ARCHIVED - Food labelling modernization

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Purpose

  • To provide you with an overview of the Food Labelling Modernization (FLM) initiative, specifically scope, objectives, engagement strategy, schedule, and next steps, as it relates to the Canadian Food Inspection Agency's (CFIA) Change Agenda
  • To obtain your views on:
    • issues on food labelling you may have already raised and would like to restate, and
    • additional issues and comments you may have in the key areas of:
      • roles and responsibilities as it pertains to consumers, industry and government
      • labelling regulations
      • policy and program development and service delivery

CFIA's change agenda

  • The CFIA has embarked on a change and modernization agenda, propelled by the new Safe Food for Canadians Act (SFCA), with a focus on: stronger food safety rules; more effective inspection; commitment to service; and more information for consumers.
  • The SFCA is the cornerstone of CFIA's sweeping change agenda, that will help bring about legislative change aimed at promoting safer food and better protection to optimize the health and safety of Canadians and make Canadian businesses more competitive globally. Key change agenda initiatives include:
    • Inspection Modernization;
    • Food Regulatory Modernization;
    • Food Safety Action Plan's Import Licensing;
    • Compliance Promotion; and
    • Food Labelling Modernization

Shared responsibility for food labelling (at the federal level)

At the federal government level, the responsibility for food labelling requirements is shared between:

  • Health Canada
    • Establishes policies, regulations and standards relating to the health, safety and nutritional quality of food sold in Canada.
  • Canadian Food Inspection Agency
    • Enforces the policies and regulations that are developed by Health Canada.
    • Administers and enforces non-health and safety policies and regulations.

Some of the key challenges in food labelling

As it relates to voluntary claims:

  • CFIA has seen increased usage of voluntary non-health and safety claims by industry
  • CFIA is also being asked to respond more and more to company-to-company labelling complaints in this area
  • CFIA has seen focused media attention on these types of claims, which has increased consumers' awareness and their expectations of companies, the industry and CFIA
  • Consumers are also expecting more transparency and action from both industry and government
  • CFIA recognizes that in this area there are diverse views on the respective roles of consumers, industry and government
  • A number of countries are exploring different ways of responding to these types of non-health and safety claims and redefining the roles and responsibilities of consumers, industry and government

Food labelling modernization objectives and focus

Objectives:

  • Develop a modern and innovative food labelling system within the context of CFIA's priorities and vision and which aligns with the new Safe Food for Canadian's Act and that
    • Provides a better understanding of roles and responsibilities and continuous improvement as it relates to partnerships with other government departments such as Health Canada and with consumers and industry
    • Appropriately responds to consumer and industry needs around food labelling within CFIA's mandate
    • Promotes smarter regulations and risk-based oversight by Government
    • Improves service delivery such as in relation to inquiries and availability of labelling information and tools

Focus:

  • Will include all foods, as well as the review of CFIA food labelling frameworks and regulatory, program design and delivery systems
  • Will not include food labelling activities that fall under the mandate of other government departments (for example: Health Canada)

Key areas of focus for the FLM consultation

FLM vision: to design an innovative and modern food labelling system, trusted and respected by Canadians and the international community.

Area of focus

  1. Roles and responsibilities
    • Outcome: Improve compliance by effectively balancing the roles and responsibilities between consumers, industry, and government.
  2. Regulations
    • Outcome: Better protect consumers and support industry innovation by strengthening the regulatory framework, while considering global standards and approaches.
  3. Policy and program Development
    • Outcome: Improve compliance by developing effective policies and programs; that are based on risk; facilitate partnerships and support consistency.
  4. Service delivery
    • Outcome: Improve service delivery by applying standardized inspection approaches based on risk and prevention, and supported by appropriate services and tools.

Overall focus:

  • It will include all foods, as well as CFIA food labelling frameworks and regulatory, program design and delivery systems.

Examples:

In focus:
All food – including imported, domestic, retail; consumer packaged or bulk, further manufacturing

Roles, responsibilities and partnerships

In focus:
Examining the roles and responsibilities that consumers, industry and government play in food labelling within the CFIA's mandate

Regulations

In focus:
  1. Labelling regulations under CFIA's responsibility
    • list of ingredients
    • placement of information
    • standards of identity
    • ingredient class names
    • grade marks
    • net quantity
    • best before date
    • common name
    • type size
    • dealer name and address
  2. Administering labelling requirements for imported and domestic products that fall under CFIA responsibility in the following legislation:
    • Food and Drugs Act/Food and Drug Regulations
    • Consumer Packaging and Labelling Act/Consumer Packaging and Labelling Regulations
    • Meat Inspection Act/Meat Inspection Regulations
    • Fish Inspection Act/Fish Inspection Regulations
    • Canada Agricultural Products Act and its regulations

Policy and program development

In focus:
  1. Examining policies and guidelines that are within the mandate of the CFIA, and that:
    • no longer respond to industry and consumer needs,
    • contain gaps, or
    • are not harmonized with international standards or agreements
  2. Examining CFIA's process for developing and delivering policies, programs and frameworks.

Service delivery

In focus:
  1. Examining inspection activities and tools related to labelling and advertising of food under the responsibility of the CFIA
    • inspection approach and strategy
    • training materials
    • Information Management /Information Technology tools
    • guidance materials (for example: Guide to Food Labelling and Advertising, Nutrition Labelling Toolkit)
    • labelling website information
  2. Enforcing labelling requirements for imported and domestic products as they pertain to:
    • Food and Drugs Act/ Food and Drug Regulations
    • Consumer Packaging and Labelling Act/Consumer Packaging and Labelling Regulations
    • Meat Inspection Act/Meat Inspection Regulations
    • Fish Inspection Act/Fish Inspection Regulations
    • Canada Agricultural Products Act and its regulations

Out of focus:

  • Does not include food labelling activities that fall under the mandate of other government departments (such as Health Canada).

Examples:

Out of focus:

  • Food for export/ sale outside of Canada

Roles, responsibilities and partnerships

Out of focus:

  • Transferring legislated responsibilities to other government departments

Regulations

out of focus:
  1. Examining labelling regulations under Health Canada's responsibility
    • nutrition labelling and health claims requirements
    • food additives
    • allergen labelling requirements
    • fortification
    • genetically modified foods , novel foods
    • foods for special dietary use
    • food safety related labelling requirements
    • aspartame and sugar alcohols
  2. Labelling regulations under other government department's responsibility, for example:
    • Industry Canada
    • Office of the Official Languages
    • Competition Bureau
    • Measurement Canada
  3. Examining recently developed or revised labelling regulations under CFIA's responsibility,for example:
    • Organic Products Regulations
    • icewine standard
    • cheese regulatory amendments
  4. Examining labelling regulatory changes under CFIA's responsibility that would make them inconsistent with international standards such as the Codex General Standard for the Labelling of Prepackaged Foods
  5. Examining regulations and policies under CFIA responsibility that are not related to labelling of food, for example:
    • animal and plant health
    • microbiological standards
    • agricultural inputs (for example: feed, fertilizers)
  6. Examining labeling regulations and policies under provincial and territorial responsibility, for example
    • provincial standards and requirement
      • Nova Scotia Liquor Standards Corporation
      • Ontario Milk Act
  7. Requirements for bilingual labelling
  8. Metrification in relation to net quantity declaration

Policy and program development

out of focus:
  • Examining policies and guidelines that are outside the mandate of the CFIA

Service delivery

out of focus:
  1. Examining inspection activities and tools under CFIA responsibility that are not related to labelling of food, such as related to:
    • animal and plant health
    • microbiological standards
    • agricultural inputs (for example: feed, fertilizers)
  2. Labelling Recipe and Registration Unit

Engagement strategy for FLM

Objective:

  • Identify and analyze issues that will lead to development of recommendations for a more modern and innovative food labelling system

Strategy:

  • 2-phased consultation approach focusing on consumers, industry, government—aiming to achieve a balanced perspective
  • First phase to focus on issues identification
  • Second phase will engage on potential recommendations for modern and innovative food labelling system
  • Will use various approaches to engagement: discussion paper, online questionnaire, face-to-face listening sessions

Overview of food labelling modernization – Timeline

Click on image for larger view
Overview of food labelling modernization – Timeline. Description follows.

Description for image - Overview food labelling modernization - Timeline

The image illustrates the timelines for the food labelling modernization initiative.

June to December 2013 is stage 1: Launch, engage and gather issues

  • the Safe Food for Canadians Act will influence food labelling modernization and other CFIA Change agenda initiatives
  • the anticipated outcome from this stage will be issues gathered and engagement completed

January to May 2014 is stage 2: Analyze Data and Draft recommendations

  • the anticipated outcome from this stage will be approval of draft recommendations

June to November 2014 is stage 3: Engage on draft recommendations and analyze data

  • the anticipated outcome from this stage will be completed engagement

December 2014 to June 2015 is stage 4: Finalize report on recommendations and implementation proposal

Path forward

  • Compile the information received from this forum and include it with other stakeholder feedback we received
  • Communicate with stakeholders (for example: via e-mail and the FLM webpage) about upcoming engagement opportunities
  • Continue to align with other CFIA Change Agenda initiatives (for example: Regulatory Modernization, Importer Licencing) to co-ordinate engagement and share information

Food labelling continuum and FLM areas of focus: food for thought

Click on image for larger view
Food labelling continuum and Food Labelling Modernization areas of focus: food for thought Description follows.

Description for image - Food labelling continuum and FLM areas of focus: food for thought

This diagram is designed to provide food for thought for discussion. Itillustrates the food labelling continuum and the areas of focus for the food labellingmodernization initiative:

  • the roles, responsibilities and partnerships
  • program development
  • service inspection (with the example of inspection)
  • regulations
  • policy development

The types of issues in the labelling continuum vary in terms of their risk to health and safety, from those of higher risk to lower risk. This includes areas related to food safety (such as allergens), preventative health (nutrition information and claims), product composition (highlighted ingredients) and consumer values (non-health and safety related such as natural claims).

Questions

  1. What are the specific regulations within the CFIA mandate that require attention in order to modernize food labelling? Are there any gaps?
  2. With respect to policy/program development and service delivery, what are the key issues that affect you regarding inspection, guidance, tools and IM/IT?
  3. Considering the scope of the inspection and food labelling modernization initiatives (specifically those areas related to non-health and safety consumer values, for example, claims on: natural, local, method of production),
    • What primary challenges or gaps do you observe, as it relates to roles and responsibilities of consumers, industry and CFIA?
    • How can we collectively modernize these roles?

Please send any comments you may have:

  • By email: CFIA-Modernisation@inspection.gc.ca
  • By mail:

    Strategic Partnerships Division
    1400 Merivale Road, Tower 1
    Floor 6, suite 218
    Ottawa, ON K1A 0Y9
    Canada
    Attn: Food labelling modernization

  • By fax: 613-773-5606

Annex 1: Drivers for food labelling modernization

Consumers – drivers

Changes in consumer demand

  • Consumers are becoming more aware and knowledgeable about labels on products, to ensure that products meet their needs (e.g. health and safety; getting best value for money)
  • Higher consumer expectations and increased media attention around labelling requires improved transparency and accountability

Consumer – issues

  • Safety
  • Public health
  • Marketplace Deception
  • Country of Origin
  • Quality
  • Legibility and consistency of information
  • Knowledge of roles and responsibilities of government and industry

Industry – drivers

Global supply chains have significantly changed the way in which products are processed, produced, packaged and sold

  • Manufacturers are finding more innovative and creative ways to communicate their products to consumers
  • Food processing industry has become more competitive to meet consumers' needs

Industry – issues

  • Level playing field for domestic and imported products
  • Market access
  • Ability to innovate
  • Modernized regulations to keep up with ingredients and technology
  • Consistency of policy interpretation andenforcement
  • Timeliness and coordination
  • Common names
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