Bill 96 product labelling rules apply to every herbal brand that ships into Quebec, and they reach further than the federal bilingual label. Since June 1, 2025, Quebec's amended Charter of the French Language has tightened how trademarks, slogans and package text can appear in English. As a result, a label that meets Health Canada's requirements can still fall short in Quebec. Here's what changed, where herbal brands usually get caught, and how to plan your artwork before the next print run.
Key Takeaways
- Quebec requires French on every inscription on a product, its packaging and any document supplied with it, not just the mandatory federal label text.
- English text can stay, but it can never be more prominent than the French version.
- The trademark exception still exists, but generic or descriptive words inside a trademark need a French translation.
- Products made before June 1, 2025 can be sold until June 1, 2027, so non-compliant stock has a hard end date.
- The cheapest fix is to build French into the artwork before your next print run, ideally alongside the 2028 product facts table update.
What Bill 96 Changed for Product Labelling in Quebec
Quebec's National Assembly passed Bill 96 in June 2022. It amended the Charter of the French Language, which already governed product labels in the province. Then, in June 2024, the government published the final version of its regulation on the language of commerce and business. Most of the product rules took effect on June 1, 2025.
The core rule hasn't moved. Every inscription on a product, its container, its wrapping and any document supplied with it has to appear in French. That includes directions, warranty text and inserts. Other languages are allowed, but they can't have greater prominence than the French.
What changed is the detail around that rule. Bill 96 product labelling requirements narrowed the trademark exception, added translation duties for descriptive words and set firm transition dates. The Office québécois de la langue française (OQLF) handles complaints and enforcement.
Federal Bilingual Labels vs. Bill 96 Product Labelling
Most herbal brands already print bilingual labels. The Natural Health Products Regulations require the mandatory label information in both English and French, which we cover in our guide to bilingual NHP labelling requirements. However, the federal rule focuses on the mandatory information: product name, NPN, dose, cautions and so on.
Quebec's rule is broader. It covers everything printed on the package, so marketing copy counts too. For example, a front-panel tagline, a "small batch" badge or a short brand story on the side panel all need French. The same goes for outer cartons, inserts and printed QR-code prompts.
This is where most brands run into trouble. A label can carry a perfect bilingual mandatory panel and still fail in Quebec because the hero claim sits in English only. So the audit has to cover every word on the package, not just the regulated fields.
The Trademark Exception Under Bill 96 Product Labelling Rules
The trademark exception lets a brand keep a non-French trademark on a product without translating it. Still, Bill 96 tightened the terms. Section 51.1 of the Charter refers to a trademark registered under the federal Trademarks Act. Meanwhile, the 2024 regulation refers to a "recognized" trademark, which could include pending or unregistered marks.
Law firms have flagged that gap as unresolved. So the safe position for a herbal brand is simple: register the mark with CIPO. Our post on herbal brand trademarks in Canada walks through that process. Also note one catch: if a French version of your trademark appears on the register, you have to use the French version.
The second change matters even more for herbal products. Generic or descriptive words inside a trademark now need a French translation on the product. For example, in a mark like "Northfield Herbal Tincture", the words "Herbal Tincture" describe the product. Therefore, the package needs "teinture à base de plantes" or a similar French equivalent. The translation must sit on the product itself or on a medium permanently attached to it.
The June 2027 Sell-Off Date and the Penalties
The regulation included a transition window for existing stock. Products manufactured before June 1, 2025 can stay on sale until June 1, 2027. That only applies when no French version of the product's trademark appears on the register.
Here's what that means in practice: older labels have about seven months left. After June 1, 2027, a retailer in Quebec can't keep selling them, whatever the manufacture date. Distributors and health food chains also tend to check this before they renew a listing. That's why the date matters for your distribution plans as well as for compliance.
Bill 96 also raised the fines. For a business, a single offence can now cost between $3,000 and $30,000, and the amounts climb for repeat offences. In addition, the OQLF can act on a consumer complaint, and a single complaint is often how an investigation starts.
A Bill 96 Product Labelling Checklist for Herbal Brands
Start with a full audit of every SKU that reaches Quebec, including stock sold through Amazon or a national distributor. Then work through each panel with this list:
Timing matters as well. Health Canada's new product facts table becomes mandatory for NHPs in 2028, as covered in our NHP product facts table guide. If you combine both changes into one redesign, you pay for one round of artwork, translation and plates instead of two.
Finally, use a professional French translator, not a machine draft. A clumsy or inaccurate French panel can still draw a complaint, even when the text is technically present. For anything unclear, such as how a specific mark fits the exception, ask a Quebec lawyer.
Planning Bill 96 Compliance With Your Manufacturer
Label changes are easiest when your manufacturer knows about them early. Share the final French artwork before you order the next print run, so labels and cartons arrive ready for filling. Also confirm who owns label approval, because a contract manufacturer applies the artwork you supply and doesn't act as your legal reviewer.
If you're launching a new private label line, build Bill 96 product labelling into the first design. It costs far less than relabelling stock later. To talk through a new product or a label refresh, see our manufacturing services or contact Perfect Herbs for a quote.
Published: October 29, 2026