Understanding Québec’s Bill 96: What It Means for U.S. Marine Manufacturers
As Québec’s Bill 96 continues to reshape the commercial landscape in Canada’s second-largest province, U.S. recreational marine manufacturers selling into the market are being urged to pay close attention. With new French-language requirements now in force, the law is raising questions around enforcement, penalties, and what compliance looks like for U.S. manufacturers.
Following recent discussions at IBEX 2025, NMMA Canada has worked with legal counsel and partners in Québec to clarify the rules and help U.S.-based members chart a path forward.
What is Bill 96?
The Charter of the French Language was first introduced in 1977, declaring French the official language of Quebec and implemented rules regarding its use in areas like government, education, and business. Adopted in 2022, Bill 96 is part of Québec’s push to reinforce French as the province’s official and common language. The law strengthens the existing Charter of the French Language and significantly expands requirements for how businesses communicate with consumers in Québec.
The key changes from the Bill, enacted in 2022, came into effect June 1, 2025.
For U.S. companies, the impact reaches to: websites, warranties, user manuals, contracts, advertising, packaging, and in-store materials must now be presented in French, alongside any English content.
The law’s goal is clear—preserve and promote the French language in all aspects of daily life for Quebec residents. But its implications for cross-border trade, especially in consumer-facing sectors like recreational boating, have created significant confusion and compliance concerns.
What Must Be in French?
In short: anything shown to the end consumer must be bilingual. That includes:
- Product documentation
- Digital content (e.g., websites, mobile apps)
- Promotional materials
- Contracts and warranties
- Labels and manuals
Business-to-business (B2B) materials—such as distributor or dealer communications—can still be in English, as long as the Québec-based partner/dealer agrees to it in writing. But anything that touches the customer must comply with the bilingual mandate.
How Is It Enforced?
Unlike proactive inspections, enforcement under Bill 96 is complaint driven. A regulator will only investigate if a consumer (or third party) submits a formal complaint. The typical process:
- A complaint is filed - The Office Québécois de la langue française (OQLF) sends a demand letter to the company flagged in the complaint.
- A 30-day response window begins - The company must reply, outline corrective steps, and propose a timeline. If the plan is deemed reasonable, regulators will typically agree and offer a grace period, sometimes lasting up to a year.
- Only if the company fails to respond or act, the OQLF may issue a formal compliance order, followed by another 30-day appeal window.
- Fines are a last resort - If a compliance order is ignored, daily fines of up to $30,000 per day can be issued. Legal counsel confirms that most penalties are single-instance fines of $3,000, and daily maximums are rarely, if ever, enforced.
What Does This Mean for U.S. Manufacturers?
If your products are being sold in Québec, you are legally responsible for ensuring that all consumer-facing content is compliant.Failure to meet the standards:
- Puts your local dealer at risk
- Can trigger reputational damage
- May eventually lead to regulatory action
you are not directly responsible for compliance if:
- Your product is not marketed or distributed to Québec
- You are not targeting Québec consumers or dealers
- The product enters Québec through unauthorized third-party resale, such as a dealer or individual who purchased the product elsewhere in Canada
In this case, the responsibility likely shifts to the Québec-based seller, especially if they are the ones advertising, selling, or servicing the product in Québec.
Dealers are under increasing pressure to vet the materials they receive from foreign manufacturers. Some may start declining to carry products that don't comply, out of fear of being held liable.
NMMA Canada: On the Ground and Supporting Members
To help U.S. manufacturers navigate Bill 96, NMMA Canada has mobilized a multi-pronged response:
- Legal Support - NMMA has retained Alexandre Fallon of Osler LLP to advise members on specific compliance questions (at no cost to members).
- Translation & Communications Help - Through a partnership with BlueSky Strategy Group, members can access translation and localization services to bring their materials up to standard (member-funded).
- Ongoing Advocacy - NMMA Canada is in regular contact with Québec regulators, dealer associations, and trade allies like Nautisme Québec and ACVLQ to advocate for fair enforcement and provide feedback from the marine sector.
- No direct lobbying will occur on the topic as the French language is protected through the Charter of French Language, and French remains an official language of Canada, protected in the Charter of Rights and Freedoms. We will continue to lobby for industry supports and matters of economic viability.
Bottom Line: Don’t Panic, But Don’t Wait
Bill 96 is not going away—and neither are the compliance expectations. But the system is not designed to punish businesses that demonstrate good faith efforts to adapt. Key Takeaways for U.S. Manufacturers:
- There is no automatic fine for non-compliance
- Most enforcement follows a complaint + grace period + negotiation model
- Having a French version of all consumer-facing materials is essential (website, product line brochure, customer service, etc.)
- B2B content can remain in English with proper documentation
- Legal is available through NMMA Canada
NMMA Canada recommends preparing bilingual materials for any product line that could reasonably end up in Québec — especially if:
- The product is available anywhere in Canada
- Your brand is visible online or in Canadian showrooms
- You're working with national or regional distributors
Our goal is to protect Québec dealers from being caught in enforcement actions and to minimize exposure for U.S.
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