Food > Labelling > Guide to Food Labelling and Advertising > Chapter 13 

Chapter 13 - Guide to the Labelling of Maple Products

Introduction

Most of Chapter 13 applies to maple products obtained exclusively from the maple sap such as maple syrup, maple sugar, soft maple sugar, maple butter and maple taffy, which have been produced in establishments which are federally registered with the Canadian Food Inspection Agency (CFIA) or imported. These products are destined for interprovincial, import or export trade.

Maple products are regulated by the

• Maple Products Regulations (MPR)
• Food and Drugs Act (FDA) & Regulations (FDR)
• Consumer Packaging and Labelling Act (CPLA) & Regulations (CPLR)

Information that is required by the Act and these Regulations to be shown on a label, shall be shown in a manner easily legible to the consumer under normal or customary conditions [15, CPLR].

The requirements described below are applicable for maple syrup shipment of more than 100 L and maple products shipment of more than 25 kg. Some other exemptions for non commercial shipments are applicable, as defined in 13.14 below [18, MPR].

Export

Export requirements are described in 13.12 below.

Import and Interprovincial Trade

These sections below are applicable for import and interprovincial trade of prepackaged products. Import and interprovincial labelling requirements for shipping containers and bulk containers are the same as for prepackaged products, except for the situations described in 13.11.1 and 13.11.2 of this Guide [15(1), 19(2)(a), MPR].

13.1 Common Name [2, 12, 19, MPR; B.01.001, B.01.006; 10(b)(ii), CPLA]

Product identity declaration consists in the designation of a product by its common or generic name or by its function. Every product must bear the name "Maple Syrup" and "Sirop d’érable" or the name of the its contents if it is a maple product other than maple syrup.[12(1)(a), 12(3), MPR]

"maple syrup" means the syrup obtained by the concentration of maple sap or by the dilution or solution of a maple product, other than maple sap, in potable water; (sirop d'érable) [2, MPR].

"maple product" means any product obtained exclusively by the concentration of maple sap or maple syrup, excluding any substitute; (produit de l'érable) [2, MPR].

"substitute" means any product that resembles a maple product in appearance and is prepared for the same uses as a maple product but is not obtained exclusively from maple sap; (succédané) [2, MPR].

(See 13.13 below for information about the labelling of maple syrup substitutes).

13.1.1  Location [B.01.006(1); 12(b), CPLR]

The common name must be shown on the principal display panel of the label or package.

13.1.2  Type Size [A.01.016; 14(1), 15, CPLR]

The height of the letters used is based on the area of the principal display surface. The common name must be shown in type of at least 1.6 mm in height, based on the lower case "o".

Principal Display Surface of the Packaging		Minimum Height of letters and numerals
square centimetres	square inches	millimetres	inches
32	5	1.6	1/16
> 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

13.1.3  Language [12(1)(a), MPR; B.01.012(2); 6(2), CPLR]

The common name must appear in English and French.

13.1.4 List of Ingredients

As explained in 13.1 of this Guide, maple products and maple syrup covered under the MPR are made exclusively from the concentration of the maple sap or a dilution or solution of a maple product in potable water. For such single ingredient foods, the common name of the product is considered to be the list of ingredients.

13.2  Net Quantity Declaration [10(5), 12(1)(d), 19(1)(vi), MPR; 14,15, CPLA; 22(1)(3), CPLR]

For maple syrup, the metric net quantity must be shown in units of volume (mL, L) as the product is a liquid. For other maple products, the metric net quantity must be shown in units of weight (g, kg). There are prescribed standard container sizes for maple syrup and maple sugar. See 13.8 of this Guide.

13.2.1 Location [B.01.006(1); 4(2), CPLA; 12(a), CPLR]

The net quantity declaration must be shown on the principal display panel of the label.

13.2.2  Type Size [12(2), MPR; 14, 15, CPLR]

A minimum type height of 1.6 mm, based on the lowercase "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 above table, included in 13.1.2 of this Guide.

13.2.3  Language [B.01.012(2); 6(2), CPLR]

The net quantity declaration must appear in English and French.

13.3 Maple Syrup Grade [4, 12(1)(b), 19(1)(a)(i), Schedule I, MPR]

Maple syrup grades must be used in the following cases:

1. when the maple syrup has been manufactured, graded and repackaged in a registered establishment
2. when the maple syrup was imported and sold in its original container.

A Canadian company manufacturing a product for which a grade standard is prescribed must be registered with the CFIA in order to have the authority to apply the grades prescribed for this product. Moreover, displaying a grade on a maple product, other than maple syrup, for which the Regulations do not prescribe grade standards, is prohibited.

13.3.1  Canadian Maple Syrup [5(2), 5.1, MPR ]

In order to use a Canadian grade on the label, an establishment must be federally registered with the CFIA.

Products graded in an establishment registered in Canada must declare a grade beginning with the word "CANADA," e.g., CANADA No.1.

13.3.2  Imported Maple Syrup

The use of American grades on products sold in Canada is not permitted. Imported maple syrup must meet the MPR requirements, must be graded with Canadian grades, using the "Grade" prefix instead of "Canada" (see table below) and the country of origin must be indicated.

Combining declarations of country of origin and grade is not permitted. For example, "Product of / Produit du Canada No. 1" is not permitted.

Maple syrup imported in bulk in Canada must bear a grade beginning with the word "CANADA" once they have been graded, processed or repacked in a registered establishment.

13.3.3  Location [12(1)(b), MPR]

Designation of grade must appear on the principal display panel of the label.

13.3.4  Type Size [12(1)(b), MPR; 14, 15, CPLR]

The height of the letters used is based on the area of the principal display surface (see the above table in section 13.1.2). The grade must be shown in type of at least 1.6 mm in height, based on the lower case "o".

13.3.5 Language  [B.01.012(2); 6(2), CPLR]

The maple syrup grade information must appear in English and French.

13.4 Maple Syrup Colour [12(1)(c), schedule III, MPR]

Maple syrup with a colour class found to be Extra light, Light or Medium may be graded as "Canada No. 1", providing it meets the requirements of the "Canada No. 1" grade. Maple syrup with a colour class found to be Amber may be graded as "Canada No. 2" providing it meets the requirements of the "Canada No. 2" grade. Maple syrup with a colour class found to be Dark may be graded as "Canada No. 3" providing it meets the requirements of the "Canada No. 3" grade. Note that all the above colour classes could be used in combination with the "Canada No. 3" grade for maple syrup that meets only the Canada No. 3 requirements. The method for the determination of colour class of maple syrup is outlined in Schedule III, MPR.

13.4.1  Location  [12(1)(c), MPR]

The colour designation must be printed immediately after the grade on the principal display surface of the container, example: "Canada No. 1 Médium/Canada No. 1 Medium".

13.4.2  Type Size  [12(c), 19, Schedule IV, MPR]

The height of the letters used is based on the area of the principal display surface (see the above table in section 13.1.2). The colour must be shown in type of at least 1.6 mm in height, based on the lower case "o".

13.4.3  Language  [12(1)(c), MPR; B.01.012(2); 6(2), CPLR]

The maple syrup colour must appear in English and French.

13.5  Name and Address

Domestic Maple Products [12, MPR]

The name and address of the responsible party must be indicated as follows:

• the name and address of the sugar bush establishment, the packing establishment or the maple syrup shipper establishment, or

• the name and address of the first dealer and the registration number of the packing establishment.

Imported Maple Products [19, MPR]

The name and address of the packer or the importer must be indicated on the label.

13.5.1  Location  [B.01.005; 13, CPLR]

The name and address of the party responsible may be shown anywhere on the label, except on the bottom of the packaging.

13.5.2  Type Size  [14, 15, CPLR]

The height of the letters used is based on the area of the principal display surface (please refer to 13.1.2 of this Guide). The name and address must be shown in type of at least 1.6 mm in height, based on the lower case "o".

13.5.3  Language  [B.01.012(2); 6(2), CPLR]

This information may be written in English and / or French.

13.6 Registration Number [12, MPR]

Canadian-made maple products regulated by the MPR that are sold on interprovincial or export markets must be prepared in a registered establishment for which a registration number has been assigned by CFIA.

13.6.1  Declaration

The registration number must be applied to the label when the name and address on the label is that of a first dealer. A manufacturer may or may not add its registration number to a label when its complete name and address is indicated.

13.6.2  Location

The registration number can be anywhere on the label, including on the bottom of the package. It is recommended, however, that the registration number be close to the name and address of the person responsible.

13.6.3  Type Size  [A.01.016; 15, CPLR]

The registration number must be shown in type of at least 1.6 mm in height, based on the lower case "o".

13.7 Country of Origin  [19, MPR]

We recommend that the country of origin marking be preceded by "Product of... \ Produit de..." However, no further marking indicating the country of origin would be required if it is an integral part of the name and address of the foreign producer, for example: "ABC Maple Farm, Vermont, USA."

Imported Maple Products

Imported maple products must carry a declaration of the country of origin.

Imported Maple Product, Processed in Canada

When a foreign product undergoes any processing in Canada, the origin of the product may change, for example:

• Maple syrup imported from the United States in bulk and processed into maple sugar would be classified as "Product of Canada/ Produit du Canada".

Imported Maple Product, Graded and Re-Packed in Canada

If the product is only graded and re-packed in Canada, its declaration of the country of origin cannot be changed to "Product of Canada /Produit du Canada."

Canadian Maple Product Packed in a Foreign Country, and Re-Imported in Canada

Canadian maple products which have been shipped to and packed in a foreign country and then re-imported to Canada must have the following statement on their label : "Product of Canada, Packed in . . . / Produit du Canada, emballé au . . .".  The abbreviation "USA" may be used because it is recognized around the world. However, all other abbreviations are not permitted because they could cause confusion among consumers and thus the name of the country of origin must be written out in full.

13.7.1  Location  [B.01.005]

This information must appear on any surface of the package, with the exception of the bottom.

13.7.2  Type Size  [14, 15, CPLR]

The country of origin must be shown in type of at least 1.6 mm in height, based on the lower case "o".

13.7.3  Language  [B.01.012(2); 6(2), CPLR]

This information may be written in English or/and French.

13.8 Standard Container Sizes for Maple Syrup and Maple Sugar

•  Maple Syrup [10(3) , Schedule V.1, MPR]
  The containers prescribed by the MPR are:

  250 ml or less (sizes in whole numbers) 375 ml 500 ml 540 ml (19fl oz.)	750 ml 1 L 1.5 L Any whole number multiple of 1L

• Maple Sugar [10(4), MPR]
  The containers prescribed by the MPR are:

  125 g or less 250 g 375 g 500 g

  750 g 1 kg any multiple of 1 kg

There are no standard container sizes prescribed for other maple products.

13.9  Nutrition Labelling

Amendments to the Food and Drug Regulations will make nutrition labelling mandatory for most prepackaged products by December 12, 2005. Small companies with revenues from the sale of food of less than $1 million in Canada for the 12 months prior to December 12, 2002 have a five year transition period. These regulations affect the maple products. More details on the requirements for nutrition labelling can be found in Chapters 5 and 6 of this Guide.

13.10  Nutrient Content Claims

Nutrient content claims can be made on some products. For more information on the conditions for making these claims, refer to Chapter 7 and 8 of this Guide.

13.11 Labelling of Shipping Containers and Bulk Containers

The labelling requirements for shipping containers and bulk containers are the same as for prepackaged products [15(1), 19(2)a), MPR]. Bulk containers are defined containers as exceeding 5 L for maple syrup and containers exceeding 5 kg for maple products [19 (2), MPR].

13.11.1 Interprovincial Trade [15(2), MPR]

Interprovincial trade of bulk containers, in which the product is not graded or marked in compliance with the MPR, is allowed if the product is to be repacked or reprocessed in a registered establishment.

13.11.2  Import Authorization [19(2)(b), MPR]

Bulk containers that are not marked as per the labelling requirements must be accompanied by a written authorization from the CFIA, for each shipment, prior to entry into Canada. Please, contact your local CFIA office to know how to obtain such an authorization.

13.11.3  Shipping Containers

Although the MPR set out the marking for shipping containers in 12 and 19, it is a recognized acceptable commercial practice for the number and capacity of the individual prepackaged containers (eg. 12 x 540 ml), as well as the registration number, to be printed on the shipping container. Other information required by the Regulations is then provided by a sample of the label used on the individual inner prepackaged product being displayed on the shipping container.

13.12  Export

Export of products packed in non-standard container sizes (including bulk and shipping containers) and not marked in compliance with the Canadian regulations is allowed if

1. the CFIA establishment registration number is shown on the container, the bill of lading or the contact of sale (see the introduction of this Chapter and 13.6 of this Guide for information about CFIA establishment registration); and
2. the label or other markings on the product make no false declarations and no misrepresentation of the quality, composition, character, safety, or value of the food product [16(2), MPR].

FDA&R and CPLA&R Requirements

Different sections of the FDA&R and CPLA&R are referenced in the section "Import and Interprovincial Trade". Concerning the export trade, it is important to remember that the FDA&R is applied only for products sold in Canada, as defined in section 37(1) of the FDA :

"This Act does not apply to any packaged food, drug, cosmetic or device, not manufactured for consumption in Canada and not sold for consumption in Canada, if the package is marked in distinct overprinting with the word "Export" or "Exportation" and a certificate that the package and its contents do not contravene any known requirement of the law of the country to which it is or is about to be consigned has been issued in respect of the package and its contents in prescribed form and manner" [37(1), FDA].

Labelling Requirements of the Receiving Country

If in doubt about a foreign country's requirements on imported foods, it is advisable that you enquire through the importing country's department of agriculture or perhaps through their embassy/consulate/trade commission in Canada before exporting to that country.

13.13  Substitutes

Pure maple products are unique and must come exclusively from the concentration of the sap of maple trees (see definitions in 13.1 of this Guide) Maple substitutes are defined as follows in the MPR :

"substitute" means any product that resembles a maple product in appearance and is prepared for the same uses as a maple product but is not obtained exclusively from maple sap (succédané) [2, MPR]

It can be difficult for consumers to differentiate pure maple products from food products made with other types of sugar, maple flavour preparations, or a blend of maple products and other ingredients.

Section 3.1 of the MPR specifies that " no person shall market a product in import, export or interprovincial trade in such a manner that it is likely to be mistaken for a maple product for which a grade or standard is established under these Regulations".

Naming Table Syrup Containing Some Maple Syrup

A product made from sugar, water, maple flavouring and, for example, with less than 20 % maple syrup added may not be called "Canadian Maple Syrup". Common names for this product, to which the CFIA is not likely to object are: "Canadian Table syrup with x % Maple Syrup", "Canadian Blended Syrup with x % Pure Maple Syrup ", where x is the correct % of maple syrup actually in the product.

13.13.1 List of Ingredients

For maple substitutes, the list of ingredients must comply with the FDR. (see 2.8 of this Guide gives information on how to declare a list of ingredients. For single ingredient foods such as pure maple syrup and maple products, the common name of the product is considered to be the list of ingredients.

The list of ingredients may appear on any surface of the label, with the exception of the bottom and must appear in both English and French. The minimum type size height must be 1.6 mm, based on the lowercase "o".

13.13.2 Provincial Regulations on Substitutes

In the province of Quebec and Ontario, the provincial authorities have specific regulations on maple and maple products but also on the use of the word "maple" on maple substitutes. For products destined for this market, it may be preferable to contact them as to the acceptability of the use of the word "maple" or maple images on products which do not fall under the Maple Product Regulations.

You may contact them at:

• QUÉBEC

  Ministère de l’Agriculture, des Pêcheries, et de l’Alimentation ( MAPAQ)
  200, chemin Ste-Foy, 11e étage
  Québec (Québec)
  G1R 4X6
  Phone: 1-800-463-5023
  Website : http://www.agrireseau.qc.ca/erable/

• ONTARIO

  Ontario Ministry of Agriculture and Food (OMAF)
  Risk Management Specialist - Foods of Plant Origin
  5th Floor NW
  1 Stone Rd W
  Guelph , ON N1G 4Y2
  Phone: 613-475-5175 Fax: 519-826-4375
  Website (food): http://www.gov.on.ca/omaf/english/food/
  Website (maple): http://www.gov.on.ca:80/OMAFRA/english/crops/facts/maple.htm

13.14  Exemptions for Non-Commercial Shipments [18, MPR]

This chapter does not apply to a shipment of maple syrup or maple products that

• does not exceed 100 litres or weighs 25 kg or less
• is part of an immigrant’s effects
• is carried on any vessel, train, motor vehicle, aircraft or other means of transportation for use as food for the crew or passengers thereof
• is consigned to a national or an international exhibition, weighs 100 kg or less and is not intended for sale in Canada
• is imported from the United States onto the Akwesasne Reserve for use by an Akwesasne resident
• is bonded.

13.15  Information on the Absence or Non-Addition of Non-Permitted Ingredients or Chemicals

Information concerning the absence or non-addition of non-permitted ingredients or chemicals is not permitted in maple products labelling or advertising. A claim pertaining to the absence or non-addition of non-permitted ingredients or chemicals infers a false uniqueness and gives an unfair advantage to the food. Such a claim infers that other similar maple products contain non-permitted ingredients or chemicals when in fact, Canadian regulations prohibit the use of this substance. Therefore, this type of claim is considered misleading under subsection 5(1) of the FDA.

13.16  Maple Syrup with Nutrients Added

Section D.03.002 of the FDR prohibits the addition of nutrients to maple syrup or maple products sold in Canada. However the product may be produced in Canada for export trade providing the requirements of section 37 of the Food and Drugs Act are met.

For example, if a maple product contains added vitamin C, it should clearly indicate that vitamin C is added, by modifying the common name, adding a statement and/or a list of ingredients, subject to the regulations of the receiving country.

Summary of Mandatory Maple Syrup Labelling Requirements
Table 13-1

Summary of Mandatory Maple Products Labelling Requirements
Table 13-2