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Guidelines for Highlighted Ingredients and Flavours

This page has been archived

These guidelines are under review while marked as Archived Content. See Highlighted Ingredient Claims for the current policy.

Purpose

The purpose of this document is to provide guidance to clarify existing requirements and policies on the use of highlighted ingredient or flavour claims on a label or advertisement to promote truthful and not misleading labelling. This will result in meaningful information for consumers and promote a level playing field for industry.

Legislation

The Guidelines for Highlighted Ingredients and Flavours (Guidelines) are to provide guidance with regards to the Food and Drugs Act (FDA), subsection 5.(1) and the Consumer Packaging and Labelling Act (CPLA), subsection 7(1) which prohibit the labelling of products in a manner which is false, misleading or deceptive or is likely to create an erroneous impression. It does not take precedence over specific Canadian federal or provincial legislation. Depending on the situation, there could be other applicable legislation, such as section 34 of the Consumer Packaging and Labelling Regulations (CPLR) concerning pictorial representations of flavours on labels. When legislation mandates a specific common name or other highlighting information, the Guidelines for Highlighted Ingredients and Flavours are neither triggered nor may they be applied in place of the mandated name or information. Additionally, for non-standardized foods, applying the Guidelines does not guarantee the common name will adequately describe the product.

Definitions

Highlighted Ingredient: An ingredient, component, class of ingredients, or flavour in a food, which has its presence suggested or emphasized through the use of words, pictures or graphics.

The definition for "highlighted ingredient" applies to foods as defined by the FDA. It includes ingredients, components of ingredients and classes of ingredients viewed as valuable, beneficial or otherwise desirable for the common food purposes of satisfying hunger, thirst, taste or texture modification but, for the purposes of these guidelines, does not include herbs/spices and seasoning ingredients such as leeks, onion, garlic, hot peppers, etc. (when added for seasoning), nutrients, phytochemicals (whether added or naturally occurring) or products regulated as natural health products.

Similar Ingredient: A non-highlighted ingredient, component or group of ingredients present in a food that belongs to the same class or has some of the same characteristics as the highlighted ingredient. It is added for the same purpose or to fulfill at least one of the primary functions of the highlighted ingredient such that a similar ingredient can generally replace the highlighted ingredient to form the same food (Also see section 5 of Annex 1 on Other Functions and Incidental Additions).

The following are examples of ingredients that could be considered similar ingredients when an ingredient has been highlighted: (Note: the list is not exhaustive).
Highlighted Ingredient Examples of Ingredients that could be considered Similar Ingredients
Peaches, such as dried, frozen, pureed, etc. Other fruits such as fresh strawberries, frozen cherries, dried apples, pear puree, apple pieces, etc.
Berries Other non-berry fruits
Blueberry juice Other reconstituted or concentrated juices, purees, water/sugar/blueberry flavour preparations, etc.
Beef Pork, chicken, extended meats, simulated meats
Rolled oats Cereals and cereal type products such as buckwheat, rice flour, wheat flour, corn, soy
Whole grains Non-whole grain such as bran, flour, starch or maltodextrin (except when present at low levels for functional reasons, see section 5 of Annex 1 for more information).
Ancient grains (Kamut, Quinoa) Whole wheat flour, white flour, other grains
Brown Sugar Sweetening agents such as sugar, honey, glucose syrup, maple syrup, sucralose, and other food additive sweeteners, brown sugar flavour. (See section 6 of Annex 1 for special considerations on honey and maple)
Butter Margarine, vegetable oil, lard, shortening, ghee, etc.
Mozzarella cheese Cheddar and other varietal cheeses, cheese-like dairy products, vegetable-based loaves, fortified vegetable-based loaves, cheese powder.
Chocolate Cocoa, carob, etc. (See section 6 of Annex 1 for more information on chocolate)

Imitation Ingredient: A subset of similar ingredients; these foods are specifically manufactured to have the same physical appearance as the highlighted ingredient. Note that for liquids, colour on its own does not constitute an imitation ingredient (e.g. When mango juice has been highlighted on a juice, an added orange juice is considered a similar ingredient, not an imitation).

The following are examples of ingredients that could be considered not only similar ingredients, but also imitation ingredients when the real ingredient is highlighted on a vignette or in a statement (Note: the list is not exhaustive).
Highlighted Ingredient Examples of Ingredients that could be considered Imitation Ingredients
Peach pieces Composite product (consisting of sugar, flavour, starch and gelling agents), peach colored (could be flavoured) fruit/vegetable bits (other than peach).
Chocolate chips Carob chips, compound chips, cocoa flavoured palm oil chips
Crab Kamaboko
Mozzarella cheese Any other white cheese that could be mistaken for mozzarella (White cheddar, etc.)
Beef Simulated or natural red meats that look like beef

Highlighting

It is common for labels and advertisings to include claims that highlight ingredients or flavours, such as "made with fruit" or "cherry flavoured ice cream". When truthful and not misleading, this is valuable information for consumers, allowing them to choose between products based on attributes of importance to them. However, when highlighting ingredients, care must be taken not to over-emphasize the importance, presence or absence of an ingredient or substance in a food because of its desirable or undesirable qualities, or for any other reason [Highlighted Ingredient Claims]. Areas of concern, which are addressed in these guidelines, include substitution, over-emphasis and misrepresentation of flavours.

Substitution
Substitution occurs when an imitation ingredient in present in a food to replace a genuine ingredient. Any name or description on the label must not lead consumers to conclude that the imitation or substitute is genuine [Negative claims pertaining to the absence or non-addition of a substance]. Examples of highlighting of this type are when an imitation ingredient is visible in the product at the time of sale and suggests the presence of the genuine ingredient.
Over-Emphasis
Over-emphasis occurs when a highlighted ingredient is either present at very low level or at least partially replaced by a similar ingredient in the food, giving an erroneous impression the highlighted ingredient is present in a higher amount than it really is. In principle, any emphasis regarding the presence of an ingredient, component or substance should be accompanied by a statement regarding the amount of that ingredient, component or substance present in the food [Highlighted Ingredient Claims].
Misrepresentation of flavours
Misrepresentation of flavours occurs when flavours or very small amounts of ingredients are added for the purpose of flavouring but representation (through claims or vignettes) creates an impression that either the actual ingredient was added (rather than a flavour) or there is more of the ingredient in the food than is actually the case (over-emphasis).

The following figure breaks down the different compositional conditions and provides guidance on how to present information on the attributes of the food to consumers without misleading on the composition, to promote compliance with the relevant sections of FDA and CPLA. It should be noted that other options can be used to clarify highlighting, such as declaring a percentage of the highlighted ingredient.

Image - Guidance on providing clarifying information when substitution, over-emphasis or misrepresentation of flavours occurs. Description follows.
Description for photo - Guidance on providing clarifying information when substitution, over-emphasis or misrepresentation of flavours occurs

When any amount of imitation ingredients are used, the common name of the imitation ingredient should be part of the claim or common name of the food.

When the combined weight of similar and highlighted ingredients represents the majority of the food and the highlighted ingredient is present in a higher amount than each similar ingredient, clarify with a clear indication on the label, through the vignette or text that similar ingredients are present.

When the combined weight of similar and highlighted ingredients represents the majority of the food and the highlighted ingredient is not present in higher amount than each similar ingredient, similar ingredients should be specifically identified by common name adjacent, as part of the claim or within the common name of the food.

When the combined weight of similar and highlighted ingredients represents less than the majority and the highlighted ingredient is present in a higher amount than all the similar ingredients combined, then, generally, no additional information is required.

When the combined weight of similar and highlighted ingredients represents less than the majority and the highlighted ingredient is not present in a higher amount than all the similar ingredients combined, clarify with a clear indication on the label, through the vignette or text, that similar ingredients are present.

When the highlighted ingredient is present at very low levels or as a flavour preparation, the word "flavoured" or equivalent should be displayed adjacent or within the highlighting.

Example of policy applications to the above principles are presented in Annex 2.

Presentation

Additional information such as percentage declarations, statements indicating the presence of similar ingredients or additions for the purpose of flavouring are considered prominently displayed when they are easily legible, in distinct contrast to other printed material and either in the common name of the food or adjacent to the highlighting such that a consumer would easily be able to see and relate them. With multiple highlighting of an ingredient (claim, vignette, and common name), additional information that is prominently displayed only needs to appear once, in close proximity to the most prominent highlighting.

A prominent and descriptive common name is often all that is required to clarify highlighting. Referenced ingredients, whether in the common name or a claim, should be stated in descending order of proportion by weight as is the case with the list of ingredients. In addition, all portions of any common name must be in a type height that is a minimum of one half the type height of the largest portion and no smaller than 1.6 mm based on the lower case "o" [15, CPLR].

For legibility and avoidance of misleading consumers, the general guidance for the type height of additional information is that it should at least meet the smallest of either:

In both cases, the absolute minimum is the minimum type height requirement of the Net Quantity found in the CPLR 14(2) of 1.6 mm (based on the lower case "o").

Highlighted Ingredients and Flavours Percentage Statements

A percentage statement is another option for providing information to consumers on the proportion of the highlighted ingredient in the food [Highlighted Ingredient Claims].

Note that in the case of mixed nuts, the percentage of the type of nut that is present in the product in the greatest amount must be declared on the label [B.01.071, FDR].

Percentage Calculation

Percentages of highlighted ingredients are based upon the weight of the ingredients before they are combined to make the food. This is consistent with subsection B.01.008(3) of the Food and Drug Regulations pertaining to the declaration of ingredients as a percentage of the prepackaged product before they are combined to form the prepackaged product.

Percentages are calculated by dividing the ingoing weight of the ingredient by the total weight of all the ingoing ingredients of the food and multiplying this amount by 100 (Note: When a class of ingredients is highlighted; the numerator is the total weight of all ingredients within the class of ingredients).

Example: 35 kg of single strength strawberry puree is present in a batch of muffin batter weighing 200 kg: (35 / 200) X 100 = 17% Strawberries

Exceptions and Specific Situations

  1. The weight of volatile ingredients or added water that is subsequently removed during processing is not included in the weight of the ingoing ingredients.

    Example: If 100 g of water is added as part of the ingoing ingredients and 80 g is subsequently removed as a result of processing, 20 g of water is considered to have been added as an ingredient.

  2. Subject to situation 1 above, when concentrated or dehydrated ingredients are reconstituted by the manufacturer at the same mixing bowl stage, the weight of either the reconstituted ingredient or the concentrated ingredient may be used to calculate the percentage but the list of ingredients must reflect the choice and declare the ingredient as reconstituted or as concentrated, consistent with the basis of the calculation.

    Example (a): In a one litre fruit beverage weighing 1000 g consisting, in part, of 100 g of concentrated cranberry juice (3/1) (three parts water are required to dilute one part concentrated juice) and 300 g (or more) water were added either prior to or at the mixing bowl, the percent calculations are as follows:

    • (100 g / 1000 g) X 100 = 10% Cranberry Juice concentrate; or
    • [(100 g + 300 g) / 1000 g] X 100 = 40% reconstituted Cranberry Juice

    Note that when water is added to reconstitute a concentrated ingredient at the same mixing bowl stage, and it is subsequently removed during processing (as per example 1 above) or when the theoretical reconstitution occurs at a later processing step, the option to make a percent declaration based upon the reconstituted ingredient is no longer available.

    Example (b): A 1000 g of product at the mixing bowl stage includes 100 g of concentrated cranberry juice (3/1) and 300 g of added water. The processing this product undergoes results in a moisture loss of 200 g. As the juice had not been reconstituted prior to addition to the mixing bowl, the lost moisture is considered to be added water that was subsequently removed and a claim with respect to "reconstituted juice" is not considered acceptable. A claim about the percent content of "concentrated cranberry juice" is calculated as follows:

    • Total product weight equals: 1000 g - 200 g (lost water) = 800 g
    • Concentrated cranberry juice weight equals:
      • 100 g concentrated cranberry juice + 100 g water (a partial reconstitution) = 200 g
      • 200 / 800 X 100 = 25% concentrated cranberry juice

    Note: For the above example, if the juice had actually been reconstituted prior to the mixing bowl stage, the percentage could be calculated based upon 400 g of reconstituted cranberry juice compared to the 1000 g total ingoing weight (40% reconstituted cranberry juice). In this case there is no added water, only reconstituted juice, and all moisture loss is from the ingredients.

  3. For products requiring preparation by the consumer, it is also acceptable to make a claim based upon the percentage of the highlighted ingredient in the food "as prepared". This claim may only be made when the percentage of the highlighted ingredient in the food "as sold" is also present and where there are directions for preparation.

    Example: A pudding mix requiring preparation with milk could make the claim "X% milk ingredients when prepared according to directions" (based upon the milk ingredient content of the food as prepared). However, this claim may only be made when the percentage of milk ingredients found in the mix (as sold) is also declared (e.g. "25% milk ingredients - 60% milk ingredients when prepared according to directions" on a mix consisting of 20 g of milk powder in 80 g of mix that is reconstituted with milk).

  4. When multi-component ingredients are used, percentage declarations are based upon the entire ingredient when the claim/clarification is made with respect to the ingredient as a whole. When the declaration is made with respect to the major component of an ingredient, the claim must be based upon the contribution of that component only, not the entire ingredient. Care must be exercised in cases where the ingredient name is the same as that of the major component.

    Example (a): The declaration of the percentage of raspberry jam in a jam pastry is based upon the jam; however, a claim for the raspberry content of the pastry would be based upon only the raspberry portion of the jam.

    Example (b): The declaration of the percentage of peas in a soup which includes canned peas is based upon the weight of the peas only. The weight of the other ingredients of the canned peas (such as water, sweeteners, preservatives, etc.) must not be included when calculating the percentage of the peas in the soup.

100% statements

For guidance on the use of the statement "100%", please refer to the Pure, 100% Pure, 100%, All. Specific guidance for fruit juices and the use of "100%" can be found in Annex 1 of these guidelines.

Declaration and Rounding

The amount declared shall be:

  1. a minimum percentage, where emphasis is on the high content of an ingredient; or
  2. a maximum percentage, where emphasis is on the minimal content of an ingredient; and
  3. rounded to the nearest:
    1. whole number for percentages from 1 - 99%;
    2. 1/10 of one percent for amounts greater than 99.5%;
    3. 1/10 of one percent or stated as "< 1%" for amounts less than 1%; or
    4. declared as "0" when none is present.

Annex 1 - Exceptions

These guidelines do not apply to herbs/spices and seasoning ingredients such as leeks, onion, garlic, hot peppers, etc. (when added for seasoning), nutrients, phytochemicals and products that are not considered foods under the Food and Drugs Act, such as natural health products.

Regulations:

This policy does not take precedence over existing federal or provincial legislation. The following are examples of regulations related to highlighted ingredients. It is important to consult federal and provincial legislation to ensure compliance.

1. Raisin Bread [B.13.025, FDR] shall be bread that contains for each 100 parts by weight of flour used not less than 50 parts by weight of seeded or seedless raisins, or raisins and currants of which not less than 35 parts shall be raisins and may contain spices or peel.

2. (naming the percentage) Whole Wheat Bread [B.13.026, FDR] shall be bread in the making of which the named percentage of the flour used shall be whole wheat flour, and (ii) contain not less than 60 per cent whole wheat flour in relation to the total flour used; and . . .

3. Speciality Breads [B.13.029, FDR] are not required to name the percentage but are expected to have a minimum level of the named ingredient as set out in the table of common specialty breads in Grain and Bakery Products. However, any percentage declaration on the product label, other than that required by B.13.026, must be based upon the total weight of all ingredients and not as a percentage of the flour used.

4. Bakery Products (such as cookies, dessert loaves, bars, muffins, cakes, etc.) have generally been made with white flour plus a premium ingredient. With the exception of when whole wheat flour or whole grains are highlighted, white flour is not considered when calculating the weight of similar ingredients (e.g., an oatmeal cookie would be evaluated against the presence of other flours but without considering the amount of white flour. A percent declaration on the label or advertising, however, would be based on the product as a whole). This non-inclusion of white flour as a similar ingredient only applies to snack or dessert-type bakery items and not to cereals and other grain based products.

5. Other Functions and Incidental Additions

Exceptions to situations in section 4 above involving similar ingredients include substances that are present in small amounts for a different function in a multi-ingredient food. For example, a "Rice loaf" which contains a small amount of potato starch in addition to the rice flour or soy oil used as a carrier in a "Canola Oil Margarine". These ingredients would not be considered a similar ingredient. However, the guidelines apply to those ingredients not added for a different function, such as 3 % concentrated lemon juice added to an "Orange Juice Beverage".

6. Food Generally Recognized as Flavoured

Exceptions to these requirements for clarifying information include those products which have traditionally highlighted their flavour and which consumers have no expectation of a real ingredient being present (or present in any significant amount). Simple references to the flavour of products in flashes or the common name (e.g., "blueberry" or "cherry candy") do not require clarifying information on products such as puddings, soft drinks, jelly powders, gum, hard candy, popsicles, flavoured teas or flavoured coffees (Also see section 8b below on "Naming the Fruit flavoured drink").

"Chocolate" has been frequently used as a flavour description on products which do not contain real chocolate. The simple expression "chocolate" may be used without indicating "flavour" whenever cocoa products are present and the foods do not appear to contain real chocolate, for example, where there are no coatings or solid pieces that resemble real chocolate or no additional chocolate highlighting such as "milk chocolate" or a vignette of chocolate.

e.g., "Hot chocolate mix", or "chocolate cake" on a cocoa flavoured cake are acceptable highlighting, while "milk" chocolate mix or cake would not be acceptable. "Chocolate flavoured" is required on a bar, chip or a cake which has a hard chocolate-like coating that is not chocolate.

It is important to note that these are exceptions and that there are few products that fall into this category. Consumer research demonstrates that, generally, there is a high expectation of the named ingredient to be present in foods and the exception does not apply if there is additional highlighting that suggests the juice or other named ingredient may be present.

Ingredients such as honey and maple syrup present in minor amounts in dry food such as cereals and crackers are generally recognized as flavours and do not require additional "flavour" statements (Note that this does not apply to products such as sauces or sweetening preparations). Only when other ingredients are present to provide a similar flavour, including flavour preparations, is a "flavour" statement needed.

e.g., a cereal which contains sugar, raisins and honey but no honey flavouring could be called "Raisin and Honey cereal" but if honey flavoured substitute were to be added, the cereal would then have to be called "Raisin and Honey flavoured cereal".

7. Concentrated foods and sauces

In the case of concentrated foods such as soups, the removal of the water may cause the end product to contain more than 50% of the highlighted ingredient and these products are evaluated as if the combined weight of highlighted and similar ingredients is less than 50% of the total weight of the product. Highlighting is acceptable without further clarification whenever the highlighted ingredient is present in a higher amount than the similar ingredient's weight.

By the nature of the product, sauces are known to contain ingredients added to decrease the viscosity (e.g., milks to cheese) and these ingredients will not be considered as similar ingredients. However, when other non-softening similar ingredients (other cheeses) are added, the product is evaluated as if the weight of the highlighted and similar ingredients combined represents the majority of the food. The presence of these similar ingredients must be acknowledged.

Examples

8. Fruit Juices and Fruit Drinks

Beverages that include the name of a fruit within the common name must be labelled and advertised to distinguish them clearly from standardized juices; see the following information or Guidelines on Beverages or Beverage Mixes Identified with Name of a Fruit which provides the specific juice and juice drink policy.

a. "(Naming the Fruit) Juice Drink" - Minimum of 25% juice

The word "juice" may only appear in the common name of the product when it contains a minimum of 25%, in total, of the named juice(s). For example, "Orange Juice Cooler", "Reconstituted Grape Juice Cocktail", "Cranberry-Apple Juice Beverage". When "juice" is in the common name, it must be accompanied by a bilingual declaration of the percentage of each named juice or the total amount for all named juices, on the principal display panel of the label, clearly and prominently displayed and in type size at least as large as the numerical portion of the net quantity. The juice description and percentage juice statement must follow the conventions in section 8d and section 8e below.

b. "(Naming the Fruit) Flavoured Drink" - With Juice/Fruit Claims and less than 25% juice

When the percentage of juice is less than 25%, the word "juice" may not appear in the common name; however the product may be described as "flavoured". Claims about the fruit juice content such as "made in part with fruit juice" are permitted outside of the common name if accompanied by the percentage fruit juice. The juice description and percentage juice statement must follow the conventions shown in section 8d and section 8e below.

c. "(Naming the Fruit) Drink, Cooler, Beverage, Cocktail"

Fruit-based or fruit-flavoured beverages [B.11.150, FDR] have been made primarily with water, sweetening ingredients, colour, flavours etc., plus occasional premium ingredients such as fruit juices, fruit derived products or vitamin C. Due to long standing practice such products are not required to indicate "flavour", as the basic common name has been accepted as an indication of the characterizing flavour. In other words, "(Naming the fruit) drink" such as "Fruit Drink", "Blueberry Cocktail", "Cherry Cooler" will be considered synonymous with (naming the fruit)-flavoured drink, cooler, etc., only when there is no other mention of juice and no further highlighting implying the product contains real juice, such as; "real fruit beverage", "orange cooler - contains real oranges", naming a specific variety of fruit such as "Granny Smith Apple Drink", the word "juice", or images of juice dripping from the fruit.

Note: For these drinks, while a vignette of the fruit that represents the flavour is not considered to be further highlighting, if artificial flavour of the fruit is added, this will trigger Section 34 of the CPLR which would provide appropriate clarifying information for the vignette.

When there is further highlighting that implies the product contains real juice, such as the vignette of the juice dripping from the fruit or other statement, the claim will be evaluated separately with other added juices, purees, water, etc. and considered as contributing to the total weight of similar ingredients.

d. "Made with X % fruit juice"

When a claim such as "made with 10% fruit juice" is made, while the exact form of the fruit juice ingredient used must be declared in the list of ingredients, the form is not required to be declared as part of the claim. For example; "contains 8% fruit juice" or "contains 15% real juice", where the fruit is not specifically named, is acceptable whether "orange juice", "orange juice from concentrate" or "concentrated orange juice" is used.

e. "Made with X% (naming the fruit) juice"

However, when a claim such as "made with X% (naming the fruit) juice" is made, the actual form of the juice ingredient must be declared as part of the claim. For example, "made with 7% orange juice" means single strength orange juice, and other forms of orange juice such as orange juice from concentrate were not used.

f. De-characterized Juices

A decharacterized juice is not considered to be juice and therefore must not be included in the calculation of % juice present, nor represented on the label as a juice. Such products are to be shown in the ingredient list by an appropriate descriptive name such as; de-acidified apple juice from concentrate, de-flavoured pear juice, reconstituted de-coloured orange juice. However, decharacterized juice is considered a similar ingredient to real juice.

g. 100% Claims on Juices

"100% fruit juices" means only juices (and fruit purees) are present, without added ingredients, including any permitted by a standard. The juices may or may not be reconstituted (As per existing policy, the form of the juice is only required when the actual juice(s) are named as in; "100% orange and grapefruit juice from concentrate").

When other ingredients are present, the 100% claim may still be made when the added ingredients do not result in a diminution of the juice soluble solids and the ingredients are identified either as part of the claim or in the product common name. Ingredients that do not impact upon the soluble solids content and would be acceptable as part of the claims are preservatives, flavours, additives, dry sweeteners and solid food products. Liquid sweeteners would impact upon juices but not on reconstituted juices, where the liquid portion of the sweetener makes up a portion of the reconstitution.

Acceptable:

  • "100% fruit juices with natural flavours and citric acid"
  • "100% Fruit juices with added tapioca balls"
  • "Cranberry Mango Flavoured 100% Juice Blend" (Acceptable when juices are the only ingredients other than the named flavours)
  • "100% Grapefruit Juice from concentrate with added glucose solids and flavour" (A dry sweetener is acceptable in this claim)
  • "100% Grapefruit Juice from concentrate with added sweetener" (Either dry and liquid sweetening agents are permitted in claims for reconstituted juices)

Not Acceptable:

  • "100% Fruit Juices with added glucose" (when liquid glucose is used)
  • "Made with 100% Grapefruit Juice" on a beverage containing added water

Annex 2 - Application of the Guidelines Examples

Note: The lists of ingredients provided in this annex contain only the ingredients relevant to the discussion and thus are not necessarily complete.

Product Evaluation - Example 1: Chocolate Chip Cookie
Product Label and Advertising
Information and Formulation
Acceptability and Possible options
(not exhaustive)

1.1

Label: "Chocolate Chip Cookie"

Ingredients: 6% carob chips and 5% chocolate chips

Not acceptable as an imitation ingredient is also present without additional information. Some clarifying options would be to indicate the percentage of chocolate chip on the principle display panel or to include similar ingredients in the common name:

  • "Carob chip and chocolate chips cookie", "Carob and chocolate chip cookie"; or
  • "5% Chocolate Chip Cookie"

1.2

Label: "Cookie" with the claim "made with chocolate chips"

Ingredients: 6% carob chips and 5% chocolate chips

Similar to the previous example, the real chocolate chips are highlighted through the claim but imitation ingredients are present. The options are similar to Example 1.1:

  • Change the claim: "made with carob and chocolate chips"; or
  • Change the common name:
    • "Carob chip and Chocolate chips cookie"; or
    • "5% Chocolate Chip Cookie"

1.3

Label: "Cookie" plus an additional image of a chocolate slab

Ingredients: 6% carob chips and 5% chocolate chips

Similar to the previous example, the real chocolate chips are highlighted through the image of the chocolate slab but an imitation ingredient is present. The options similar are Example 1:

  • Change the common name:
    • "Carob chip and Chocolate chips cookie"; or
    • "5% Chocolate Chip Cookie"

1.4

Label: "Cookie" plus an additional vignette of the cookie showing chips

Ingredients: 6% carob chips and 5% chocolate chips

Acceptable. The label does not highlight real chocolate chips.

Product Evaluation - Example 2: Cereal Bars
Product Label and Advertising
Information and Formulation
Acceptability and Possible options
(not exhaustive)

2.1

Label: "Cereal Bar" and "Raspberry Flavour flash

The red fruit composite particles are visible in either the product (transparent package) or the vignette of the product, at time of sale.

Ingredients: 8% fruit composite (consisting of cranberries, fillers and raspberry flavour)

Not acceptable as an imitation ingredient is also present without additional information. Raspberry has been highlighted by the flavour statement and the erroneous impression given is that the visible red pieces are raspberries in the product. Some clarifying options would be to indicate the percentage of strawberries on the principle display panel or to specifically disclose all similar ingredients:

  • "Raspberry Flavoured Cranberry Cereal Bar" which clearly explains the product; or
  • "0% Raspberry" or "contains no raspberry".

Indicating "flavour" is not an option here, as it is the flavour statement that contributed to the improper highlighting.

Note that if the red fruit composite were not visible in the product or on the vignette at the time of sale, it would then be acceptable as the consumer would not be lead to believe that real raspberries are present in the food.

Product Evaluation - Example 3: Pizza
Product Label and Advertising
Information and Formulation
Acceptability and Possible options
(not exhaustive)

3.1

Label: "Pepperoni Pizza"

With pepperoni slices visible in either the product or the vignette.

Ingredients: The slices are simulated pepperoni made from textured soy protein

Not acceptable as an imitation ingredient is present without additional information to disclose the real nature of the slices. Consumers would expect real pepperoni slices. Some clarifying options are:

  • "Simulated Pepperoni Pizza"; or
  • "Pepperoni flavoured soy pizza"

Simply adding "0% Pepperoni" or "contains no pepperoni" would contradict the label as a whole and confuse/mislead consumers.

3.2

Label: "Pepperoni Pizza"

With the slices visible in either the product or the vignette.

Ingredients: 5% pepperoni (real pepperoni)

Acceptable. In this case there are no similar ingredients present.

Product Evaluation - Example 4: Cereal
Product Label and Advertising
Information and Formulation
Acceptability and Possible options
(not exhaustive)

4.1

Label: "Soy Cereal" with a label showing only soy

Ingredients: 40% soy, 25% wheat, 20% oats, and 5% rice

Not acceptable; even though soy is more prominent than each similar ingredient, the total weight of all highlighted and similar ingredients represents the majority of the food and the label does not somehow indicate that similar ingredients are present. Options could include indicating the percentage of soy, or indicating that soy is added for flavour.

  • "Soy, Wheat, Oat, and Rice Cereal" or "Three grains plus soy cereal"; or
  • Add "40% Soy" on the label, or in the common name; or
  • Showing all 4 similar ingredients on the vignette; or
  • "Soy flavoured cereal"

4.2

Label: "Soy Cereal"

Ingredients: 40% wheat, 25% soy, 20% oats, and 5% rice.

Not acceptable as the name does not indicate other similar ingredients are present. As all similar ingredients represent together the majority of the food and the soy part of the product is not present in a higher amount than each similar ingredients, some options are:

  • "Wheat, soy, oats and rice cereal" (in descending order); or
  • Add "25% soy" prominently on the label; or
  • "Soy flavoured cereal"
Product Evaluation - Example 5: Seafood Mix
Product Label and Advertising
Information and Formulation
Acceptability and Possible options
(not exhaustive)

5.1

Label: "Seafood mix with Crab"

With a vignette of a crab

Ingredients: 40% Cod, 40% Pollack and 10% crab

Not acceptable: crab is highlighted by both the vignette and the common name and the highlighted and similar ingredients together represent the majority of the food. Because crab is not present in a higher amount than each similar ingredient, some clarifying options would be:

  • "Cod, Pollack & crab mix"; or
  • Add "10% Crab" on the label or part of the common name; or
  • "Crab flavoured seafood mix"

5.2

Label: "Seafood and Crab Mix"

  • Vignette of a crab
  • Imitation crab is visible at time of sale

Ingredients: 40% Cod, 40% Pollack and 10% imitation crab"

Not acceptable as an imitation ingredient is also present without additional information. Crab has been highlighted in the name, the imitation crab is visible, and there is a vignette of a crab. The erroneous impression given is that real crab is contained in this seafood product. Some clarifying options would be:

  • "Seafood with imitation crab mix"; or
  • "Cod, Pollack and imitation crab mix", "Cod, Pollack and crab flavoured white fish"

Simply adding "0% Crab" or "contains no crab" would contradict the label as a whole and confuse/mislead consumers.

Product Evaluation - Example 6: Honey Spread
Product Label and Advertising
Information and Formulation
Acceptability and Possible options
(not exhaustive)

6.1

Label: "Honey Spread" with vignettes of bees, hives and honey dippers

Ingredients: 46% corn syrup and 44% honey

Not acceptable. As all similar ingredients represent together the majority of the food and the highlighted ingredient is not the most prominent, the similar ingredients should be identified by common name, or use a percentage/flavour statement.

  • "Corn Syrup and Honey Spread"; or
  • "44% honey spread"; or
  • "honey flavoured spread"
Product Evaluation - Example 7: Snacks
Product Label and Advertising
Information and Formulation
Acceptability and Possible options
(not exhaustive)

7.1

Label: "Fruit Snack" or "Fruit flavoured snack - made with real oranges"

Ingredients: 70% (sugar, flavour, pectin, starch) and 24% concentrated orange puree

Not acceptable: even though oranges are present, the name does not indicate other similar ingredients (sugar/flavour/pectin) are present in a higher amount. Some clarifying options would be:

  • "Candy and Fruit snack"; or
  • "Fruit Snack - 24% oranges"

7.2

Label: "Fruit flavoured gummy treats" or "gummy and fruit flavoured snacks - made with oranges" or "fruit flavoured snack - made with real oranges in a candy"

Ingredients: 70% (sugar, flavour, pectin, starch) and 24% concentrated orange puree

Acceptable: These common names are acceptable as they make it clear this is not solely a fruit product but is a candy-like product made with fruit or fruit flavouring.

Note: If other fruits had been present, the "orange fruit" highlighting would be further evaluated against the amount of the other fruit ingredients.

Product Evaluation - Example 8: Juice and Fruit drinks
Product Label and Advertising
Information and Formulation
Acceptability and Possible options
(not exhaustive)

8.1

Label: "Cranberry Drink"; or "Fruit Drink" plus a large CRANBERRY, and with a cranberry vignette

Ingredients: 60% water, 20% apple juice, and 10% cranberry juice

Acceptable: see Annex 1, section 8c. With no mention or representation of "juice" simple common names such as "cranberry drink" are accepted as indicating "cranberry flavoured drink".

Note: This would apply whether cranberry juice, other fruit juices, or no juice of any kind is actually present in the product.

8.2

Label: "Blueberry Juice Drink"

Ingredients: water, glucose, blueberry juice (5%), flavour

Not acceptable; "Juice" may not be in the common name of a drink unless there is at least 25% total juice (and the percentage is declared). See Annex 1, section 8a. Options include:

  • Change name to "Blueberry Drink" and, if desired, add a separate "made with 5% blueberry juice" statement.

8.3

Label: "Cranberry and Mixed Berry Juice Blend" with vignettes of cranberry, blueberry and strawberry

Ingredients: Concentrated apple (50%), cranberry (20%), blueberry (15%) and strawberry juices (15%)

Not acceptable as non-berry juice (apple) is also present but not represented. (Also, cranberry should not be shown first within the common name as it is not the most prominent juice in the blend). Some clarifying options would be:

  • "Apple, mixed berry and cranberry juice blend" plus "100% Juice" (% required for all "[named] juices"); or
  • "100% Mixed Juice Blend – 20% Cranberry"

Note: See Annex 1, section 8a as percentage juice statements are required whenever "juice" is in the common name.

8.4

Label: "100% Juice Blend"; Plus "cranberry" and the image of cranberries

Ingredients: Water, Concentrated Grape, Cranberry and Apple Juices

Not acceptable. Cranberry is highlighted and there is no indication that "blend" refers to other juices. Some clarifying options would be:

  • "Reconstituted Grape, Cranberry, and Apple Juices" plus "100% Juice". You can also add images of grapes and apples; or
  • Keep the common name plus provide the cranberry percentage; or
  • "100% Juice Blend" plus "20% Cranberry juice"

Note: See Annex 1, section 8a as percentage juice statements are required whenever "juice" is in the common name.

Product Evaluation - Example 9: Butter Pastry
Product Label and Advertising
Information and Formulation
Acceptability and Possible options
(not exhaustive)

9.1

Label: "Butter Cake" or "Made with butter"

Ingredients: 5% butter and 8% canola oil

Not acceptable as butter and canola oil represent less than the majority of the food and butter is not the most prominent. Some clarifying options would be:

  • "Canola oil and Butter cake"; or
  • "5% butter cake"; or
  • "butter flavoured cake"

Note: The label would be acceptable if the ingredients had been 7% butter and 6% canola oil.

Product Evaluation - Example 10: Cookies
Product Label and Advertising
Information and Formulation
Acceptability and Possible options
(not exhaustive)

10.1

Label: "Butter oatmeal cookies with a creamy filling"

Ingredients: 8% butter and 5% canola oil

Note: the filling contains hydrogenated palm oil.

Acceptable; the butter claim relates solely to the biscuit portion of the product, which is distinct from the filling. As the butter and canola oil represent less than the majority of the food, and that butter is more prominent, there is no objection to the label.

Product Evaluation - Example 11: Graham Crackers
Product Label and Advertising
Information and Formulation
Acceptability and Possible options
(not exhaustive)

11.1

Label: "Honey Graham Crackers"

Ingredients: 10% graham flour, 5% sugar, 3% honey, sodium bicarbonate

Graham highlighting is acceptable as white flour is not counted towards the weight of similar ingredients.

See Exception for Bakery Products in Annex 1, section 4.

Honey highlighting is acceptable as honey is present in a dry product with no other similar ingredient present to simulate its flavour (See Annex 1, section 6 Generally recognized as flavour statement).

Product Evaluation - Example 12:Candy Bar
Product Label and Advertising
Information and Formulation
Acceptability and Possible options
(not exhaustive)

12.1

Label: "Maple" and a maple leaf vignette. Common name is "candy bar"

Ingredients: chocolate, sugar,... natural maple flavour

Not acceptable. The claim "Maple" and the maple leaf vignette highlights maple as an ingredient. Since no real maple is present, there should be clarifying information to indicate that fact;

  • "Maple flavoured candy bar"; or
  • use an asterisk (*) and a "*natural maple flavour" statement

Note that either option would have to be prominently displayed.

12.2

Label: "Maple" and a maple leaf vignette. Common name is "candy bar".

Ingredients: chocolate, [...], 38% maple syrup, 1.2% natural maple flavour

Acceptable. The wording "Maple" and the maple leaf vignette highlights maple as an ingredient. As real maple is present with a very small amount of flavour, this is not misleading to consumers.

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