R. v. Roberts, 2018 ONCA 411 (Paciocco):

[82] In my view, the relevant, settled law can be stated in the following way. Lawfully obtained evidence conscripted from a detainee through roadside sobriety testing is admissible to establish grounds for an arrest or detention, but such evidence is not admissible as proof of actual alcohol consumption or impairment. As I will explain, according to the law of Ontario, evidence is conscripted in the relevant sense only if the act directed by the officer is, itself, a sobriety test.

[83] To be clear, sobriety testing is not confined to the physical co-ordination tests prescribed by regulation as contemplated by s. 254(2)(a) of the Criminal Code. Sobriety testing can include questions asked about alcohol consumption (Orbanski); directions to detainees to perform physical challenges not provided for in s. 254(2)(a) such as informal co-ordination tests (Milne) or directions to exit a motor vehicle (Visser; and R. v. Iannotta, [2009] O.J. No. 5181 (S.C.)); or directions to blow into the face of an officer (R. v. Weintz, 2008 BCCA 233, 256 B.C.A.C. 197, leave to appeal refused, [2008] S.C.C.A. No. 362).

[93] In Ontario, the leading decision is R. v. Brode, 2012 ONCA 140, 109 O.R. (3d) 481. In Brode, this court held that if an officer directs a motorist to get out of their vehicle as a sobriety test, the observations cannot be admitted at trial to prove impairment. If an officer directs a motorist to get out of the car not as a sobriety test, but to facilitate further investigation, including gathering other information about sobriety through questioning once the driver is outside of the car, observations made of the motorist while exiting the car are admissible at trial to prove impairment. In Brode, even though Mr. Brode was being directed out of the car so that his sobriety could be observed once out of the car, since it had not been established that Mr. Brode was directed to exit his car so that his manner of exiting the car could be used as a sobriety test, evidence that he stumbled when doing so was admissible as proof of his impairment.