Wow this brings back memories. Over twenty years ago I added Vary support to various mod_cache submodules for Apache 2.0, and it was way too high a pain to reward ratio. It just uncovered so many user agent bugs and crazy backends. I remember arguments about being able to cache variable based on non-literal virtual headers (e.g. a geo location header), and a crazy request to Vary based on "Date:" ... which makes absolutely no sense. The whole thing was just too clever for its own good. It's no surprise that language selection ended up in URLs (/en-US/..) rather than "Vary: Accept-Lang" features.