Nitide / Guides

Bilingual labelling, for brands selling into Quebec

A Montreal buyer has just told you your label will not do. Most of what you are about to fix is federal law that already applied to you in Ontario, Alberta and BC. A smaller part is Quebec's. Here is where the line sits.

Updated 22 September 2026 · 11-minute read

Start with the part that already applied to you

Section 206 of the Safe Food for Canadians Regulations and s. B.01.012(2) of the Food and Drug Regulations require every item of mandatory information on a consumer prepackaged food to appear in both official languages, in Saskatoon as much as in Sherbrooke: common name, net quantity, ingredient list, allergen declarations, the Nutrition Facts table and prescribed expressions.

The exceptions are short. The name and principal place of business of the responsible party may be in one language, under B.01.012(9), as may a closed list of 47 spirit and liqueur common names, and the label of a shipping container destined to a commercial or industrial enterprise or an institution, provided the container and its contents are not resold as one prepackaged unit to a consumer at retail and all required information appears in one official language. Section B.01.012(8) is what makes ordinary two-sided packaging lawful: where a label has another surface at least as large and prominent as the principal display panel, the panel may be in one language if the other appears on that surface.

Two details get missed on artwork. Type size: s. 210(2) sets a 1.6 mm minimum character height, measured on an upper case letter or the lower case "o", while net quantity numerals follow Schedule 6 and run up to 12.7 mm, in boldface. Prescribed wording: a durable life date of 90 days or less carries "best before" and "meilleur avant" grouped with the date.

Three category exemptions exist and almost never help here. Local food assumes one official language is the mother tongue of under 10% of the local unit's population, which in Quebec would mean a label with no English, and the Charter still requires the French. Test market food runs out after 12 cumulative months and only starts after a notice of intention filed with the CFIA six weeks ahead. Specialty food covers religious ceremonial foods and certain imported foods, not something you manufacture here.

What Quebec adds on top

Article 51 of the Charter is the operative rule. Every inscription on a product, on its container or wrapping, or on a document or object supplied with it must be drafted in French. A translation may accompany it, but no inscription in another language may be given greater prominence than the French "or be available on more favourable terms". The Regulation respecting the language of commerce and business does not widen that reach: its s. 1 carries the Division I exceptions across to leaflets, brochures and cards supplied with the product.

Quebec's test on a pack is weaker than the one usually quoted. There is no regulatory definition of "greater prominence" for products; the OQLF's gloss is that other-language inscriptions must not appear more obviously than the French, and that the consumer must not have to make extra effort to reach it. Equal footing is enough. The twice-the-space rule, in ss. 27.4 and 27.6, defines "markedly predominant" for signs and advertising, and mentions products nowhere. It does bite on a display stand: unlike packaging, the OQLF says, a présentoir counts as advertising, so a market table follows the stricter rule while the box on it does not. And watch the limb nobody quotes, "available on more favourable terms": a pack whose French is reachable only by scanning a code or opening an insert fails it even when the type sizes match.

What actually changed on 1 June 2025

Less than the coverage suggested. Trademarks did not become French, a point McCarthy Tétrault published a piece in May 2025 to correct. Article 51.1 says a registered trademark may be drawn up, even partially, only in a language other than French where no corresponding French version appears on the Trademarks Act register, and s. 7.1 carries the same rule to a recognized but unregistered mark. What is new is the second sentence: where a generic term or a description of the product is included in the trademark, it must appear in French on the product or on a medium permanently attached to it. Section 27.2 carves the enterprise name and "the name of the product as sold" out of both categories.

The OQLF's worked examples show where the line falls. On a toothpaste pack, "Happy Teeth" is the product name and may stay in English, while "Toothpaste", "Whitening", "Gum care" and "Mint flavor" are generic or descriptive and need French. One warning in the same guide catches brands from outside the province: if a French version of your trademark is registered at the Canadian Intellectual Property Office, it must appear on your products. A brand that defensively filed a French mark years ago and never used it is worse off, not better off.

What happens if someone complains

The OQLF publishes its complaints policy, and the sequence is more forgiving than the headline fines imply. Complaints come from the public and may be anonymous. Reception, with the Office contacting the complainant within 30 business days. Evaluation, which can include an inspection. Accompaniment, where the Office explains the breach and agrees a correction schedule. Only then, remedial measures. The only firm deadlines published anywhere are those 30 business days, the notice of at least 15 days before an order issues where s. 5 of the Act respecting administrative justice applies, and 30 days to contest one before the Administrative Tribunal of Quebec. The time a business gets to fix a label is described only as a reasonable delay, so a 30-day or 60-day compliance clock quoted at you is invented.

The fines matter less than people expect, because of how Bill 96 rewrote the penal chapter. Section 205 creates an offence for contravening ss. 78.1 to 78.3 or 176, or for disobeying an order. Article 51 is not on that list. The route to a fine runs complaint, inspection, correction request, notice, order under s. 177, disobedience, referral to the Director of Criminal and Penal Prosecutions. At the end of that chain the range is $700 to $7,000 for a natural person and $3,000 to $30,000 for anyone else, doubled on a first repeat.

The published record tracks it. Article 51 product convictions exist and are modest: Supermarché Greenfield inc. on 8 February 2024, and Shop Santé on 28 January 2022, both $1,500. But all 15 convictions published for 2026 as of 4 September are under s. 205 for failing to comply with an order, fourteen at $3,000 and one at $700 against an individual. Nobody was fined this year for a bad label; they were fined for ignoring the Office after it asked. The volume is real, 10,371 complaints and 9,813 inspections in 2024-2025, and so is the resolution rate: 93.8% of correction requests were fixed without judicial process, and the report names service, websites and signage as its top three complaint subjects without publishing the share held by product language. The honest expectation is a letter, a schedule, and a reprint bill at a moment you did not choose.

The QR code cannot carry the mandatory text

Section 214 prohibits selling a prepackaged food unless a label meeting Divisions 1 and 2 is applied or attached to it, and s. 208 and FDR A.01.016 require the information to be clearly and prominently shown under customary conditions of purchase. Both statutory definitions of "label" describe something attached to, included in or accompanying the package. The only off-label routes are physical or postal, and both are conditional. B.01.466 moves the Nutrition Facts table to a tag, insert, inner label, fold-out, sleeve or collar only where the package meets the insufficient-display-surface condition in B.01.454(3), B.01.455(3), B.01.457(2)(b), B.01.461(3), B.01.462(3) or B.01.463(2)(b), and where it goes on an insert or inner label the outer label must say where it is, in 8 point or larger. B.01.467 lets a product whose available display surface is under 100 cm² drop the table if the outer label carries an indication of how to obtain the information that includes a postal address or toll-free number, neither of which a URL can replace, and it does not reach the products excluded by B.01.467(2). The Safe Food for Canadians Regulations contain no occurrence of "QR", and that silence is not a permission, because the requirement is written positively.

The clearest prohibition written by a Canadian body is CFIA guideline RG-12: replacing mandatory information with a machine-readable format is not permitted on the label. It matters that RG-12 governs livestock feeds, so it is the nearest analogue, not the applicable rule. GS1 agrees by omission: its retail 2D guideline puts regulatory compliance out of scope and requires the linear barcode to stay on-pack until 90% of checkouts read 2D. What a page can legitimately add on top of a compliant label: ingredient origin, recipes, recall notices, certifications, lot-level information, a third language. On one condition: French first, with no other language more prominent or easier to reach, which is worth testing on the page your code opens. Our GS1 QR code guide goes further.

Before your next print run

• Check the federal side first: common name, net quantity, ingredient list, allergens and Nutrition Facts, bilingual, at 1.6 mm or better, or 0.8 mm only where both conditions in s. 210(3) are met, namely that the information Division 2 requires is shown on the principal display panel and the principal display surface is 10 cm² or less, with the declaration of net quantity excepted and on its own Schedule 6 scale.
• Read your back panel for the copy federal law does not touch, and get it into French: taglines, claims, origin stories, serving suggestions.
• Look inside your logo lockup. Anything naming an ingredient, a colour, a scent, a flavour or a characteristic is generic or descriptive and needs French on the product, unless those words are the enterprise name or the name of the product as sold, which s. 27.2 carves out of both categories.
• Check whether a French version of your mark sits on the CIPO register. If it does, the trademark exception is not yours to use.
• Make sure nothing in French is harder to reach than the same thing in English, on the pack, on the insert and on the page the code opens.
• Ask your printer when the next run is. Language fixes are close to free at a reprint you were already paying for, and expensive at any other moment.

If the product is also going into a Metro, Sobeys or Loblaw system, the same data has to exist as a bilingual product record. Our ECCnet guide covers that side.