For thirty years, a brand could put an English trademark on a product sold in Quebec and leave it at that. “Ultra Soft Bath Tissue” was a trademark; a trademark was exempt from the French requirement; the exemption covered the whole mark, descriptive words included. On June 1, 2025, that reading ended.
Quebec’s Bill 96 trademark rules for product packaging now require many generic and descriptive terms contained in non-French trademarks to also appear in French. The rules affect manufacturers, importers, distributors and brands selling products in Quebec, including companies based elsewhere in Canada, the United States and overseas.
The Office québécois de la langue française (OQLF) provides official guidance for businesses on the rules governing trademarks displayed on products.
This article explains the Quebec trademark rules introduced under Bill 96, what changed on June 1, 2025, which trademarks remain exempt, how the transition period works, and what a compliant packaging redesign involves in practice.
Bill 96 Trademark Rules: How the Old Quebec Trademark Exemption Worked
The Charter of the French language has required every inscription on a product sold in Quebec to be in French since 1977. Another language may appear, provided the French is at least as prominent.
The Regulation respecting the language of commerce and business carved out an exception for a “recognized trademark” within the meaning of the federal Trademarks Act: such a mark could appear exclusively in a language other than French, unless a French version had been registered.
Two things made the exception wider than the legislator intended. Federal law recognizes unregistered trademarks, so any English phrase a company used as a brand qualified. And brands learned to fold product descriptions into their marks, so that “Whitening Toothpaste” or “Family Size Cookies” travelled to Quebec shelves in English under the protection of the mark.
Bill 96, adopted in 2022, gave the government the power to narrow the exception. The regulation published on June 26, 2024 did so, with effect on June 1, 2025.
Quebec Product Packaging Rules Since June 1, 2025
Three changes matter most for companies selling products in Quebec.
Only Registered Trademarks Qualify for the French-Language Exemption
A trademark may appear on a product in a language other than French only if it is registered under the Trademarks Act and no French version of it appears in the register.
A mark that is merely used, or whose application is pending, no longer qualifies.
Brands relying on common-law marks for Quebec therefore have to register them. Registration in Canada currently takes well over a year, which is why the June 26, 2024 reference date matters for the transition provisions discussed below.
The relevant rule can be found directly in section 51.1 of Quebec’s Charter of the French language, which sets out the conditions under which a registered trademark may appear on a product exclusively in a language other than French.
Generic and Descriptive Terms in Trademarks Must Appear in Canadian French
Where a registered non-French trademark includes a generic term, the kind of product, such as “shampoo”, “cookies” or “toolkit”, or a description of the product, such as “ultra soft”, “lavender scented” or “extra strength”, that term must also appear in French on the product or on a medium permanently attached to it.
The trademark itself stays as registered. The Quebec French translation appears alongside it, and the French must not be less prominent than the English generic or descriptive term it translates.
Bill 96 Packaging Requirements Apply Beyond the Main Product Label
The Quebec language requirements are not limited to the front panel of a package. They can apply to the container, wrapping, label, tag, and documents or objects supplied with the product. Inserts, instruction leaflets and warranty cards were already subject to French-language requirements in full.
Which Trademarks and Product Names Are Still Exempt Under Bill 96?
Several important exceptions remain. The name of the enterprise, the name of the product as sold, designations of origin and distinctive names of a cultural nature may still appear in another language. A brand name that is not descriptive, such as “Tide” or “Lululemon”, is generally unaffected. The longstanding rule that French must be at least as prominent as any other language on the product was also not introduced in 2025. It has existed for decades, although many companies treated the June 2025 changes as if they had created that requirement.
Bill 96 Packaging Transition Period: June 1, 2027 Deadline
The regulation allows certain products that do not comply with the new trademark rule to continue to be sold until June 1, 2027, subject to two cumulative conditions:
- the product was manufactured before June 1, 2025; and
- no French version of the trademark was registered before June 26, 2024.
The transition applies only to the generic-and-descriptive-term rule.
It does not apply to the general French prominence requirement, which has been in force since 1977, and it does not apply to signage. In practice, the transition covers inventory already in the distribution channel when the new rule took effect. It does not cover a new production run using old packaging in September 2025. Distributors and retailers in Quebec have understood this distinction and may refuse non-compliant stock manufactured after the effective date.
If you have stock that qualifies for the transition, document its manufacturing date. The burden of showing that a product falls within the transition is on the person selling it.
Bill 96 vs Federal Canadian Packaging and Labelling Requirements
Quebec’s product packaging rules sit on top of federal Canadian labelling requirements.
The Consumer Packaging and Labelling Act requires bilingual mandatory information on most prepackaged consumer products sold anywhere in Canada.
Food, cosmetics, natural health products, drugs and medical devices carry additional bilingual requirements under Health Canada regulations, and the front-of-package nutrition symbol that became mandatory on January 1, 2026 is itself bilingual.
A product that complies with Quebec’s Bill 96 trademark rules but not with federal Canadian labelling legislation can therefore still be non-compliant.
Our guide to bilingual labelling requirements in Canada covers the federal side, while our French labelling guide for food products in Quebec explains Quebec’s food-specific rules.
How to Make Product Packaging Bill 96 Compliant in Quebec
Most brands ultimately create a dedicated Canadian packaging variant rather than relying on stickers.
There are three common reasons:
- stickers applied over trademark elements can look temporary and may attract scrutiny;
- French text often runs 15 to 25 percent longer than English and needs space designed for it;
- one properly designed bilingual Canadian variant can serve the entire country.
A typical Bill 96 packaging compliance review involves several steps. Inventory every SKU sold in Quebec and obtain the current artwork. Identify each trademark appearing on each SKU and check the Canadian trademark register: is the mark registered, and is there a French version?
Within each registered mark, identify any generic or descriptive terms. Translate those terms into Quebec French and keep the terminology consistent across the product range, for example by using the same French translation for “ultra soft” on every relevant SKU. Then review the rest of the packaging against the general French-language prominence rules. This stage often identifies English-only claims, taglines and usage instructions that were never covered by the trademark exemption in the first place. The designer can then place the French text with at least equal prominence before the final artwork undergoes a bilingual proofreading review. A brand with sixty SKUs typically needs two to four weeks for translation and proofreading, with additional time required for design, printing and channel replacement.
That is why the June 1, 2027 transition deadline is closer than it appears for companies still holding transition stock. Our French packaging and label translation team works directly from designers’ files and returns artwork ready for print.
OQLF Enforcement and Bill 96 Packaging Penalties
Product labelling generated about 6 percent of the 11,125 complaints the OQLF received in 2025-2026. That may appear modest by volume, but the consequences of a substantiated packaging complaint can be significant. A complaint involving a product may lead to an order to withdraw the product from sale, while retailers may respond to OQLF attention by delisting products. Fines of $3,000 to $30,000 per offence apply to companies, with penalties doubled or tripled for repeat offences. Each day of continued sale can constitute a separate offence. Our Bill 96 fines and penalties page explains the enforcement framework in more detail. Complaints about packaging can originate from consumers as well as competitors, particularly competitors that have already invested in bringing their own packaging into compliance.A worked example
English Trademark Sold in Quebec
Consider a US skincare brand selling a “Hydra Boost Overnight Repair Cream” in Quebec through a Canadian distributor. “Hydra Boost” is registered in Canada as a trademark with no French version. “Overnight Repair Cream” is not part of the registered mark.
Before June 2025, the brand relied on the trademark exemption for the whole front panel and printed the rest of the label bilingually.
After June 2025, “Hydra Boost” may remain in English as registered. “Overnight Repair Cream”, however, was never exempt and must appear in French with at least equal prominence, which it should already have done. Now imagine that the registered trademark had instead been “Hydra Boost Overnight Repair Cream” in full.
The words “overnight repair cream” would be descriptive terms contained inside the registered mark and would therefore require a French equivalent alongside them on the panel, with the French no less prominent than those English words.
Stock manufactured in March 2025 may qualify to sell through until June 1, 2027. A production run scheduled for October 2025 requires the new artwork. The result is typically one Canadian bilingual label, with French front-panel elements integrated by the designer and a terminology glossary ensuring that terms such as “crème réparatrice de nuit” remain consistent across the entire product range.
What Companies Should Do Next
The trademark rule is only one part of Quebec’s French-language compliance framework. Companies selling products in Quebec should review packaging alongside signage, websites, contracts, customer-facing documentation and other commercial communications.
Our Bill 96 compliance checklist covers the main requirements, while our Bill 96 deadlines and timeline page tracks the June 1, 2027 packaging transition deadline. And if your company sells products into Quebec without having an office in the province, our guide on whether Bill 96 applies without a Quebec office addresses that question specifically.
Bill 96 Trademark and Packaging FAQ
Does a US-Registered Trademark Qualify for the Bill 96 Exemption in Quebec?
No. Registration under the Canadian Trademarks Act is what counts.
Does a Pending Canadian Trademark Application Qualify?
Not until registration. A pending application does not qualify, which is why brands with Quebec sales are filing sooner rather than later.
Can the French Translation Appear on a Hang Tag or Sleeve?
It can appear on a medium permanently attached to the product. A removable tag is not considered permanent.
Does French Have to Be the Same Size as English on Quebec Packaging?
The requirement is that French be at least as prominent, meaning equal or greater visual impact. On packaging, equal size and equivalent placement is generally the safest approach.
What If the Product Name Itself Is Descriptive?
Suppose the product is called “Original Crunchy Granola”. If the wording is registered as a trademark, the descriptive elements may require French alongside them. If it is the name of the product as sold rather than a trademark, the exception for product names may apply. The distinction can be narrow, and legal advice should be obtained before relying on the exception.
