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# Quebec French Language Labeling: What Hardware Sellers Must Know About the Charter of the French Language

Canada's federal Consumer Packaging and Labelling Act requires both English and French on pre-packaged consumer products sold nationally. Quebec goes further. The Charter of the French Language — commonly called Bill 101 — requires that French be the predominant language on product packaging, labels, catalogues, brochures, directories, order forms, and invoices supplied to consumers in Quebec. Bill 96, which amended the Charter in 2022, tightened the rules, increased penalties, and extended application to software and digital interfaces. Any hardware company selling into Quebec without a language compliance review is operating with legal exposure it probably hasn't quantified.

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At a glance

Governing law

Charter of the French Language

Enforcement body

OQLF

Key amendment

Bill 96 (2022)

Max penalty

CAD 115,000 (repeat)

## What the Charter requires for hardware products

### Product inscriptions must be in French

The Charter requires that the name, product description, directions for use, warranty information, and any text on the product itself appear in French. English or other languages can appear alongside, but French must be at least as prominent — and where the law specifies a marking obligation, French must predominate (meaning it must be at least as large and visible as any other language).

### Packaging and labeling

Outer packaging, including boxes, inserts, quick-start guides, and safety warnings, must be in French. Bill 96 strengthened enforcement: the Office québécois de la langue française (OQLF) has expanded inspection powers and can initiate proceedings on complaints.

### Software and interfaces

Since Bill 96 came into force in June 2024, software provided with products sold in Quebec — including firmware interfaces and mobile apps bundled with hardware — must be available in French. This is a genuinely new obligation that catches many hardware companies by surprise.

### B2B sales vs. consumer sales

The predominance-of-French rule applies primarily to consumer products. Business-to-business sales where the buyer has explicitly agreed to conduct business in another language have more flexibility, but this exception does not apply to labeling on physical products.

### OQLF enforcement and complaint process

The Office québécois de la langue française (OQLF) is the enforcement body. Complaints can be filed by anyone — including competitors. The OQLF can issue compliance orders, and non-compliance can result in fines up to CAD 30,000 for first offenders and up to CAD 115,000 for repeat violations under Bill 96.

## How to get French-language labeling right

01

Audit your product packaging, inserts, quick-start guides, warranty cards, and any in-product user interface for all text that appears. Anything a Quebec consumer can read is subject to the Charter's reach.

02

Ensure French appears on all mandatory label fields — product name, description, directions for use, warnings, and country of origin — in a font size at least equal to the English version. If only one language is used on a label, it must be French.

03

For bundled software, firmware UI, or companion mobile apps: if these are sold as part of the product to Quebec consumers, French language support is required. Test both language options and document that French is the default or easily accessible language selection.

04

Review your Quebec-market commercial terms. Any written agreement offered to Quebec consumers (warranty terms, user agreements) that are in a language other than French must also be available in French, and the consumer must have received the French version before signing.

05

File a trademark exemption if applicable — the Charter allows non-French text that is a registered trademark to appear on packaging without a French translation of the mark itself. However, a generic description accompanying the trademark must still appear in French.

06

Maintain compliance documentation. OQLF investigations typically begin with a written request for documentation. Having translation certificates, label proofs, and compliance records available reduces the risk of an adverse finding.

## Frequently asked questions

### Does the bilingual federal labeling requirement satisfy Quebec's Charter?

No — they are separate obligations. The federal Consumer Packaging and Labelling Act requires English and French in equal prominence on national packaging. Quebec's Charter additionally requires that French be predominant (at least as prominent as any other language) and extends beyond labeling to all written communications with Quebec consumers. Meeting the federal requirement gets you to the starting line for Quebec, not the finish line.

### Do small companies get an exemption from the Charter's requirements?

There is no small-company exemption for product labeling. The obligations apply regardless of company size. There are limited exceptions for certain types of B2B contracts where parties agree to use another language, but these don't extend to consumer-facing product packaging or labeling.

### What did Bill 96 actually change for hardware companies?

Bill 96 (An Act respecting French, the official and common language of Québec), which came into force in stages from 2022–2024, extended the Charter's reach to software, firmware interfaces, and digital content bundled with products; increased penalties significantly; and gave OQLF stronger inspection and enforcement powers including the ability to require on-demand production of compliance documents. The biggest practical impact for hardware companies is the software/firmware obligation — it's genuinely new and broadly applicable.

### If we sell through Amazon.ca or another national retailer, are we still responsible for Quebec compliance?

Yes — the manufacturer or importer bears responsibility for the labeling on the product itself. Retailers have their own obligations for in-store and online descriptions, but the Charter compliance burden for physical product labeling rests with whoever puts the product into the Quebec market, which is typically the manufacturer or their Canadian distributor.

**Disclaimer:** Educational resource only. Regulatory requirements change and vary by product category. Consult an accredited test laboratory or qualified compliance engineer before making certification decisions.

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