First, it raised concerns about Bill 96. Now the Trump administration has turned its attention to another Quebec law, listing the province’s cultural sovereignty legislation as a potential trade barrier.
The United States Trade Representative listed Bill 109 last month in its 2026 National Trade Estimate, a U.S. government report cataloguing foreign measures considered unfair trade practices.
Known as Bill 109 and adopted in December 2025, the sweeping law aims to promote cultural sovereignty and the discoverability of online French-language cultural content.
The U.S. document, published March 31, notes the law “requires streaming services and device manufacturers to promote and prioritize French-language content for Quebec users and could impose a separate investment and discoverability obligation at a subnational level for content in French.”
The document adds: “The United States will closely monitor the implementation of the bill” and any possible implications for the Canada-United States-Mexico free trade agreement.
Trade relations between Canada and the U.S. have been strained since Donald Trump began his second term as U.S. president in January 2025.
The White House has imposed tariffs on key Canadian goods, sparking retaliation by the federal and provincial governments.
U.S. cites procurement rules
In the 2026 National Trade Estimate, the U.S. also notes that Quebec is one of three provinces that imposed restrictions on U.S. companies’ access to procurement processes.
Beginning in March 2025, Quebec, Ontario and British Columbia “implemented regulations or policies that discriminate against or require procuring entities to exclude U.S. businesses from tenders.”
“These policies and regulations range from price penalties on bids from U.S. businesses to complete prohibitions on procurement from U.S. suppliers.”
The U.S. Trade Representative said Canada should “ensure that all provincial and federal procurement policies and regulations are implemented consistently with Canada’s international procurement commitments.”
Bill 96 impact on trademarks
It’s not the first time the U.S. has focused on a Quebec law as a possible trade irritant.
In last year’s trade-barrier review, the U.S. Trade Representative cited Bill 96, Quebec language legislation that overhauled the Charter of the French Language, commonly known as Bill 101.
“U.S. businesses have expressed concerns about the impact that Bill 96 will have on their federally registered trademarks,” the 2025 report said.
Quebec’s cultural sovereignty law will require apps serving Quebec users to default to French, set quotas for French video and audio content, require smart TVs to spotlight French programming and entrench access to French content in the Quebec Charter of Human Rights and Freedoms.
Although the law was adopted, the Coalition Avenir Québec government has not provided details regarding how some of the measures will work.
In December, Culture Minister Mathieu Lacombe said the regulations would be public this year, coming into effect gradually starting in the fall of 2026.
Lacombe has said the planned measures are “essential for the future of our culture and our language,” particularly among youth.
Quebec’s arts sector and the province’s French-language commissioner hailed the law as long overdue, arguing the French language is in danger.
But the plan has faced resistance from major streamers, several of which are based in the U.S. Netflix, Spotify, Apple and YouTube submitted briefs opposing the law.
Streamers push back
Quebec’s plan would be difficult to implement and could interfere with how people listen to music, Graham Davies, head of the Digital Media Association, said in an interview Tuesday.
“The consumer doesn’t want any interference,” he said, pointing to a DIMA-commissioned Léger poll that found 66 per cent of Quebec respondents did not want governments influencing which music is available on streaming services.
Davies, whose organization represents streamers such as Spotify and Apple Music, said the global databases behind streaming services aren’t built to identify songs by language or nationality.
“Some of this kind of metadata tagging that regulators would like — it’s just not there,” Davies said.
He described Quebec music as a streaming “success story.”
Thanks to streaming platforms, music from the province is reaching audiences around the world, with more than 100 million listeners in 180 countries engaging with francophone music over the past year, Davies said.
He said DIMA continues to seek dialogue with the CAQ government as it puts the regulations together.
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