On June 1, 2025, the final provisions of Bill 96, now An Act respecting French, the official and common language of Québec, which amends the Charter of the French language (the “Charter”), will come into force. These new provisions mainly concern trademarks.

This article provides an overview of the coming changes to the Charter. For a more detailed analysis, read our previous article on the subject.

Trademarks on products (section 51.1 of the Charter)

If a recognized trademark appears on a product (its container, its wrapping, or on a document or object supplied with it) and includes a “generic term or a description of the product” in a language other than French, this generic term or product description will have to appear in French on the product or on a medium permanently attached thereto.

  • The term “description” refers to one or more words used to describe a product’s “characteristics,” except for the “name of the enterprise and the name of the product as sold” and “designations of origin and distinctive names of a cultural nature.”
  • The “generic term” refers to one or more words used to describe the “nature of a product,” except for the “name of the enterprise and the name of the product as sold” and “designations of origin and distinctive names of a cultural nature.”

The new regulations provide for a two-year compliance grace period, starting on June 1, 2025, during which businesses will be allowed to sell products with containers, wrappings, etc., that are non-compliant with the new regulations, provided that these products have been manufactured before June 1, 2025.

Trademarks on public signage (section 58.1 of the Charter)

If a recognized trademark is used in public exterior signage or in public signage visible from outside premises, French must be markedly predominant, as provided for in section 58.1 of the Charter. The same applies for the names of enterprises that include an expression taken from a language other than French, as provided for in section 68.1 of the Charter.

Starting on June 1, 2025: The “markedly predominant” threshold is met when the “French text has a much greater visual impact than the text in a language other than French.” The Regulation further specifies that the French text achieves a much greater visual impact if the following conditions are met in the same visual field:

  • The “space allotted to the French text is at least twice as large as the space allotted to the text in another language.”
  • The legibility and permanent visibility of the French text are equivalent to those of the text in another language.
  • For “dynamic signage” where the English and French texts are displayed in alternation (such as on digital screens), the French text must be “visible at least twice as long as the text in another language” to ensure that French has a much greater visual impact.

For a detailed overview of the amendments provided for in the Regulation to amend mainly the Regulation respecting the language of commerce and business, please refer to our previous article on the subject (which also includes an annotated version of the Regulation respecting the language of commerce and business).

Registration requirement with the Office québécois de la langue française (OQLF) for enterprises

Separate from the regulations governing trademarks, it is important to note that as of June 1, 2025, enterprises that employ 25 people or more during a six-month period will have to register with the OQLF within the six months following the end of that period. This threshold was previously fixed at 50 people.

In light of the significant impact of Bill 96 on businesses operating in Québec, we recommend consulting a member of our Advertising, Marketing and Product Regulatory or Trademark teams to discuss practical steps to mitigate risks and ensure compliance.