ARCHIVED - Record of Discussion (RoD) – November 6 - 7, 2014

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On November 6 and 7, 2014, members of consumer and health associations joined officials from the Canadian Food Inspection Agency (CFIA) for the eighth meeting of the Consumer Association Roundtable (CAR).

1. Welcome Remarks from the Chair

Presenter: Carolina Giliberti, Executive Vice-President, CFIA


  • To provide introductory remarks as the new Chair.
  • To review the meeting agenda and identify key areas of focus.

Key Points of Discussion:

  • The Chair introduced herself and provided an overview of her background and experience. She identified two areas of focus:


  • The CFIA is experiencing a culture shift.
  • The CFIA is working on internal communications to staff to make sure that they understand the transitions and that they are on board with transformation initiatives.
  • CFIA staff are committed to keeping food safe. The CFIA wants to continue this high level of staff dedication during and post-transformation.

Stakeholder engagement:

  • The CFIA learns by asking questions.
  • The CFIA must make sure we are connecting with the right people to gauge that the Agency is heading in the right direction.
  • The CFIA engages many different interest groups with very different opinions on how the Agency should conduct its business.
  • This Consumer Association Roundtable (CAR) provides key perspective on consumer issues.
  • The CFIA wants to make sure CAR is engaged on all Agency priorities and that the members' agenda meshes with that of the Agency.
  • The CFIA wants CAR members to know that CAR's views are being considered.
  • CAR members raised the following:
    • CAR members mentioned a problem of perceived inconsistent regulation, often in the critical area of food safety.
  • The Chair commented:
    • The regulatory function of the CFIA is not changing. As a regulator, the CFIA must make sure that the regulations for which it is responsible can be enforced.
    • The CFIA seeks the assistance of its partners to share important information and educate on compliance and enforcement.
    • The CFIA has many partners with different roles and responsibilities, and consumers play a big part.

2. Presentation: The Challenges of Food Allergy: What Consumers Need to Know

Presenter: Marilyn Allen, Food Allergy and Anaphylaxis Consulting


  • To provide an overview of some of the work being done by Anaphylaxis Canada and some of its emerging and ongoing concerns, including challenges regarding:
    • food labelling regulations;
    • precautionary statements such as "may contain" and "free from" labelling;
    • food service training.

Key Points of Discussion:

  • The importance for consumers to be able to separate accurate information from marketing on labels was stressed.
  • Enforcement: All domestic and imported products must be labelled as of August 4, 2014.
  • CFIA inspectors must understand the seriousness of undeclared allergens in food.
  • Consumers also need clear and complete information on recall notices, especially given the prevalence of imported foods in today's marketplace.
    • A concern was expressed that recalls are often designated Class III rather than Class II, but could still pose a risk for the general population with allergens.
  • Special concerns were expressed about beer labelling.
    • Beer labelling is a huge concern for consumers with allergies.
    • Anaphylaxis Canada wants allergens to be identified, but brewers are exempt under the law (standardized beer does not need to be labelled for allergens).
    • Brewers do follow current law by adhering to the regulations for the compositional standards of beer.
    • It is assumed beer does not need to label for wheat "because everyone knows wheat is in beer," and brewers want to be exempt from listing any additives or preservatives because they fall within the standard allowable regulations. However:
      • Sulphites are not being identified;
      • Levels of salt are not being identified;
      • Hazelnuts used during fermentation are not being identified;
      • Caramel is not being identified; and
      • Gelatin is not being identified.

Food labelling regulations:

  • There was a discussion about current regulations and declaration options, such as the ingredient list in common language on labels in parentheses or a "contains" statement, which must include all allergens in the product.
  • Reference was made to a consumer group study about product labelling on energy-efficient products. In that study, people wanted to know the authority behind the label because they did not know if they could trust the information being presented.
  • Consumers value controlled labelling and assume the government has made the product safe.
  • The need for further consumer education was reiterated regarding both the role of the consumer and CFIA enforcement.

Precautionary statements:

  • Health Canada recommends voluntary statement guidance for industry.
  • The risks and application of "may contain" statements on products was discussed, noting that the proliferation of "may contain" statements is vast and limits what consumers can choose to eat.
  • Precautionary statements such as "may contain" or "free from" require confirmation by a third-party audit.
  • The United Kingdom is looking at removing all "contains" statements because they have been found to be problematic.

Food service training:

  • More and continuing education is needed for the "halo" group: These are people who cook and prepare food for those who are at risk, primarily at daycares.
  • The "halo" group has been identified as a primary problem because these people tend to be less adept at reading information. They may not read all the ingredients.
  • Just looking at a "contains" statement is not enough (i.e. the product may appear to be peanut-free, but may not be tree nut-free, due to contamination).

3. CFIA Food Regulatory Modernization

Presenter: Lyzette Johnston, Domestic Food Safety Systems Division, CFIA


  • To provide an overview of the Safe Food for Canadians Act and proposed regulations;
  • To outline requirements for regulated parties;
  • To review consultation feedback; and
  • To discuss next steps/future issues.

Key Points of Discussion:

  • Current regulations and the planned streamlining of regulations under the Safe Food for Canadians Act was discussed.
  • Clarity is needed to explain what role the federal government plays.
  • Clarity is needed for consumers to explain what is covered and what is not.
  • It was reassuring for CAR members to hear that most large and medium companies are ready to comply, but there is a need for more education for small "mom and pop" shops.
    • Some in industry still need to be educated because they may not think the law applies to them.

Modernization and enhanced CFIA authority:

  • Much of Agency modernization and transformation pertains to licensing, food safety requirements and preventative control plans.
  • Federal establishments must be licensed to trade, import or export food.
  • CFIA inspectors now have the authority to see a company's preventative control plan.

Modernization and enhanced requirements for regulated parties:

  • Regulated parties would be required to:
    • Meet common food safety requirements (such as the CODEX Alimentarius [CODEX] international food standards, guidelines and codes of practice, which contribute to the safety, quality and fairness of the international food trade that Canada follows).
    • Put CODEX traceability in place by providing an address and identifying where ingredients come from.
  • The CFIA expects strong alignment with regard to Canada-United States Hazard Analysis Critical Control Point (HACCP) standards.

Modernization and enhanced guidance:

  • The CFIA has changed to a single food program, and its new guidance group is developing interpretive guidance.
  • The role between the CFIA's policy branch and inspectorate operations branch is changing – the policy side sets guidance and operations follows it. This is important to make sure the inspectorate is following regulations set by policy the same way across the country.
  • The CFIA is changing its approach to manuals with less emphasis on complicated documents and more focus on explaining what the regulations mean.
  • The CFIA is preparing plain-language model systems.
  • The CFIA is engaging in a learning partnership that includes large companies, food safety coalitions and academic institutions.

CAR members raised the following:

  • CAR members strongly support the CFIA's modernization agenda.
  • Concerns were raised about the ability of small business to comply.
  • CAR members stressed the importance of open consultations with consumers to get their feedback early in the process, and for consumers and consumer groups to have an idea of the government's long-term plans and timelines, so they may engage.
  • Interest was expressed in seeing the appeal process.

4. Health Canada Nutrition Labelling Consultation

Presenter: Dr. William Yan, Director of the Bureau of Nutritional Sciences, Health Canada


  • To provide an overview of the nutrition labelling review process;
  • To briefly describe the proposed changes to the nutrition facts table and list of ingredients that were the subject of consultation. The second consultation closed in September 2014; and
  • To provide an update on the current status of work, and next steps.

Key Points of Discussion:

  • Serving sizes were cited as confusing and the number one complaint of consumers.
  • Three approaches to sugar declarations were discussed:
    1. Added sugar declaration (same as the proposed US approach);
    2. Daily value (DV) for sugar (100 g of sugar potential DV); and
    3. Group all sugar-based ingredients added directly to food under the common name "sugar."
    • CAR members report that consumers overwhelmingly prefer the third approach.

Nutrition labelling review process:

  • A concern was raised that out of the 151 comments received from industry and associations, there appeared to be little consideration given to the report sent in from a CAR member.
  • The voices of smaller organizations need to be heard.

Nutrition Facts Table:

  • CAR members were pleased to see that the nutrition facts table is being made a higher priority.
  • CAR members strongly support the nutrition facts table, but stressed the need to educate consumers on the value of the label.
  • Consumers do pay attention to this information, so it is important for people to be able to read it.
  • Issues of legibility, the need for font sizes to be prescribed, as well as the overall size of the table with respect to the space available on the product were discussed.

5. Responding to Health Canada's Consultation on Nutrition Labelling

Presenters: Marie-Claude Mallet, Nutrition Manager – Health Check Program, Heart and Stroke Foundation of Canada and Pat Vanderkooy, Public Affairs Manager, Dietitians of Canada


  • To provide an overview of the nutrition labelling consultation feedback of the Heart and Stroke Foundation and the Dietitians of Canada, highlighting aspects that are of particular concern to dietitians and that would be of interest to Health Canada and the CFIA.

Key Points of Discussion:

  • CAR members raised a concern about a lack of advanced, direct notice when a consultation is about to take place.
    • Concerns were expressed that 60 days' notice does not provide sufficient time to effectively communicate with members and participate in the consultation.
  • The importance of considering consumers' rights and responsibilities with respect to food purchasing choices was discussed.
    • Consumers' rights were defined as reflecting individual civil rights.
    • Defining consumers' responsibilities was more nuanced, with no standard answer.
      • The diversity of the Canadian population must be considered.
      • Most people do not understand nutrition.
      • There is a need to consider who a label is going to help the most.

Nutrition information:

  • The information on packaging is crucial.
  • Consumers want information that is easy to read, valid and accurate, based on sound science.
  • Consumers want more information available online.
  • Health information is also important to public health educators.
  • There is need for a central website where dieticians can get more information.
  • There is a need to develop a framework to provide information for health professionals and consumers and to identify who would be responsible to deliver specific aspects.
  • CAR members expressed the opinion that they are not confident industry will proactively provide more information online on their own, and that the entire educational process needs the participation of government, industry and associations.

Nutrition Facts Table:

  • Dieticians have differing ideas about the nutrition facts table, its usefulness and how they view certain elements.
  • CAR members expressed their preference for the use of daily value (DV) for added sugars, versus total sugars, on the nutrition facts table.
  • The nutrition facts table needs to be accurate for healthier lives, and this accuracy must be monitored and enforced.

Label literacy and education:

  • Labelling changes need to be discussed in concert with education plans.
  • Health Canada is updating values that appear on labels to make them scientifically sound, but it is important for consumers to be able to understand the information.
  • The presenting groups propose to focus educational efforts to build consumer awareness and understanding of important areas of labelling change (the addition of added sugars, etc.).

6. Update on the Food Labelling Modernization Initiative

Presenter: Luc Rivard, Director, Consumer Protection and Market Fairness Division, CFIA


  • To provide an update on progress to date on the food labelling modernization initiative and seek views on key issues; and
  • To provide information on what we plan to consult on in the second phase of food labelling modernization engagement, including the development of a plan to modernize food standards.

Key Points of Discussion:

  • CFIA is working to release summary reports for four areas of responsibility:
    • regulations;
    • roles and responsibilities;
    • service delivery; and
    • program and policy development.
  • The next phase is being prepared with early recommendations that will be shared with CAR members during the consultation.
  • The CFIA is sensitive to CAR members' needs and wants them to have enough time to prepare for the consultations.


  • In 2014, the Government of Canada announced the modernization of beer standards, as well as a plan to modernize all food standards under the Food and Drug Regulations.
  • The Agency, in close collaboration with Health Canada, is developing a plan on how to modernize the food standards found in the FDR; the beer standard is already under consultation with stakeholders.

Labelling and shared responsibility:

  • The CFIA consultation is designed to obtain many viewpoints from all impacted stakeholders and generate consensus where possible.
  • The CFIA is aiming to revise the labelling framework, not only in terms of regulations, but also in reviewing consumer, industry and government roles and responsibilities.
  • Part of the changing roles and responsibilities should enable industry and consumers to take greater part in program and policy development.
  • Consumers also need to be invested as they share in the responsibility.

7. Discussion: Communications activities and sharing of CFIA information with CAR

Presenters: Geneviève Desjardins, Vice-President, CFIA Communications and Public Affairs (CPA), and Bryan Blom, Issues Communications Manager, CPA, CFIA


  • To provide a brief overview of the role of the CPA Branch in the recall process; and
  • To discuss how the CAR members can help expand the reach of recall and allergy alerts to consumers.

Key Points of Discussion:

  • Geneviève Desjardins, Vice-President, CPA, identified three goals:
    • More proactive communication and more risk communication;
    • Compliance promotion with industry (more in-person communication); and
    • Crisis management (establishing partnerships to communicate with industry and consumers).

Communicating recalls:

  • The CFIA continually aims to communicate better with the public.
  • The CFIA is looking for new and better ways to reach Canadians.
  • The CFIA seeks to determine how to work with the CAR members to spread the message when recalls occur.
  • CAR members raised the following:
    • CAR members expressed that they believe there is too much information from the CFIA to media in terms of recalls. Less "noise" would mean more pickup.
    • However, CAR members also noted that an information gap exists with respect to Class III recalls, and called for a better partnership to provide that information because some consumers want it.
    • There is value in allowing people to decide which messages they receive so there is not as much "noise." CAR members have their own databases, and consumers come to them for specific information.
    • CAR members noted that most of the recalls are allergy-related.
    • CAR members expressed that CFIA communications tell consumers to go to their shelves, check the product and throw it out.
    • CAR members believe that industry should tell consumers to throw out recalled products.
    • CAR members commented that the ability to scan a product and see if it's been recalled would be helpful to the consumer.

Recall process and communications:

  • Recalls originate from the CFIA or industry when a problem is discovered.
  • If a recall originates from the CFIA, the Agency should be notifying consumers directly. People should get information from the CFIA, not another organization.
  • Since all are concerned about health and safety of Canadians, there is a need to expand collective dissemination of information.
  • CAR members were asked if associations can communicate CFIA messages to members.
  • CAR members raised the following:
    • Members commended the CFIA on efforts to improve the health and safety of Canadians, and recent improvements and use of social media to share information.
    • There was discussion concerning retailers' responsibilities to post information about recalls and possibly having regulations to enforce this.
    • CAR members are happy to work with the CFIA. CAR members are willing to communicate recalls that could affect its readership, by re-tweeting and re-sending CFIA emails.
    • Research has shown that consumers tend to trust associations more than government, but it costs money to communicate with the public. CAR members have media contacts and corporate sponsors who can help with disseminating information. However, this requires a paid staff position to send out all of the CFIA's recall notices.
    • CAR members expressed the opinion that advertising about recalls should be paid by industry, not from consumers/taxpayers.


  • With respect to the broader discussion about communicating recalls with the public, the CFIA recapped that filtering notices is very important, use of public notices should be considered in order to get the message out, and there should be more focus on partnerships.
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