Found it.
Lighting System and Retroreflective Devices (Standard 108) - Transport Canada
My layman interpretation concludes that Section 47.1 effectively allows the use of a fog lamp as a DLR according to this Transport Canada Regulation. The supporting SAE standards talk about angle and beam strength. Since fog lights point at the same angle as low beam, the remaining question is the bulb which is beyond me. I suppose that you can just look up the bulb strength on other current makes that do not use LEDs. But who cares.
You may also recall that the early Audis and several US minivans used the fog lamps (really low on the lower front valance) as DLRs.
I really don't think that this is now an issue either side of the border.