Method of Production Claims

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Overview

"Method of production" refers to how a product was produced, grown, handled, manufactured, etc. Claims related to the method of production are subject to subsection 5(1) of the Food and Drugs Act (FDA) and section 7 of the Consumer Packaging and Labelling Act (CPLA), which prohibit statements and claims that are false, misleading, deceptive or that create an erroneous impression regarding the product including, in the case of the CPLA, its method of manufacture. In addition, some method of production claims have specific regulatory requirements that apply to them.

Refer to the following sections for additional information on specific regulatory requirements for claims related to the method of production:

Claim Substantiation

As outlined in the Overview section, all method of production claims 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 Canadian Food Inspection Agency (CFIA), regulated parties should be able to substantiate the claims.

Acceptable manners to substantiate a method of production claim include:

  • third party audit;
  • valid documentation; or
  • non-government certification programs.

All documents used to substantiate a method of production claim must be made available to a CFIA inspector upon request.

Nature, Natural

"Nature", "natural", "Mother Nature", "Nature's Way" are terms often misused on labels and in advertisements.

Labels and advertisements should not convey the impression that "Nature" has, by some miraculous process, made some foods nutritionally superior to others or has engineered some foods specially to take care of human needs. Some consumers may consider foods described as "natural" of greater worth than foods not so described.

A food or ingredient of a food that is represented as natural is expected:

  • not to contain, or to ever have contained, an added vitamin, mineral nutrient, artificial flavouring agent or food additive.
  • not to have any constituent or fraction thereof removed or significantly changed, except the removal of water. For example: the removal of caffeine.
  • not to have been submitted to processes that have significantly altered their original physical, chemical or biological state (i.e. maximum processes). See Annex 1 – Minimum Processes and Annex 2 – Maximum Processes, Processes Affecting the Natural Character of Foods.

Note that the use of minimum processes listed in Annex 1 does not automatically make the food product eligible for a natural claim. For instance, although "cutting" is listed in Annex 1 as a minimum process, the use of the claim "natural cuts" would be considered misleading if used in relation to a food product that did not meet all the criteria for a natural claim.

Note that some food additives, vitamins and mineral nutrients may be derived from natural sources. Some of these additives may be regarded as natural ingredients, in which case the acceptable claim would be that this food contains "natural ingredients". The processes used to produce the food additive should not significantly alter its original, chemical, or biological state. Note that while the ingredient can be described as "natural", the food itself cannot, since it contains an added component.

Use of the word "natural" in a trademark name is subject to the same criteria as outlined above. See Trade-Marks for more information.

Flavour Descriptors

Substances that impart flavours that have been derived from a plant or animal source, may be claimed to be "natural". As well, any additive, such as preservatives and solvents added to a flavour preparation to have a technological effect solely on the flavour, does not modify the "natural" status of the flavouring material itself. However, the addition does alter the natural status of the food to which it has been added, even though it need not be declared as an ingredient on the food label. In other words, such foods may not be claimed to "contain only natural ingredients".

Furthermore, acids, bases, salts and sweeteners may be used to impart sour, bitter, salty and sweet tastes in conjunction with natural flavours. They do not alter the "natural" status of the flavouring material itself. For example, citric acid is not a flavour but acts only as an acidulant when used in conjunction with natural flavours.

Note, however, that while the flavour remains "natural", such acids, bases, salts or sweeteners have an effect on the foods to which the flavour preparation is added. Therefore, the list of ingredients of such foods must declare acids, bases, salts or sweeteners that are present by their proper common names.

The status of enzymatic flavours, processed flavours, reaction flavours or nature-identical flavours has not been established under these guidelines. Each one will therefore be examined on a case-by-case basis.

Novel Foods, Including Novel Foods that are Products of Genetic Modification

As defined in the Food and Drug Regulations (FDR), "novel food" means,

  1. a substance, including a microorganism, that does not have a history of safe use as a food;
  2. a food that has been manufactured, prepared, preserved or packaged by a process that
    1. has not been previously applied to that food, and
    2. causes the food to undergo a major change; and
  3. a food that is derived from a plant, animal or microorganism that has been genetically modified such that
    1. the plant, animal or microorganism exhibits characteristics that were not previously observed in that plant, animal or microorganism,
    2. the plant, animal or microorganism no longer exhibits characteristics that were previously observed in that plant, animal or microorganism, or
    3. one or more characteristics of the plant, animal or microorganism no longer fall within the anticipated range for the plant, animal or microorganism [B.28.001, FDR].

Genetically modify means to change the heritable traits of a plant, animal or microorganism by means of intentional manipulation [B.28.001, FDR]. Genetically engineered foods are one type of genetically modified foods.

The FDR require that, prior to the sale or advertisement of a novel food, Health Canada be notified with sufficient accompanying information, as outlined in B.28.002(2) of the FDR, to conduct a safety assessment. If Health Canada deems the novel food to be safe for consumption, a letter of no-objection is issued notifying the petitioner to that effect.

Health Canada may require, for those novel foods that result in a health or safety change or a significant change in nutrition or composition, a declaration on the label that details the manner in which the novel food differs from its non-modified counterpart. This applies to any novel foods, including products of genetic modification. This statement then becomes mandatory on the novel food.

For additional information including the safety assessment process and regulation of novel foods, fact sheets, frequently asked questions, lists of recent Health Canada approvals of novel foods, and other resources, consult Health Canada's webpage on Genetically Modified Foods and Other Novel Foods.

Voluntary Labelling and Advertising of Foods That Are and Are Not Products of Genetic Engineering

In the Canadian General Standards Board (CGSB) National Standard for Voluntary Labelling and Advertising of Foods That Are and Are Not Products of Genetic Engineering:

"Genetic Engineering" refers to a technique by which the genetic material of an organism is changed in a way that does not occur naturally by multiplication and/or natural recombination.

"Product of Genetic Engineering" refers to food consisting of organisms that have undergone genetic engineering and to food derived from these organisms.

Novel foods, as described in the previous section, include products of genetic engineering.

In Canada, voluntary claims on foods that are and are not products of genetic engineering may be made provided such claims are truthful, not misleading or deceptive, and not likely to create an erroneous impression of a food's character, value, composition, merit or safety, and in compliance with all other requirements set out under the FDA, the CPLA and other applicable legislation.

The National Standard of Canada for Voluntary Labelling and Advertising of Foods that Are and Are Not Products of Genetic Engineering (Standard) provides criteria for making voluntary labelling and advertising claims that identify foods sold in Canada that are or are not products of genetic engineering. It includes detailed information including criteria for claims on both single and multi-ingredient foods, verification, and examples of claims. It provides guidance on the appropriate use of the terms such as "genetically engineered" and "product of genetic engineering".

For more information on genetically engineered foods, please see the Labelling of Genetically Engineered Foods in Canada Factsheet.

Kosher

Kosher, which means "fit" or "proper", describes foods and practices that are specifically permitted by Jewish dietary laws. Certification that a food is processed in accordance with the requirements of the Kashruth is made by a Rabbi or Rabbinical organization and identified by the appropriate Rabbi or Rabbinical organization symbol.

In the labelling, packaging and advertising of a food, the Food and Drug Regulations prohibit the use of the word "kosher" or any letter of the Hebrew alphabet, or any other word, expression, depiction, sign, symbol, mark, device or other representation that indicates or that is likely to create an impression that the food is kosher, if the food does not meet the requirements of the Kashruth applicable to it [B.01.049, FDR].

The terms "kosher style", "kind of kosher", and other similar terms are considered to create an impression that the food is kosher, and therefore, the food must meet the requirements of the Kashruth in order for these terms to be used. The terms "Jewish-style food" or "Jewish cuisine" are not necessarily considered to create the impression that the food is kosher.

Halal

In the labelling, packaging or advertising of a food, the Food and Drug Regulations prohibit the use of the word "halal" or any letters of the Arabic alphabet, or any other word, expression, depiction, sign, symbol, mark, device or other representation that indicates or that is likely to create an impression that the food is halal, unless the name of the person or body that has certified the food as halal is indicated on the label, package, or in the advertisement for that food [B.01.050, FDR].

The name of the certifying body or person is required where the claim is being made, whether that is on the label or the package or in the advertisement. Having the name of the certifying body or person on one of these elements does not preclude it from being required to appear on the other elements when a halal claim is made.

Acronyms and some company logos may not be easily recognizable to all consumers. Therefore, the complete name of the person or body that certified the food as halal must be present.

There are no specific requirements on the proximity of a halal claim and the name of the person or body that certified the food to one another.

The intent of the requirement is to provide additional information to consumers so as to enable them to make informed decisions about the food they purchase. Like all claims, halal claims must be truthful and not misleading.

Homemade, Artisan Made

The term "homemade" describes a food that is not commercially prepared. "Homemade" foods do not require further preparation. The use of a brand name or trademark symbol in conjunction with the term "homemade" is considered misleading if the food is prepared in a commercial establishment, including small, artisan like establishments.

The terms "homemade style", "home-style", "like homemade" may be used to describe a food that may contain mixes, in whole or in part, from commercial or private recipes. In advertising, these terms are potentially misleading when the food is portrayed in a home setting.

When a food is prepared in the style of a "homemade" food, the term must be qualified (e.g., "homemade" baked beans versus "homemade style" canned baked beans).

The claim "tastes like homemade" is left to the judgment of the consumer and is, therefore, acceptable.

The claim "Artisan made" describes products that are manufactured in small batches. The claim "Artisan made" is not specific for a particular type of food, rather it is a manufacturing method that would be considered traditional and rudimentary, involving a significant portion of manual labour and a limited use of automated machines performing functions on mass quantities of food, as compared to similar products. The use of additives and preservatives that would typically be purchased from a grocery store and found in a common household kitchen such as vinegar, salt, sugar, lemon juice would be acceptable. The process of heat treatment and sterilization would be accepted for food safety purposes.

The claim "artisan-style" may be used to describe a food prepared in the style of an "artisan" food. In this case, it is a best practice to qualify the claim "artisan-style" to describe how it is different from an "artisan" food.

Method of Production Claims for Meat, Poultry and Fish Products

Claims about how meat, poultry and fish were raised or fed are voluntary. However, when used on a food label or advertisement, the guidance outlined below is intended to assist with industry compliance and consumer protection.

Natural Claims

Meat, poultry and fish products may bear the claim "natural" if they use the same criteria as all foods. Refer to Nature, Natural for more information on the criteria for making a natural claim.

Given that the definition of "natural" is not based on raising practices, the claim "naturally raised" may be used as long as further explanation of what is meant by the claim appears along with the claim on the label, to avoid misleading the consumers.

Other, more specific claims that convey information on the methods used to raise a particular animal may be used, as long as they are truthful and not misleading.

Feed Claims

The following criteria support several different feed claims and their variations.

  1. "Fed no" or "raised without" and

    • animal products,
    • animal by-products,
    • animal fat,
    • animal meal, and/or
    • bone meal.

    The above claims may only appear on meat, poultry, or fish products that were raised on feed that is free of ingredients or components of ingredients of animal origin (including animal products (definition) and animal by-products (definition)). This criteria applies to:

    • non-nutritive feed additives
    • supplemental sources of minerals and vitamins that contain animal products, such as
      • vitamins and minerals which are encapsulated in gelatin of animal origin
      • vitamin D3 derived from the lanolin of sheep wool

    Each of these claims may be used provided they are accurate, truthful and not misleading. For example, a meat product labelled "fed no bone meal" may be acceptable when the animal feed is free of all ingredients or components of animal origin.

    An exception to the above is that for ruminants, until a legally approved non-animal source of vitamin D3 is available in Canada for use in feed, a meat product of these species fed vitamin D3 derived from lanolin of sheep's wool may bear these claims (e.g. "Fed no animal by-products"), as long as a statement is added to inform the consumer of the source of vitamin D3.

    Some animal feed is manufactured with bakery and snack food waste that contains animal products as well as animal by-products. If this type of feed is used, the resulting meat products may not be labelled or advertised with these claims.

    The milk fed to an animal is not taken into consideration when evaluating these claims for the absence of animal products and animal by-products in the animal's diet.

  2. "Grain fed"

    This claim may be used when a minimum percentage of the feed is made up of grains (definition) and grain by-products calculated over the animal's entire life cycle. The minimum percentages of grain content are as follows:

    • feed for beef and other sources of red meat: 75 percent
    • feed for turkey: 80 percent
    • feed for chicken: 85 percent

    The remaining portion of the feed may contain other feed ingredients, regardless of origin. Examples include

    • minerals
    • vitamins
    • antioxidants (for preservation)
    • fish meal (as a source of omega-3 or omega-6)
    • enzyme supplements
    • pellet binders
    • anti-caking agents (to help with milling and pelleting)
    • flavouring agents
    • medications
    • other non-nutritive feed additives

    Note that the species-specific percentages are based on attainable levels of grain in feed. Because of nutritional needs, most animals are not fed diets made only of grains. Other ingredients are an important part of the feed, required to make it nutritionally balanced.

  3. "Grain fed" and

    • no animal products,
    • no animal by-products,
    • no animal fat,
    • no animal meal, and/or
    • no bone meal.

    These claims are a combination of the criteria for the claims in sections A) and B), mentioned above.

    For example, "grain fed, no animal meal" or "grain fed, no bone meal or animal fat" may be acceptable if the feed

    • uses the criteria for "grain fed" (section B), and
    • is free of ingredients or components of ingredients of animal origin (section A).

    Note the exception made for ruminants meat products that may bear claims referred to in section A, as long as the clarifying statement is added.

    Please refer to sections A) and B) for complete details.

"Raised Without the Use of Antibiotics" Claims

To display the claim "raised without the use of antibiotics," in relation to a meat, poultry or fish product, the animal may not have been treated with antibiotics (definition), administered by any method, from birth to slaughter or harvest.

This includes administration through

  • feed,
  • water,
  • injection,
  • local application, or
  • injection to embryos and eggs.

In addition, antibiotics may not be given to the lactating mother of the animal in question in any manner that would result in antibiotic residue in the animal.

In the event that antimicrobial agents (definition) are given for the purpose of having an antimicrobial effect, the claim may not be consistent with subsection 5(1) of the FDA and section 7 of the CPLA.

Meat, poultry and fish products are not considered eligible to make the claim "raised without the use of antibiotics" if the animals were raised with arsenicals or substances that fall into the four categories of antimicrobial drugs listed in Health Canada's antimicrobial categorization documentFootnote 1. Examples include:

  • aminoglycosides, such as gentamicin and neomycin
  • beta-lactams including penicillins and cephalosporins, such as amoxicillin and ceftiofur
  • fluoroquinolones, such as enrofloxacin and danoflaxacin
  • ionophoresFootnote 2, such as monensin
  • macrolides, such as tylosin
  • streptogramins, such as virginiamycin
  • sulphonamides
  • tetracyclines

However, meat, poultry and fish products may claim "raised without the use of antibiotics" if the animals were raised with the following veterinary drugs or biological products (the list is not exhaustive):

  • vaccines
  • antisera
  • colostrum
  • chemical coccidiostats, such as amprolium and decoquinate
  • direct-fed microbial products registered with the CFIA as feed ingredients

Additionally, in order for the claim to be used, vitamins and minerals given to the animals may only be given at the level of physiological action for dietary supplement, not for antimicrobial effect.

A claim such as "fed no antibiotics" may imply that the animal was raised without the use of antibiotics in cases where the animal has received antibiotics through injection or spraying. If such a claim is applied, the criteria for the claim "raised without the use of antibiotics" may be used to avoid misleading information.

"Raised Without the Use of Added Hormones" Claims

Meat, poultry and fish products may carry the claim "raised without the use of added hormones" on the label or advertising as long as no hormones or β-agonists, such as ractopamine, were administered in any way to the animal. In addition, hormones may not be administered to the lactating mother of the animal in question in any manner which would result in increased hormone levels in the animal. However, consumers may not be aware that the use of hormones is only permitted with certain animals.

  1. In cases where the use of hormones is legally authorized and none were used, the products may claim "raised without the use of added hormones."
  2. In cases where the use of hormones is prohibited or not authorized, the claim "raised without the use of added hormones" may be considered misleading as it creates false uniqueness between similar products. This misleading impression may be avoided by applying an additional statement, such as "like other (naming the product or source animal)".

For example, since the use of hormones is not authorized in Canada for chickens, the use of the claim "raised without the use of added hormones" on chicken products could imply that other chickens may have been raised using hormones. A claim such as "like other chickens, this chicken was raised without the use of added hormones" may be used.

The claim "hormone free" used without any other information could create the impression that the animal product in question does not contain hormones. As meat, poultry and fish products contain naturally occurring hormones, the claim "hormone free" is not considered acceptable.

The claim "no growth stimulants" may also be misleading for consumers and be inconsistent with the relevant legislation on truthful and accurate labelling. Due to a broad and diverse understanding of the term "growth stimulant," the simple statement "no growth stimulants" could mean the absence of a number of substances (such as hormones, β-agonists or low dose of antibiotics) and the presence of others (such as vitamins and minerals).

Method of Production Claims for Fresh Fruits and Vegetables

Genetic Engineering Claims

Claims that a fresh fruit or vegetable is or is not a product of genetic engineering may be made if it meets certain criteria. Refer to Voluntary Labelling and Advertising of Foods That Are and Are Not Products of Genetic Engineering for more information.

"Free of Pesticides Residues" Claims

The use of the claim "free of pesticides residues" on fresh fruits and vegetables may be considered misleading and is subject to subsection 5. (1) of the Food and Drugs Act and section 3.1 (1) (g) and 6. (1) of the Fresh Fruit and Vegetables Regulations. These legislation prohibits claims that may create an erroneous impression regarding the character, value, quantity, composition, merit or safety of the product.

Growing practices (soil, hydroponic or greenhouse) for fruits and vegetables may involve direct, indirect use of or exposure to pesticide or pest control product. For example, fresh produce may be exposed to residue of pesticides present in soil and/or water from background contamination, chemical drift or runoffs. Considering the possibility that pesticides can remain or move in the environment before crop emergence, claim such as "free of pesticide residues" may be considered misleading.

It is the responsibility of the regulated party to demonstrate that their product is free of pesticides residues when such claims are made.

Annex 1 – Minimum Processes

Examples of Processes Affecting the Natural Character of Foods with a minimum of Physical, Chemical or Biological Changes

  • Aeration
  • Ageing
  • Agglomeration (without chemical change or addition)
  • Blending
  • Centrifugation
  • Chilling (including refrigerating and freezing)
  • Chopping
  • Churning
  • CleaningFootnote 3
  • Concentration (without chemical change)
  • Cutting
  • Deboning (manual)
  • Defatting (without chemical change)
  • Degerming
  • Dissolving
  • Drying, dehydration, desiccation, evaporation, freeze-drying
  • Emulsifying (without synthetic chemical addition)
  • Extrusion
  • FermentationFootnote 3
  • FilteringFootnote 3 and clarifying
  • Fining, finishing (without chemical change)
  • Flaking
  • Flocculation (without chemical addition)
  • Forming
  • Fumigation
  • Grating
  • Grinding
  • Heating (including baking, blanching, boiling, canning, cooking, frying, microwaving, pasteurizing, sterilizing, parboiling, roasting)
  • Homogenization
  • MaturationFootnote 3 (without chemical addition)
  • Melting, thawing
  • Milling
  • Mixing, blending
  • Packaging, canning
  • Peeling (without chemical change)
  • Pressing
  • Puffing
  • Reconstitution (without chemical addition)
  • RipeningFootnote 3 (other than by chemical means)
  • Separating (including screening, clarifying, centrifugation, decanting, extraction, filtering, shelling, trimming)
  • Shredding
  • Smoking (without direct chemical addition)
  • Soaking
  • Treatment with inert gases (nitrogen pack)
  • Treatment with toxic gases (with no chemical change)

Annex 2 – Maximum Processes

Examples of Processes Affecting the Natural Character of Foods with a maximum of Physical, Chemical or Biological Changes

  • Anion exchange
  • Bleaching (with chemical addition)
  • Cation exchange
  • Conversion (with chemical addition or synthesis)
  • Curing (with chemical addition)
  • Deboning (mechanical)
  • Decaffeination (with chemical addition)
  • Denaturation (with chemical change)
  • Enzymolysis (with chemical addition)
  • Esterification
  • Hormonal action
  • Hydrogenation
  • Hydrolysis (with chemical addition)
  • Interesterification
  • Oxidation (with chemical addition)
  • Reduction (with chemical addition)
  • Smoking (with chemical addition)
  • Synthesis (chemical)
  • Tenderizing (with chemical addition)

Additional Information

Labelling of Genetically Engineered Foods in Canada

Fact Sheet - Labelling of Genetically Engineered Foods in Canada

Information Letters/ Policy Updates

Definitions

Animal By-product

Animal by-product includes blood or any of its components, bones, bristles, feathers, flesh, hair, hides, hoofs, horns, offal, skins and wool, and anything containing any of those things [2(1), Health of Animals Act].

Animal Product

Animal product includes cream, eggs, milk, non-fertilized ova and semen [2(1), Health of Animals Act].

Antibiotic

Antibiotic is any drug or combination of drugs such as those named in C.01.410 to C.01.592 which is prepared from certain micro-organisms, or which formerly was prepared from micro-organisms but is now made synthetically and which possesses inhibitory action on the growth of other micro-organisms [C.01.001(1), Food and Drug Regulations].

Antimicrobial Agent

Antimicrobial agent means a naturally occurring, semi-synthetic or synthetic substance that exhibits antimicrobial activity (kills or inhibits the growth of micro-organisms) at concentrations attainable in vivo. Anthelmintics and substances classed as disinfectants or antiseptics are excluded from this definition. (OIE: World Organisation for Animal Health)Footnote 4

Grain

For the purpose of a grain fed claim:

Grain includes barley, beans, buckwheat, canola, chick peas, corn, fababeans, flaxseed, lentils, mixed grain, mustard seed, oats, peas, rapeseed, rye, safflower seed, soybeans, sunflower seed, triticale and wheat [Canada Grain Act and Canada Grain Regulations].

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