Food Labeling - VI

Canadian Food Labeling Requirements

Canada is another country like US FDA, which has its own specific requirements based on scientific research inputs, including consumer and industry inputs, which has created slight differences compared to US and FDA regulatory requirements. As usual in every food label, there has to be a Common name or an exemption, and that information must be included in the Principle display panel (PDP) with a non-decorative font where letter size has to be 1.6mm or greater.  The common name has to be appropriated to the product within the package. The net quantity has to be declared within the PDP, and it has to be declared with metric units or given units defined in Canadian legislation. The volume, weight, count, and the correct bilingual symbols must be used to indicate the quantity with the font size matching the appropriate PDP size to the letter size ratio. If optional Canadian or US units are used, they must be adequately identified, and priority must be given to the metric units before writing the optional units.
 
The list of ingredients has to follow new guidelines, including all major ingredients in descending order of proportion by weight or as a percentage with their appropriate common names.  The product components must also be declared where necessary, and sugar-based ingredients must be grouped and declared under "Sugars." There are 11 priority allergen materials declared under Canadian food labeling requirements including, Eggs, Milk, Mustard, Peanuts, Crustaceans and molluscans, Fish, Sesame seeds, Soy, Sulphites, Tree Nuts, Wheat, and Triticale.
 
Proper allergen labeling is the only way consumers with food allergies and sensitivities can find out if a food is safe for them to eat, where it is your responsibility to ensure that food products are correctly labeled. Thus, identification, prevention, and control have to be applied accordingly. The priority allergens must be declared using the prescribed source name or common names, including gluten and added sulphites in the list of ingredients, or in a "food allergen source, or in a cross-contamination statement at the end of the list of ingredients in any allergen source is presented. The lists of ingredients and allergen statements must be in English and French as the same declarations.
  

The information in the list of ingredients has to be displayed on a panel other than the bottom on a continuous surface with no intervening material with an appropriate presentation, including background and/or border with the appropriate colours and contrast recommended in the Industry Labelling Tool.
 
The name and principal place of business must be declared in the PDP, including information on locally manufactured or imported products with reasonable traceability. Hence, the product must clearly declare Canadian manufacturer/importer name and principal place of business, grouped with the geographic origin, or preceded by the expressions "Imported by / importé par" or "Imported for / importé pour" or foreign name and principal place of business. 
 
Date markings have to be represented for all the products that are not exempted where "Best Before" Date (durable life of 90 days or less, unless exempt food or packaged where sold at retail) must be in the correct wording "best before / meilleur avant" used in English and French or in one language if exempt from bilingual labeling. The date has to be clearly given or explain where, if the date is located elsewhere on the label with appropriate presentation (order of info such as yr, m, day, use of bilingual symbols for months) for consumer reference. If a product required a Packaged on" date based on the processing requirements, it has to be declared as of date making with correct wording and following bilingual requirements.
 
The product may require storage instructions based on the type of product or environmental conditions (if storage conditions differ from normal room temperature or may be required by food-specific legislation).
 
The Expiration date has to be presented if there is no exemption for expiry, which must be legible and available for consumer references.
 

The Core Nutrition Information Table refers to the core nutrition information that is mandatory for most Nutrition Facts tables, which is not an exact replica of the table in the Food and Drug Regulations (FDR). This table is available for the public for references to use while preparing your NFts. The nutrient information presented in a Nutrition Facts table is based on a specific amount of food such as edible proteins, where amount must be indicated under the Nutrition Facts heading using the phrase "Per (naming the serving size),” "Serving Size (naming the serving size)," or "Serving (naming the serving size)." The serving size is a quantity of food that can be reasonably consumed at a single eating occasion by an adult or a child based on the target consumer. Preparation of an NFt is a long technical process where interested parties must consult the Health Canada site and reference the Nutrition Labelling – Directory of Nutrition Facts Table Formats. This process requires meticulous attention and understanding before processing an NFt.  
 
Origin of the product is an essential factor, which identifies where the product is manufactured and consequences to the consumers due to the geographical, biological, and political reasons as well as countries that are explicitly polluting or contaminating the product due to low hygienic practice or food fraud. Thus, it is mandatory to let the consumer know where the product is manufactured or processed. Hence, sufficient information must be provided with contact details for complete traceability.     
 
Review of the newly enforced changes on Canadian labeling regulations

After the last review of the Labelling requirements, several changes were made to the label appearance and Daily Value calculations. Thus, new changes have reflected deviations from FDA/Codex model in order to reflect the latest science while more focusing on nutrients of public health interest and addressing the needs and concerns of the Canadian consumer.
 
The Daily Values (DV) refer to nutrient amounts Canadians should consume OR not exceed (depending on the nutrient). The amounts are used to calculate the percent DV that is seen on the Nutrition Facts table, per reference age group. Daily Value reference age groups have been updated to reflect the age groups described in the DRI documentation. Hence, the Canadian Nutrition Facts table provides Daily Value standards for three age groups instead of two, where new table differentiates between the nutritional needs of infants aged six months to less than one year and children of aged one year to less than four years, as well as adults and children four years and older. The current changes are based on the latest recommendations from the US Institute of Medicine and the Canadian Community Health Survey.
 

The Nutrition Facts table appearance has been updated to reinforce the desired changes put forth by the regulations, where calories are displayed more prominently, with a larger type size and more surrounding white space. The serving size amount is more accurately reflects with more consistent amounts that Canadians typically eat in a sitting, thereby making it easier to compare nutrient amounts in similar foods. Nonetheless, the order of nutrients has changed to reflect major contributors to calories such as fats, carbohydrates, and protein which are now the first listed underneath Calories. The major vitamins and minerals requirements have been changed to accommodate current major concerns in the society and food products. Hence, Potassium is now an essential nutrient, and vitamins A and C are no longer core nutrients, but they may be listed voluntarily. In addition, the new table requires that vitamins and minerals amounts must be listed along with the percent Daily Values to help consumers compare the levels found in supplements. Further, a percent Daily Value of sugars has been added to the list to help consumers determine whether a food contains a little or a lot of sugar to adjust their sugar intake accordingly. A new footnote has been added to inform consumers how to use the percent Daily Value to make dietary choices, where "*5% or less is a little, 15% or more is a lot."
 
Trans-fats are voluntary on the pre-existing table but are no longer displayed on the new Nutrition Facts table because research suggests that the type of fat is more important than the amount. Hence, it was determined that this information was not necessary to assist consumers in making healthy dietary choices.
 

Potassium is now an essential nutrient on the Nutrition Facts table, which was an additional nutrient on the pre-existing table. Thus, Potassium was added to the core group to increase consumer awareness because most Canadians are not consuming adequate amounts of Potassium, and it is an essential nutrient for maintaining healthy blood pressure. Hence, the Daily Value for Potassium has increased from 3500 mg to 4700 mg per day.
 
Choline is a new additional nutrient for the Nutrition Facts table, which was previously not allowed to be listed on the table, but now Choline can be voluntarily listed. The Choline is required in order to maintain liver function, where the Daily Value amount of 550 mg for adults has been set based on this research and the DRI recommendation.
 
Sugars are an essential nutrient for both the pre-existing and new Nutrition Facts tables, but a DV standard has been added to the new table, where adults' DV standard is 100 grams. The DV was added to the list to warn consumers that it could be used as the new DV footnote to help determine whether a food contains a little or a lot of sugar. Research suggests that an increased sugar intake leads to an overconsumption of calories, which has been associated with obesity and chronic diseases. This enforcement measure will help educate consumers about the sugar content of foods to assist in making healthy dietary choices.
 
Folate is an additional nutrient on the Nutrition Facts table whose unit has changed, which was reported as mcg of total folate on the pre-existing table. But the new Nutrition Facts table requires manufacturers to declare folate as mcg of DFE (Dietary Folate Equivalents). Thus, the DV standard has increased from 220 mcg to 400 mcg DFE for adults. Hence, the change in amount and unit follows the recommendation of research data, where mcg DFE is the measure used for folate in the DRI standards. DFE accounts for the differences in bioavailability between the folate found in food and folic acid, the synthetic form.
 

Vitamin A and C are no longer considered as essential nutrients on the Nutrition Facts table, which are now voluntary, and are listed below the core minerals. Because studies suggest that Canadians are consuming adequate amounts of these vitamins and that they are no longer nutrients of concern, however, the Daily Value for vitamin C has increased from 60 mg to 90 mg per day for adults. Besides, the Daily Value for vitamin A has changed from 1000 RE to 900 mcg RAE per day, where the new unit more accurately reflects the conversion of carotenoids to vitamin A in the body.
 
Food labeling regulations require that an ingredient statement be shown on the package near the Nutrition Facts table, making the ingredient statement easier to read and understand. It has to be displayed using black type on a white or light background, with a standard sans serif font, where ingredients are listed in descending order by weight, in upper and lower case letters, and are separated by a bullet point or a comma. Necessary components of an ingredient should be listed by the common name, and it has to be shown in parentheses after the ingredient. The food colors are listed by their specific common names instead of just listing the word "colour."
 

Nonetheless, new regulations provide additional guidance for the reporting of sugar-based ingredients in the ingredient statement where, if a product contains more than one sugar-based ingredient, all those ingredients are grouped together in the ingredient list and are listed in descending order in parentheses after the word, Sugars/Sucres. Hence, the combined weight of all sugar-based ingredients decides the order that the Sugars group is listed on the ingredient statement. The objective is to help consumers see that sugars have been added to the food and understand how the amount of sugar added compares to other ingredients. In the pre-existing ingredient statement, sugar-based ingredients are listed separately in the ingredients list, making it difficult for consumers to understand that the total amount of sugars may be high. As to current regulation changes, ingredients designated as sugars must include all sugar such as white sugar, beet sugar, raw sugar or brown sugar or agave syrup, honey, maple syrup, barley malt extract or fancy molasses, as well as fructose, glucose, glucose-fructose/high fructose corn syrup, maltose, sucrose or dextrose, and fruit juice concentrates or purées concentrates that are added to replace sugars in foods.
 
Reference:
https://www.canada.ca/en/health-canada/services/technical-documents-labelling-requirements/directory-nutrition-facts-table-formats/nutrition-labelling.html#a1
http://www.healthycanadians.gc.ca/eating-nutrition/label-etiquetage/changesmodifications-eng.php
https://esha.com/wp-content/uploads/2017/02/ebook-health-canada-new-food-labelling-regulations.pdf
https://inspection.canada.ca/food-label-requirements/labelling/industry/food-labelling-requirements-checklist/eng/1393275252175/1393275314581
https://inspection.canada.ca/food-label-requirements/labelling/industry/label/eng/1388160267737/1388160350769
https://inspection.canada.ca/food-label-requirements/labelling/industry/general-principles/eng/1392324632253/1392324755688
https://inspection.canada.ca/food-label-requirements/labelling/industry/general-principles/eng/1392324632253/1392324755688