The Speed limits in Canada are for departures and arrivals. Long time ago the 250kts limit was not applicable for departures, now it is also. The point being if you dont need to keep flaps for the 250 limit, then you dont need to extend flaps for the 200kts limit either...that's all. Yes a departing aircraft is obviously heavier and has a much higher clean speed...irrelevant. There are cases when the pilot might not want to extend flaps to 5 when below 3000 10nm to meet the 200kts restriction (for arrival) if for example he is number 18 for the approach and will do an extended downwind for a 20nm final. Heavy jets sometimes need to go to flaps 5 if they want 200kts.
Thank you for all answers,