What Bill 96 actually is (quick primer)
Bill 96 — officially Loi 14 (An Act respecting French, the official and common language of Québec) — is a 2022 amendment to Quebec's Charter of the French Language. It tightens and extends existing French-language rules across labelling, packaging, workplace communication, contracts, public signage, and — most relevant for ecommerce brands — commercial documentation and marketing content.
The bill was signed into law in 2022 but its most impactful commercial provisions rolled out in stages. The one Canadian DTC brands need to care about landed on June 1, 2025: product labelling requirements. Enforcement is handled by the Office québécois de la langue française (OQLF), the government agency responsible for the Charter.
The short version: if a Quebec consumer can buy your product, they must be able to read every material aspect of it — the name, the ingredients, the warnings, the instructions, the warranty — in French. If your website ships to Montreal or Quebec City, this applies to you, regardless of where your business is located.
Who has to comply — even if you're not in Quebec
One of the most misunderstood aspects of Bill 96 is its extraterritorial reach. The law is not limited to businesses physically located in Quebec. It applies to anyone offering products or services to consumers in Quebec. In practice, this means:
- An Ontario Shopify brand shipping skincare to Montreal → covered
- A Vancouver-based DTC beverage brand selling into Quebec grocery → covered
- A US ecommerce brand fulfilling a single Quebec order per year → covered
- An Alberta candle maker with a French-Canadian audience on Etsy → covered
- A UK brand shipping cosmetics into Canada through Shopify Markets → covered when Quebec buyers can complete checkout
The Charter's language is unambiguous: information published on websites or social media directed at Quebec consumers is considered commercial documentation. That includes your product detail pages, your Instagram captions, your TikTok video overlays, your marketing emails, and — critically — your product photography if the product label is visible and readable.
The practical implication: if you're a Canadian DTC brand with a Shopify store and you don't geo-block Quebec, you're subject to Bill 96. Geo-blocking is legal but almost no DTC brand wants to voluntarily cut off a 8.5-million-person market. So the near-universal answer is: comply.
What has to be in French, exactly
The Charter, as amended by Bill 96, requires French on all of the following commercial material when directed at Quebec:
- Product name — the primary name of the product as it appears on packaging and in listings.
- Product description — copy on the packaging, on the product page, and in any marketing collateral.
- Ingredients or components — full list, in French, on labels and product pages.
- Safety warnings — any allergen, age restriction, or hazard information.
- Directions for use — how the product is applied, consumed, or operated.
- Warranty terms and conditions — any promise made to the buyer.
- Warranty documentation and user guides — inserts, quick-start cards, downloadable PDFs.
- Promotional inserts — anything shipped inside a box that has text.
- Websites and social media — product pages, captions, video overlays, hover states, alt text (yes, alt text) when directed at Quebec.
- Advertisements — Meta / TikTok / Google / YouTube ads targeting Quebec audiences.
There are limited exceptions — recognized trademarks that are federally registered, the product's origin country, and certain regulated fields (like ingredients that follow federal labelling law). But the exceptions are narrower than most brands assume, and each one comes with its own restrictions and OQLF interpretation.
Most importantly: French must be at least as prominent as any other language. It cannot be smaller, less visible, or de-emphasized versus English. Equal visual weight — font size, colour, placement, contrast — is the practical compliance target most brands use.
Deadlines: what's already in force, what phases out in 2027
Two dates matter for product labelling:
- June 1, 2025 — new labelling requirements officially in effect. All products manufactured on or after this date must fully comply. This deadline has already passed.
- June 1, 2027 — end of the two-year phase-out for existing inventory. Products manufactured before June 1, 2025 can continue to be sold with their pre-existing labelling until this date. After that, every product on Quebec shelves — regardless of when it was made — must be compliant.
The phase-out is generous compared to most language legislation. It's also finite: if your DTC brand has 30 months of skincare inventory in a warehouse in early 2027, the clock is running.
For ecommerce brands specifically, the more urgent deadline is often not product labelling but web content. Websites, product pages, and marketing communications had earlier compliance expectations, and the OQLF has already begun receiving complaints and issuing notices to non-compliant online sellers.
Fines and enforcement — the numbers
Under Bill 96, fines for organizations range from $3,000 to $30,000 per offense. Amounts double for a second offense and triple for subsequent violations. The largest single-organization fine potential per subsequent offense sits at $90,000.
The critical detail most brands miss: each day a violation continues counts as a separate offense. A non-compliant Shopify listing that runs for 30 days could theoretically trigger 30 separate fines. In practice, the OQLF issues warnings and gives businesses time to correct, but the statutory exposure is real.
Additional consequences beyond fines:
- The Minister of French Language may suspend or revoke government-issued permits — relevant for brands with Quebec business licences or Bureau des Alcools permits.
- Violations expose organizations to private rights of action — a Quebec consumer can bring a private lawsuit for damages, punitive damages, or injunctions.
- Class action risk is a real and growing concern for DTC brands with meaningful Quebec sales.
- The OQLF can seek court orders compelling compliance — meaning a court can force a brand to fix its labels, product pages, or advertising by a deadline.
Enforcement is primarily complaints-driven. A single Quebec consumer or competitor can trigger an OQLF investigation. Language advocacy groups are also active in monitoring for non-compliance, particularly among high-visibility DTC brands.
The product photography problem
For most DTC brands, updating written copy on a Shopify page is a translation task solved in an afternoon. The harder — and more expensive — problem is product photography.
If your product images show your packaging with an English-only label, those images are non-compliant when your product is offered to Quebec consumers. The OQLF treats a visible label in a product photo the same as a physical label. This means:
- Hero packshots on your homepage need to show bilingual labels.
- Product detail page photos — every angle, every scene — need bilingual labels.
- Lifestyle scenes where your product is held or placed need bilingual labels visible.
- Ad creatives on Meta, TikTok, YouTube targeting Quebec audiences need bilingual labels.
- Social posts on Instagram, TikTok, Facebook — where the label is legible — need bilingual labels.
For a brand with 20 SKUs, that's not a small update. That's potentially 200–400 photographs that need to be re-shot or re-produced. And for a brand with 100 SKUs, the math is genuinely painful.
Some brands have tried to shortcut this by editing text on the label in Photoshop. That works for one or two shots. It doesn't scale, and — critically — it looks obviously edited when scrutinized. Regulated categories (cosmetics, food, supplements) draw more OQLF scrutiny; a photoshopped label is a red flag.
What a full bilingual reshoot actually costs
Let's put a number on it. A typical Canadian DTC brand with 20 SKUs, each needing 4 primary photos (hero packshot, lifestyle scene, detail, and social square) with the bilingual label visible, has 80 photos to produce.
The traditional Toronto studio cost for this reshoot:
- 2 shoot days minimum — larger catalogues push to 3–5 days: $2,400–$6,000
- Studio rental: $900–$2,700 across days
- Stylist + assistant: $1,200–$3,000
- Sample re-shipping (products with new labels have to ship in): $200–$500
- Retouching (80 photos at $30–$80 each): $2,400–$6,400
- Timeline: 3–6 weeks end-to-end
All-in total: $7,100 – $18,600, delivered in 3–6 weeks. And that's just for the 20-SKU case. Scale to 50 or 100 SKUs and the cost climbs proportionally.
The pain point isn't only the money. It's the calendar. Between OQLF starting to actively enforce and your existing inventory phase-out running out in June 2027, most brands don't have the runway to do a full studio reshoot. And if you're a smaller brand — 10 to 30 SKUs, no in-house creative team — the cost alone can be enough to price you out of the Quebec market entirely.
How AI product photography solves this in days, not weeks
The core insight: your product hasn't changed. Only the label needs to change from English to bilingual French/English. Everything else about the product visual — the shape, the material, the finish, the lighting, the environment — is identical to your existing catalog.
An AI product photography pipeline exploits this perfectly. From a single reference photo of your product (either an existing English-label photo or a new photo of the physical bilingual product), the pipeline can regenerate the entire visual set — same angles, same lighting, same lifestyle contexts — with the bilingual label rendered directly onto the packaging. No physical reshoot. No sample re-shipping. No studio day.
Practical workflow:
- Send your current product images and your French label copy (or the compliant physical label design).
- The AI pipeline generates a locked description of your product with the bilingual label, then re-renders every catalog shot with the new label in place.
- Every hero, lifestyle, detail, and social variation is produced in parallel — same brand aesthetic, same lighting, same consistency across the full SKU line.
- Turnaround: 4 days for a 20-SKU catalog, versus 3–6 weeks for a traditional reshoot.
- Cost: roughly $1,900 CAD for a 20-SKU bilingual catalog refresh (matching our Brand Starter Pack), versus $7,100–$18,600 for the studio equivalent. A 65–90% saving.
For a Canadian DTC brand facing Bill 96 compliance without a large creative budget, this workflow is often the difference between compliance in weeks versus months, and staying in the Quebec market versus quietly reducing exposure.
A practical Bill 96 compliance checklist
Working list we give to Canadian DTC brands preparing their Bill 96 catalog update:
- ☐ Audit your product catalog — flag every SKU with English-only labelling on the physical product.
- ☐ Order compliant physical labels (either full package redesign or bilingual overlay/sleeve).
- ☐ Update product page copy to French for every SKU offered in Quebec — title, description, warnings, warranty.
- ☐ Update product photography for every SKU — hero packshot, at least one lifestyle scene, detail shot, and social square, all showing bilingual labels.
- ☐ Localize Meta / TikTok / YouTube ad creatives targeting Quebec.
- ☐ Localize marketing emails sent to Quebec customers.
- ☐ Add French versions of user guides, warranty documents, and any downloadable PDFs.
- ☐ Audit Instagram, TikTok, and Facebook posts — replace ones where an English-only label is prominently visible with bilingual versions.
- ☐ Verify French text on all materials is at least as prominent as English — same font size, colour, placement.
- ☐ Document your compliance timeline — if an OQLF complaint arrives, showing a good-faith remediation plan matters.
Frequently asked questions
When does Bill 96 come into force for product labels?
The updated bilingual labelling requirements under Bill 96 (Loi 14) took effect on June 1, 2025. Products manufactured before that date benefit from a two-year phase-out period ending June 1, 2027, after which every product sold in Quebec must fully comply — regardless of when it was manufactured.
Do I have to comply with Bill 96 if my business isn't based in Quebec?
Yes. Any business selling products or services into Quebec must comply with Bill 96, regardless of where the business is physically located. If your ecommerce store ships to Quebec — even from Ontario, Alberta, or the United States — French labelling, product pages, and marketing content are required for Quebec-directed sales.
What are the fines for non-compliance?
Fines for organizations range from $3,000 to $30,000 per offense. Amounts double for a second offense and triple for subsequent violations. Each day a violation continues counts as a separate offense — a non-compliant listing that runs 30 days could theoretically trigger 30 separate fines. The OQLF enforces primarily by complaint.
Does Bill 96 apply to product photography and packaging visuals?
Yes. Product packaging and any visible product name, description, ingredient list, warning, direction for use, or warranty text must be in French. Product photography that features an English-only label is treated the same as an English-only physical label — non-compliant when the product is offered to Quebec consumers.
How can I update product photos to be bilingual without a full reshoot?
AI product photography lets you regenerate the same product image with a bilingual French/English label — without a new physical photoshoot. From a single source reference and your French label copy, an AI pipeline produces the identical product shot with the compliant label visible, in hours rather than the 3–6 weeks a traditional reshoot would take. This is one of the practical workflows Shotless uses with Canadian brands shipping into Quebec.
Does French have to be equally prominent as English on my label?
Yes. Under Bill 96, French must be at least as prominent as any other language on packaging, labels, and marketing content. The French text cannot be smaller, less visible, or de-emphasized versus English. Equal visual weight — font size, colour, placement, contrast — is the practical compliance target most brands use.
Are website and Instagram content covered?
Yes. Information published on websites or social media is considered commercial documentation under the Charter and must comply with French language requirements when directed at Quebec consumers. This includes product pages, Instagram captions, TikTok video overlays, and email marketing sent to Quebec customers.
Are there any exemptions?
Limited ones. Federally registered trademarks may appear in the trademark language; the country of origin can be in the source-country language; and certain regulated fields follow federal (not Quebec) labelling law. But the exemptions are narrower than most brands assume, each comes with its own conditions, and OQLF interpretation is trending stricter, not looser. Assume compliance is required unless a lawyer has confirmed otherwise for your specific case.
This article summarizes Bill 96 (Loi 14) provisions relevant to Canadian DTC brands as of July 2026. It is a plain-English guide, not legal advice. For binding interpretation for your specific business, consult a Quebec-licensed lawyer. See also our related article on AI product photography vs traditional studio: 2026 cost comparison.