all-alcohol system in February 2027;
Québec and Yukon had signed the 2025 MOU but not the original July 2026 operating agreement; and
the Northwest Territories and Nunavut were not parties to those arrangements.

Even among participating provinces, registration requirements differ. Some require an out-of-province authorization, while others initially indicated that no separate authorization would be required.

The result is an expanding national network, not yet a single national liquor licence.

Compliance Checklist for Canadian Alcohol Producers

Before accepting an interprovincial consumer order, a producer should confirm:

it holds a valid manufacturer’s licence;
the product was genuinely manufactured in the origin province;
the product may be sold under its home-province authorization;
the destination province currently accepts DTC orders from its province;
any destination-province registration has been completed;
the product category is included;
cross-selling is permitted where applicable;
all provincial charges are calculated;
minimum-price requirements are satisfied;
applicable taxes are collected;
the product complies with labelling requirements;
the purchaser is buying for personal use;
age verification is completed;
the courier follows alcohol-delivery requirements;
required records are maintained;
provincial reports and remittances are filed; and
advertising accurately identifies where delivery is available.

How Substance Law Helps With DTC Alcohol Compliance

Substance Law assists breweries, wineries, cideries, distilleries, refreshment-beverage manufacturers, alcohol platforms and other industry participants with:

interprovincial DTC eligibility assessments;
Ontario LCBO DTC authorizations;
destination-province registrations;
manufacturer licensing;
provincial liquor-law analysis;
mark-up and pricing structures;
cross-selling arrangements;
marketplace and e-commerce models;
website terms and conditions;
age-verification procedures;
courier and fulfilment agreements;
product labelling;
alcohol advertising;
privacy and CASL compliance;
provincial reporting requirements;
regulatory correspondence;
inspections and investigations; and
enforcement matters.

Work With an Interprovincial DTC Alcohol Lawyer

Interprovincial DTC sales present a major opportunity for Canadian alcohol producers, particularly smaller manufacturers seeking customers beyond their home province.

However, the emerging framework is not unrestricted free shipping. A producer may simultaneously be subject to its home-province licence, a destination-province authorization, provincial mark-ups, tax obligations, minimum pricing, reporting requirements and age-controlled delivery rules.

Legal and operational review should occur before the producer activates a new province in its online checkout.

Substance Law advises Canadian alcohol businesses on how to structure and operate compliant interprovincial DTC sales programs.

Frequently Asked Questions About Interprovincial Direct-to-Consumer Alcohol Sales in Canada

What are direct-to-consumer alcohol sales?

DTC alcohol sales occur where a licensed producer accepts an order directly from an individual consumer and ships or delivers the product to that consumer without the consumer purchasing it from a conventional liquor store.

Can a Canadian winery ship wine directly to another province?

Potentially. The winery must be authorized by its home province, and the destination province must permit the transaction. A destination-province registration, mark-up, tax remittance and reporting may also be required.

Can breweries and distilleries use the DTC framework?

Yes. The July 2026 multilateral agreement covers beverage alcohol generally, including beer, wine, cider, refreshment beverages and spirits.

Which provinces signed the July 2026 DTC agreement?

Alberta, British Columbia, Manitoba, New Brunswick, Newfoundland and Labrador, Nova Scotia, Ontario, Prince Edward Island and Saskatchewan signed the original operating agreement.

Are Québec and Yukon included?

Québec and Yukon signed the earlier 2025 MOU but were not among the nine original parties to the July 2026 operating agreement. They may join later or implement separate arrangements.

Is British Columbia’s expanded DTC system operating?

British Columbia participated in the July 2026 agreement but committed to implement its system for all alcohol categories in February 2027. Its earlier bilateral wine arrangement with Alberta was already operating.

What did Ontario’s Bill 2 change?

Bill 2 amended the Liquor Control Board of Ontario Act, 2019 so the LCBO can be directed to implement an interprovincial DTC framework. It also amended the Liquor Licence and Control Act, 2019 to authorize intergovernmental DTC agreements and implementing regulations.

Does Ontario require an out-of-province producer to register?

Yes. The July 2026 operating agreement identifies the LCBO as the entity issuing Ontario’s Out of Province Direct to Consumer Authorization.

Can an online liquor retailer use the agreement?

Not ordinarily merely because it sells alcohol online. The framework is directed at licensed producers selling their own eligible products. A retailer, reseller or marketplace may require a different authorization and legal structure.

Can a producer sell another manufacturer’s products?

That is cross-selling. Most original parties permit it under the operating agreement, but Newfoundland and Labrador initially indicated that it would not. The producer must also be permitted to cross-sell under its own licence and the destination province’s rules.

Can a restaurant order alcohol through a DTC website?

No. The operating agreement is for purchases by natural persons for personal use, not purchases by businesses for resale or commercial use.

Does the product have to be made in Canada?

The multilateral framework applies to beverage alcohol manufactured in the producer’s home province. Merely bottling imported alcohol in that province may not satisfy the requirement.

Does DTC avoid provincial liquor-board mark-ups?

No. A destination province may require the producer to collect and remit mark-ups, taxes, fees and other charges.

Can alcohol be shipped by an ordinary courier?

A third-party delivery service may be used, but applicable alcohol-delivery, age-verification and record-keeping requirements must be followed.

Does the customer need to prove their age?

Yes. The producer and delivery service must comply with the minimum-age and identity-verification requirements applicable in the destination province.

Is the July 2026 agreement legally binding?

The operating agreement states that it does not itself create enforceable legal rights or obligations. Producers are nevertheless bound by the provincial legislation, licence conditions, registrations and DTC authorization requirements used to implement it.

Can a province suspend a producer’s DTC authorization?

Yes. Provincial liquor authorities retain their regulatory discretion and may take compliance action, including varying, suspending or rescinding an authorization.

Can Substance Law assist with interprovincial DTC sales?

Yes. Substance Law assists alcohol producers with DTC eligibility, provincial registrations, LCBO authorizations, pricing and mark-ups, online-sales terms, delivery arrangements, advertising, reporting and liquor-law compliance.

What Are Interprovincial Direct-to-Consumer Alcohol Sales?