The Order of the Minister of Municipal Affairs establishes a regulation under the Act respecting municipal taxation to define the terms “robotic devices” and “commercial warehousing” for the purposes of section 64.3 of the Act. This regulatory authority is granted by subparagraph 9.1.1 of section 263 of the Act, which was introduced through legislation in 2024, allowing the Minister to clarify these terms for municipal taxation purposes. The regulation, formally attached to the Ministerial Order, provides precise operational definitions to ensure clarity and consistency in the application of municipal tax provisions related to emerging automation technologies and commercial storage activities.

A “robotic device” under the regulation is defined comprehensively to capture a wide range of autonomous machines used in commercial and industrial contexts. A device qualifies as a robotic device if it operates autonomously through a computer system and can process information from one or more sensors to analyze its environment in real time and adapt to changing conditions. The regulation emphasizes mobility, requiring that the device has freedom of movement across at least two axes and the ability to manipulate products of varying sizes, shapes, and weights. Additionally, the device must be capable of performing more than two distinct tasks, including, but not limited to, analyzing, picking, transporting, packing, or sorting products. This multi-functional capacity reflects the practical capabilities of modern warehouse and industrial robots. The regulation also encompasses accessories exclusively used for operating such robotic devices, though it explicitly excludes the base on which a device is placed, clarifying that the definition focuses on active, functional components of automation systems rather than passive structures.

The term “commercial warehousing” is defined to cover activities related to the handling, grouping, disposition, storage, picking, or distribution of products within a location where such products are intended for distribution to retail outlets or for sale through remote channels. This definition encompasses both traditional brick-and-mortar supply chains and modern e-commerce logistics, reflecting the evolving nature of commercial warehousing. By clearly defining this term, the regulation allows municipalities to assess and apply taxation consistently to facilities and operations engaged in the storage and movement of goods intended for commercial sale, ensuring that tax obligations are applied fairly across different types of storage operations.

Overall, the regulation provides a precise framework for understanding what constitutes robotic devices and commercial warehousing in a municipal taxation context. By clearly delineating these terms, it facilitates the application of tax provisions to contemporary commercial and industrial operations, particularly those involving automation and large-scale storage. The definitions are technologically and commercially sensitive, reflecting both current industry practices and the need for regulatory clarity in emerging areas of municipal taxation. This measure aims to ensure that municipal authorities have the legislative tools necessary to administer taxes on modern warehouse operations and automated systems.

Quebec (MO) November 12, 2025
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