Food Labelling Requirements
The following basic food labelling requirements are discussed in this Chapter:
- Common name,
- Net quantity declaration,
- Dealer name and address,
- List of ingredients (including food allergens),
- Nutrition Facts table, and
- Durable life date.
2.1 Definitions [B.01.001; 2, FDA; 2, CPLA]
"Prepackaged product" means any food that is contained in a package in the manner in which it is ordinarily sold to or used or purchased by a person" [B.01.001]
"Label" includes any legend, word or mark attached to, included in, belonging to or accompanying any food, drug . . ." [2, FDA]
"Prepackaged product" means any product that is packaged in a container in such a manner that it is ordinarily sold to or used or purchased by a consumer without being re-packaged"[2, CPLA]
"Label" means any label, mark, sign, device, imprint, stamp, brand, ticket or tag [2, CPLA]
2.2 General Labelling Requirements [5(1), FDA; A.01.016, B.01.005 to B.01.008; 14 to 16, CPLA]
All of the information on food labels must be true and not misleading or deceptive, and the required information must be:
- Easily read and clearly and prominently displayed (with a recommended minimum type height of 1.6 mm (1/16 inch), based on the lowercase letter "o", unless otherwise specified); and
- On any panel except the bottom, except for the information required to
appear on the principal display panel.
Note: In certain cases, such as the Nutrition Facts table and the Durable Life Date, information may appear on the bottom panel in some instances (see 2.11.1 and Chapter 5 of this Guide for details).
2.3 Foods Requiring a Label [B.01.003; 4, CPLA ]
All prepackaged products require a label with the following exceptions:
- One-bite confections, such as a candy or a stick of chewing gum, sold individually; and
- Fresh fruits or vegetables packaged in a wrapper or confining band of less than 1/2 inch (12.7 mm).
Note: Clerk-served foods which are packaged at the time of sale are not considered to be prepackaged foods and are therefore exempt from having a label.
2.4 Bilingual Requirements [B.01.012, B.01.054; 6,CPLR]
All mandatory information on food labels must be shown in both official languages, i.e., French and English, with one exception:
- The identity and principal place of business of the person by or for whom the prepackaged product was manufactured, processed, produced or packaged for resale, may be in either English or French.
In addition, all information on the labels of the following may be in one official language only:
- Shipping containers that are not offered for sale to consumers;
- Local products sold in a local area in which one of the official languages is the mother tongue of less than 10 percent of the residents;
- Official test market products (see 2.16, Test Market Foods); and
- Specialty foods, as defined by the Food and Drug Regulations.
The province of Quebec has additional requirements concerning the use of the French language on all products marketed within its jurisdiction. Information on these requirements can be found on the Website of l'Office de la langue française: http://www.oqlf.gouv.qc.ca/
2.5 Common Name [B.01.001, B.01.006; 10, CPLA ]
The common name of a food is:
- The name prescribed by the FDR, e.g., "orange juice from concentrate", "60% whole wheat bread", "milk chocolate", "mayonnaise"; or
- The name prescribed by any other federal regulation, e.g., mixed vegetables, breakfast sausage; or
- When not prescribed by regulation, the name by which the food is commonly known, e.g., orange drink, vanilla cookies, chocolate cake.
When a prescribed common name for a food is used, the product must meet the compositional standard established for the food by the applicable regulation. Conversely, when a food meets a prescribed compositional standard, the prescribed common name, when there is one, must be used.
The common name must be shown on the principal display panel of the food label (i.e., main panel) in both French and English, with a minimum type height of 1.6 mm (1/16 inch), based on the lowercase letter "o".
The common name must not be misleading. For example:
- It should not incorporate words unwarranted by the composition of the food.
- It should not improperly suggest a place of origin.
- It should not resemble, directly or phonetically, the name of another product for which it is an imitation or substitute.
Abbreviations, including initials, should not be used if they lead to deception. Generally, the Food and Drug Regulations and the Consumer Packaging and Labelling Regulations do not permit the use of abbreviations to provide mandatory labelling information except where specified in the regulations or policies.
2.6 Net Quantity [4, CPLA; 14 and 18, CPLR; 9, Weights and Measures Act; 46 to 48, Weights and Measures Regulations]
Prepackaged products must have a net quantity declaration with the following exceptions:
- Prepackaged individual servings of food prepared by a commissary and sold in automatic vending machines or mobile canteens;
- Prepackaged individual portions of food that are served by a restaurant, airline, etc. with meals or snacks;
- Certain products (called catchweight products) which, due to their nature, cannot be packaged to a predetermined weight (e.g., turkeys, meat cuts, etc.) and are sold to a retailer by a manufacturer. The retailer is responsible for applying the net quantity declaration prior to offering the food for sale.
The CPLA and CPLR require net quantity declarations on labels of foods packaged for consumers and prescribe how the declaration must appear. The Weights and Measures Act and Regulations require a declaration of net quantity for foods that have not been prepackaged for retail sale (i.e., those foods not covered by the CPLA).
A minimum type height of 1.6 mm, based on the lowercase letter "o", is required for all information in the net quantity declaration, except for the numerals which are to be shown in bold face type and in the size shown in the following table.
2.6.1 Minimum Type Height for Net Quantity [14, CPLR]
means less than or equal to
> means greater than
|Area of Principal Display Surface||Minimum Type Height of Numerals|
|square centimetres||square inches||millimetres||inches|
|> 32 to 258||> 5 to 40||3.2||1/8|
|> 258 to 645||> 40 to 100||6.4||1/4|
|> 645 to 2580||> 100 to 400||9.5||3/8|
|> 2580||> 400||12.7||1/2|
The net quantity must be declared in metric units on the principal display panel on consumer packages in both French and English. The following metric symbols are considered to be bilingual (and should not be followed by any punctuation):
g – for grams
kg – for kilograms
ml, mL or – for millilitres
l, L or – for litres
In general, the net quantity must be indicated [21, CPLR]:
- By volume for liquids; e.g., millilitres, or litres (for amounts more than 1000 ml);
- By weight for solids; e.g., grams, or kilograms (for amounts more than 1000 g); or
- By count for certain foods, such as candied apples.
The net quantity must be rounded to three figures, unless the net quantity is below 100, when it may be rounded to two figures.
453.59 becomes 454
85.6 becomes 86
6.43 becomes 6.4
2.6.2 Canadian Units of Measure [17, CPLR]
Although Canadian (previously named "Imperial") units of measure are not required on labels, they are permitted to be used in addition to the required metric units. When the net quantity is shown in both metric units and Canadian units, the metric units should be declared first and the two must be grouped together on the label with no intervening material.
The Canadian units "fluid ounces" and "ounces" are not interchangeable terms. For example, fluids such as juices and soft drinks must always be described as "fluid ounces" rather than "ounces". The following conversions may be used:
1 fl oz Canadian = 28.413
1 oz = 28.350 g
U.S. (American) units of measure may also be used on labels provided an appropriate and accurate metric net quantity is declared. The U.S. fluid ounce is slightly larger than the Canadian fluid ounce and, if shown, does not need to be identified as "U.S.".
The following conversion factors may be used:
1fl oz U.S. = 1.041 fl oz Canadian = 29.574 ml
U.S. fluid measures, other than the U.S. fluid ounce, are smaller than Canadian measures and must be identified as "U.S." on the label. Non metric declarations (e.g., fluid ounces, pounds, quarts, etc.), if shown, may be in English or French.
2.7 Name and Address [B.01.007; 10, CPLA; 31, CPLR]
The name and address of the responsible party by or for whom a prepackaged product is manufactured or produced, must be declared on any part of the food container except the bottom, in a minimum type height of 1.6 mm (1/16 inch) based on the lowercase letter "o", in either French or English. The address must be complete enough for postal delivery within a reasonable delay.
When a product packaged for sale to consumers has been wholly produced or manufactured outside of Canada, and the label carries the name and address of a Canadian dealer, the terms "imported by/importé par" or "imported for/importé pour" must precede this address, unless the geographic origin of the product is placed immediately adjacent to the Canadian name and address.
2.8 List of Ingredients [B.01.008, B.01.010]
Prepackaged multi-ingredient foods require an ingredient list, with the following exceptions:
- Prepackaged products packed from bulk at retail (except for mixed nuts and meat products packed by a retailer which contain phosphate salts and/or water: these products do require an ingredient list);
- Prepackaged individual portions of food served with meals or snacks by restaurants, airlines, etc. (e.g., coffee creamers, ketchup, etc.);
- Prepackaged individual servings of food prepared by commissaries and sold in mobile canteens or vending machines;
- Prepackaged meat, poultry and poultry meat by-products barbecued, roasted or broiled on the retail premises; and
- Standardized alcoholic beverages and vinegars.
In general, ingredients must be listed in descending order of proportion by weight, as determined before they are combined to make the food. The exceptions are spices, seasonings and herbs (except salt), natural and artificial flavours, flavour enhancers, food additives, and vitamin and mineral nutrients and their derivatives or salts, which may be shown at the end of the ingredient list in any order. The ingredient list must be shown in both English and French unless otherwise exempted by the Food and Drug Regulations [B.01.012].
- Ingredients and their components (ingredients of ingredients) must be declared by their common names in the list of ingredients on a food label.
- To assist consumers in making informed food choices, specific mandatory common names are required for certain food products when they are used as food ingredients or components. The plant source of certain ingredients, such as hydrolyzed plant proteins, starches, modified starches and lecithin must be named. (e.g., hydrolyzed soy protein, wheat starch, modified wheat starch, soy lecithin). (See Mandatory Common Names of Ingredients and Components, Annex 2-1 of this Guide).
- Certain foods and classes of foods, when used as ingredients, may be listed by collective or class names. (See Class Names for Ingredients, Annex 2-2 of this Guide.)
- When preparations of vitamins, mineral nutrients, food additives and flavour enhancers, are added to foods, these must be shown in the list of ingredients by the common name of the active ingredient(s) present, e.g., vitamin A palmitate. Yeast preparations may be declared as "yeast".
Components (ingredients of ingredients) must be declared as part of the list of ingredients. They can be shown either:
- In parentheses following the ingredient name in descending order of proportion by weight in the ingredient, except if a source of food allergen or gluten is required to be declared, then the components are immediately after source declarations. Both declarations are required to be shown in parentheses after the ingredient name; or
- In descending order of proportion by weight in the finished food as if they were ingredients, without listing the ingredient itself.
Many foods, when used as ingredients in other foods, are exempt from a declaration of their components. (See Ingredients Exempt from Component Declaration, Annex 2-3 of this Guide.) However if any exempt components consist of food allergens, gluten sources or sulphites (at 10 ppm or more), the allergen, gluten source or sulphites must be declared. They may be declared in the list immediately in parentheses after the ingredient which they are components of or in the "Contains" statement immediately following the list of ingredients. If nutrient components are also required to be declared by section D.01.007(1)(a) and D.02.005, the nutrient components should be declared in separate brackets after the allergen, gluten source or sulphite declarations. For example: enriched flour (wheat)(niacin, thiamine, riboflavin, iron) or wheat flour (niacin, thiamine, riboflavin, iron). For more information, please refer to "Food Allergies and Allergen Labelling Information for Industry".
Certain food preparations and mixtures, including flavours and seasonings, when used as ingredients, are exempt from a declaration of most of their components. (See Component Declarations, Annex 2-4(a) of this Guide) The components which, if present, must be declared as if they were ingredients include salt, monosodium glutamate, hydrolysed plant protein, aspartame, potassium chloride and any components which perform a function in, or have an effect on the final food, e.g., flavour enhancers. (See Component Declarations, Annex 2-4 of this Guide, sections (b) and (c).)
2.8.3 Food Allergen and Gluten Source and Added Sulphite Labelling [B.01.010.1, B.01.010.2, B.01.010.3]
On February 16, 2011, amendments to the Food and Drug Regulations, were published in the Canada Gazette, Part II prescribing enhanced labelling requirements for food allergen, gluten sources and sulphites. The new requirements will come into force on August 4, 2012. Although the new regulations do not come into force until August 4, 2012, companies may start using the new requirements to prepare new food labels prior to that date. The current requirements are still applicable. However any undeclared food allergens deemed to be a health risk, may be subject to the Canadian Food Inspection Agency enforcement action including recalls.
For more information, please refer to "Food Allergies and Allergen Labelling Information for Industry".
A food processing aid is a substance that is used for a technical effect in food processing or manufacture, the use of which does not affect the intrinsic characteristics of the food and results in no or negligible residues of the substance or its by-products in or on the finished food. Note that food additives are not processing aids.
For more information on food additives and processing aids, please refer to Health Canada's Policy for Differentiating Food Additives and Processing Aids at www.hc-sc.gc.ca/fn-an/pubs/policy_fa-pa-eng.php.
The substances listed in Table 2-1 below which are added to a food during processing for a "processing aid" function are not considered food ingredients, and are not required to be declared in the list of ingredients.
|1.||Hydrogen for hydrogenation purposes, currently exempt under B.01.008|
|2.||Cleansers and sanitisers|
|3.||Head space flushing gases and packaging gases|
|4.||Contact freezing and cooling agents|
|5.||Washing and peeling agents|
|6.||Clarifying or filtering agents used in the processing of fruit juice, oil, vinegar, beer, wine and cider (The latter three categories of standardized alcoholic beverages are currently exempt from ingredient listing.)|
|7.||Catalysts that are essential to the manufacturing process and without which, the final food product would not exist, e.g., nickel, copper, etc.|
|8.||Ion exchange resins, membranes and molecular sieves that are involved in physical separation and that are not incorporated into the food|
|9.||Desiccating agents or oxygen scavengers that are not incorporated into the food|
|10.||Water treatment chemicals for steam production|
The Nutrition Facts table provides information on energy (Calories) and thirteen nutrients, based on a serving of stated size. The Nutrition Facts table must appear on the label in the prescribed manner. Refer to Chapter 5 - Nutrition Labelling for detailed information on the presentation of the Nutrition Facts table and those situations where a product is exempt from this requirement.
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