General Principles for Labelling and Advertising
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In addition to legislative requirements and specific guidelines, the general principles identified below provide an overview of some of the factors the CFIA takes into consideration when assessing any representations in food labelling and advertising for compliance with subsections 5(1) of the FDA and 7(1) of the CPLA.
Accuracy and Substantiation
As outlined in Requirements, all information provided on food labels or in advertising must be accurate, truthful, and must not mislead or deceive the consumer. During compliance and enforcement activities carried out by the CFIA, regulated parties may be requested to substantiate labelling or advertising information. There are many forms of substantiation that may be appropriate, depending on the nature of the information. Some types of substantiation include analytical results regarding nutrient profiles or gluten levels, product formulations that relate to the accuracy of ingredient lists, or evidence to support the validity of a claim.
Qualifying Statements or Disclaimers
Qualifying statements or disclaimers may not be used to correct a false or misleading statement or image. Some labels and advertisements use asterisks in order to direct the consumer's attention to a statement in an obscure location. However, it is not acceptable to use this technique to explain that a featured statement or image is not exactly what it appears to be. It is acceptable to use asterisks to direct the consumer's attention to additional information that is not essential to the accuracy or truthfulness of the statement carrying the asterisk.
Failure to Disclose
It is unacceptable to use partial truths, as these are likely to create a false impression. This includes the failure to disclose the essential facts about the properties or composition of a food, particularly when emphasis is given to the more desirable characteristics or to expensive ingredients. For example, it is technically possible to simulate meats, nuts, chocolate, etc, that have the physical appearance and texture of the food simulated. However, labelling and advertising must not create an erroneous impression that more of the real ingredients are present than is the case. To avoid an erroneous impression, it is recommended that claims for these products disclose the presence of the simulated nuts, meat or chocolate, especially when the nuts, meat or chocolate content of the food is emphasized.
To avoid creating false, deceptive or misleading impressions about a food or its consumption, it is recommended that the meaning of descriptive words used in relation to a food be clear. For example, words such as "balanced" or "prescribed" may create an erroneous impression if not further clarified (e.g., "balanced" could be clarified by stating "fresh fruits are part of a balanced diet").
Additionally, it is recommended that care be taken when using comparisons, in order to provide sufficient information to enable consumers to make an informed choice. For example, superlatives, such as "best", and comparatives such as "better" and "superior" may likely create an erroneous impression if not clarified with further information. For more information, see Comparative Claims.
Alarmist Claims and Advertising
Claims that create alarm are generally considered misleading. Examples of alarmist claims include:
- Claims that suggest any one food is essential to health or nutritional well-being.
- Claims that suggest some foods are good while others are bad, or associate guilt with certain foods.
- Claims that suggest a competitor's product contains harmful or undesirable ingredients.
References to the Food and Drugs Act (FDA) and Food and Drug Regulations (FDR)
It is prohibited to make direct or indirect references to the FDA and FDR on food labels or in advertising, unless specifically required by the FDA or FDR [B.01.013, FDR].
An exception exists in cases where a food complies with a standard established by the FDR and the manufacturer of the food has substantiated, by means of the results of tests carried out before the statement is made or by other evidence that exists before the statement is made, that the food so complies. In this case, a statement that "the food complies with the standard for (naming the common name of the food in respect of which the claim is made) in the Food and Drug Regulations" may be made on the label of, or in an advertisement for the food.
Statutory References and Terms
Certain terms such as "ingredient", "durable life", "packaging date", "age of an alcoholic beverage" and "filler" are defined in the Food and Drug Regulations. In cases where a specific legal definition of a term exists in legislation, and the term is used on food labels or advertising, the term must comply with the legal definition. For example, if a label of a meat claims "contains no filler", none of the ingredients defined in the term "filler" in B.14.001, FDR may be present in the product.
It is recommended to also consider consumer perception of the meanings of the terms used on food labels and advertising.
It is acceptable to target food claims for specific population groups, such as a certain sex, age, ethnicity, religion, or to people consuming specific diets provided that the claims comply with all relevant labelling and advertising requirements.
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