Common Questions About Quebec’s French Language Requirements

The FAQ below is a follow-up to the RV Industry Association's previous article on Bill 96, a law that increased the French translation requirements in 2022 and amended Quebec’s Charter of the French Language. 

If an RV manufacturer sells an RV into Quebec, or a supplier provides parts to an RV manufacturer that sells that RV into Quebec, do that manufacturer and supplier need to have French labeling on their products and associated documents? 

Yes, Quebec’s Charter of the French Language (the “Charter”) and subsequent amendments to the Charter, including Bill 96 and its Final Regulation, state the French translation requirements, which include but are not limited to French translations for product labeling, manuals, packaging, digital tools, legal documents, and customer communication. This law applies to any company that sells, markets, or distributes its products to consumers in Quebec, including suppliers. 

What materials does a company need to provide in French? 

All materials and documents on the product itself, as well as any materials and documents provided with the product. This includes but is not limited to instructions, warnings, warranties, manuals, marketing materials, signage, packaging, and labeling. However, brand and product names and permanent inscriptions that are embossed or engraved on the product may be exempt. 

What’s the penalty for noncompliance?

Noncompliant companies may face fines that range from $3,000 to $30,000 per violation per day. If there are repeat violations, the fines may increase. 

What are the primary French translation requirements? 

For all RV products sold in Québec, the following must be displayed in French: 

• text on the product
• its container
• labels or wrapping
• and any words on documents or materials that are shipped with, or provided with, the product (e.g., instructions, manuals, warranties, etc.). 

If a manufacturer only sells Canadian Standards Association (CSA) Z240-compliant units into Quebec, will that satisfy the Charter requirements? 

No, it will not satisfy all the requirements. Since CSA Z240 compliant units include the French warning labels, such units are closer to compliance than units that do not have the French labeling, but they still need to have French translations for all other written materials provided, such as product labeling, manuals, etc. 

Does a company need to translate its brand or product name?

Generally, if a company’s brand or product name is in English and is not registered or pending registration in Canada, such a company does not need to translate its brand or product name. However, if there are generic or descriptive terms included in the trademark, such terms may need to be translated unless clearly part of the brand or product name. The example that the Office Québécois de la langue Française (“OQLF”) provides in its guide – which is in French – is if a toothpaste package has a brand name and the word “toothpaste” is directly underneath the brand name, then the word “toothpaste” would have to be translated into French since it is a generic or descriptive term (even if were part of the trademark). 

How should the translations look?

The French translation must be at least as prominent in size, color, and placement as materials in other languages, and in some circumstances (e.g., signage), French must be the predominant language. The French translation must also be easy to access, and the display of French cannot be less favorable than any other language (e.g., if one language is easier to read because of font or color). 

Disclaimer: The information contained in this article is intended for informational purposes only and is not comprehensive or exhaustive. It is important to consult with your legal counsel on the interpretation and applicability of Quebec’s laws as they relate to French translation requirements. The RV Industry Association assumes no responsibility for any inaccuracies or omissions. The information above is subject to change by Quebec.