In Ontario, Section 40(2) of the Professional Engineers Act clearly states that using the title “professional engineer” as an occupational or business designation violates the law. 

What it says about using the title "engineer" is more qualified: "Every person who is not a holder of a licence or a temporary licence and who, ". . . (a.1) uses the title “engineer” or an abbreviation of that title in a manner that will lead to the belief that the person may engage in the practice of professional engineering; "is guilty of an offence" 

The provision doesn't seem to have been tested in court, but I suspect a good argument can be made that, while it might be risky for a person to hang out a shingle as an "engineer" without having a licence, he or she could act in-house under such a title. 

The main purpose of the provision is to protect the client and in the case of an in-house 'engineer' the client is fully aware.