Recent regulatory developments in Quebec have brought renewed attention to the province’s French language requirements, with expanded translation obligations affecting companies that sell products primarily labeled or documented in another language.
In 2024, Quebec implemented amendments through the final regulation, further clarifying and expanding the provisions of Bill 96.
The legislation, first enacted in 2022, strengthens Quebec’s Charter of the French Language by requiring broader use of French in commerce, particularly for consumer-facing materials.
Under Bill 96 and its subsequent regulations, all products sold in Quebec must include French translations on containers, packaging, and any documents or objects provided with the products. This encompasses labeling, advertising, signage, warning notices, instructions, warranty documents, and owner’s manuals.
The “Final Regulation” extended these obligations to include the French translation of any generic terms or product descriptions contained in trademarks. This means even branding elements that include descriptive English words may now require accompanying French translations.
The Office québécois de la langue française (OQLF) is the provincial body responsible for enforcing Quebec’s language laws. Its oversight ensures that businesses operating in Quebec maintain compliance with the French language requirements across all consumer communications.
“If RV manufacturers sell to RV dealers in Quebec, such manufacturers should be communicating with their respective dealers. The recent amendments in 2022 further expanded the penalties for non-compliance,” the association indicates in a News and Insights report of RVIA on October 9.
The regulatory amendments made in 2022 significantly increased the penalties for non-compliance. Companies found violating the law for the first time may face fines ranging from $3,000 to $30,000 per day.
For repeat offenses, these penalties may double or even triple.
Given the potential impact on operations, The RV Industry Association (RVIA) urges manufacturers to take proactive steps to understand and comply with Quebec’s requirements.
“For those manufacturers who sell units into Quebec, RV manufacturers should review these laws and regulations with legal counsel to ensure compliance with their respective units and any documentation supplied with those units,” the association states.
RVIA also advises that compliance extends beyond finished RV units. Manufacturers should work closely with their component suppliers to ensure that all materials—including labeling, warranties, and user instructions—are available in French.