Decisions: Basic Labelling

The "bottom" of a food or container

Question:  The Food and Drug Regulations B.01.005 (1) states that, "Subject to subsection (2) to (5), the information required to be shown on a label shall not be shown on the part of the label, if any, that is applied to the bottom of the food or container."

How is the "bottom" of a food or container to be defined when the food or container could be displayed for sale in a flat or upright position?

Answer: The bottom is defined as that part of a food or container which may reasonably be expected to be the surface on which the container rests when displayed for purchase. Some containers have several options as to how they can be displayed. If a food or container is labelled or printed in such a way that it may reasonably rest on any of the sides, then there is no bottom (e.g., as a frozen chicken dinner in a box may be displayed on more than one side, there is no definable bottom. In contrast, one would not reasonably expect a lemon meringue pie to be displayed on its side as it would result in damage to the product, and hence there is a definable bottom).

In the case of a container with no one definable bottom, the CFIA does not not object to mandatory information being on any panel (other than the mandatory information that must appear on the principle display panel).

For nutrition labelling purposes, note that the Nutrition Facts table may appear on any surface of the package, including the bottom if the available display surface includes the bottom (B.01.005(5)). (updated 2006)

Label Information on Protective Wrappings

Question: Can protective wrappings have partial label information, e.g. common name or the net content only?

Answer:  Protective wrappings do not require labels, provided they are placed inside properly labelled shipping containers. If the wrapped product is intended for sale to consumers, it is the responsibility of the retailer to label the product with all mandatory label information.

If label information is present on protective wrappings when the product leaves an establishment, this information must be complete, or the wrappings must have no information present. The presence of partial information is unacceptable, except a production code. (May/2005)