Food Products that Require a Label
Information on Prepackaged Foods

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When referring to food labelling requirements for prepackaged foods, prepackaged products (definition) are those that are packaged before being offered for sale. This includes foods that are packaged at retail before being offered for sale, such as candies packaged into containers from bulk or buns placed in a bag by the retailer.

Note that the FDR definition of "prepackaged product" includes products packaged for sale to consumers and those packaged for sale to the other companies or institutions, such as a box of flour that is sold by a mill to a bakery or an industry-sized pail of syrup that is sold by a manufacturer to a restaurant. Conversely, the CPLA definition of "prepackaged product" includes only those products that are packaged for sale to consumers.

Food products that are offered for sale unpackaged and then packaged by a clerk upon request by the consumer (definition) are not considered to be prepackaged products. These are often referred to as clerk-served foods. Examples include:

  • Deli meat on display at the deli counter that is sliced and packaged at the request of a consumer does not require labelling as it is a clerk-served item.
  • Gift baskets that are not packaged prior to a customer's order do not require labelling information. This allowance does not apply to gift baskets that are packaged prior to a customer’s order.

Food products that are offered for sale unpackaged and then packaged by the consumer (e.g., food sold in bulk bins) are also not considered to be prepackaged products.


Based on the definitions in the FDA and CPLA, a package (definition) or container (definition) is interpreted to include:

  • Inedible casings
  • Wax, cheesecloth, muslin, or similar items, on cheese
  • Confining bands on fresh produce (may be made of twine, elastic bands or twist ties)
  • Clear, colourless, transparent protective wrappings, including the shrink wrap on individual units of fresh fruits and vegetables, such as the ones used on English cucumbers, a lettuce head, a bunch of grapes, etc.
  • Any outer package that is customarily displayed to the consumer (such as outer packaging for most foods such as cartons, bags and nets)

A package or containers is interpreted to exclude:

  • Inner pouches, envelopes, boxes, bags, sleeves, etc. when sold inside an outer box or bag that is normally displayed to the consumer, regardless of whether the inside wrap is unlabelled, partly labelled, or fully labelled. This may include protective wrappings inside properly labelled shipping containers. [Note: If a food item from inside a box is sold individually, however, the inside wrap or liner is then considered to be a container and must be fully labelled when sold.]
  • Edible casings that enclose foods, because these are considered to be ingredients of a food, e.g. casings on sausages
  • Wax coatings on fresh fruits and vegetables, because these are also part of the food, e.g. wax coating on apples, turnips
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