Canadian Food Inspection Agency
Guide to Food Labelling and Advertising

Section VI: Nutrient Content Claims
Section 6.2.4

6.2.4 Carbohydrate, Sweeteners and Dietary Fibre

6.2.4.1 How to Declare Carbohydrate and Sweeteners

Carbohydrate includes: sugars such as monosaccharides (e.g., glucose), disaccharides (e.g., sucrose), etc.; sugar alcohols (isomalt, lactitol, maltitol, maltitol syrup, mannitol, sorbitol, and xylitol); polydextrose; starch; and dietary fibre. All are expressed in grams per serving of stated size and are rounded to the nearest whole number for quantities of 10 g or more, and to the nearest tenth of a gram for quantities less than 10 g. If no carbohydrate is present, its absence should be indicated by a zero. The declaration of one carbohydrate component does not trigger the declaration of any of the others.

The label of a food containing one or more of the sugar alcohols listed above, or polydextrose, must carry a statement of the specific name and amount of each, grouped together, in g/serving of stated size (B.01.018). The amount of each may be declared in the ingredient list, in a list in immediate proximity to the ingredient list, or in the nutrition panel as indicated below.

Aspartame, sucralose, acesulfame-potassium are sweeteners which must be declared on the principal display panel (see B.01.014 and B.01.015 for the labelling of aspartame; B.01.016 and B.01.017 for sucralose; and B.01.019 and B.01.020 for acesulfame-potassium). In the nutrition labelling format sucralose, aspartame,and acesulfame-potassium are declared in milligrams. No objection would be made, however, to declaring aspartame after protein.

6.2.4.2 No Sugar Added, Unsweetened, Not Sweetened (Amended 31/01/97)

The term "no sugar added", "unsweetened" or "not sweetened" requires a declaration on the label of the total quantity of sugars (all mono and disaccharides) in the food in grams per serving of stated size. If the claim is made in an advertisement, the sugars declaration may be on the label or in the advertisement (B.01.304, FDR). The terms may be used on foods which do not contain any added sugars (sugar, honey, molasses, fructose, glucose or other mono and disaccharides), or any ingredient or component which contributes a significant amount of sugars to the food.

Rationale: The terms "no sugar added", "unsweetened" or "not sweetened" imply that the food contains no added sugar and are technically sugars claims under section B.01.300 (FDR). Consumers limiting sugars need to know the amount of naturally occurring sugars in the food.

Example: "unsweetened" juices.

Exceptions:

1. The following are conditions under which the claim "no sugar added" can be used, even if sugars other than sucrose are present:

If sugar is to be added to a food by consumers before it is consumed, e.g., fruit drink mixes. When the claim "no sugar added" is made, a statement indicating that sugar should be added during the preparation of the foods should accompany the claim to inform consumers that the product is not sweet. A statement such as "sweeten to your own taste" would meet this requirement.

If the statement "no sugar added" is used to describe a food sweetened with some other product such as honey, molasses or juice, and if the expression is intended to indicate the non-addition of sucrose rather than the non-addition of other sugars, i.e., monosaccharides or other disaccharides. There would be no deception if this expression is accompanied, in equal prominence, by an indication of the replacement sweetener, e.g., "contains no added sugar (sucrose), sweetened with honey".

2. Unsweetened and semi-sweet chocolate are products used mainly for further processing and not for direct consumption by the consumer. The use of the common names "unsweetened chocolate" and "semi-sweet chocolate" has a long history and such use does not require a declaration of the sugars content on the label or in an advertisement.

6.2.4.3 Less Sweet, Lightly Sweetened (Amended 31/01/97)

The term "less sweet" or "lightly sweetened" requires a declaration of the total quantity of sugars in the food in grams per serving. They are comparative claims, acceptable on foods which have a minimum reduction in sugars content of 25 percent and a decrease of 5 g in sugars per serving, with no increase in energy compared to a similar reference food. A statement indicating the reference food and the amount of reduction should appear, grouped with the most prominent claim.

Rationale: The term "less sweet" implies that the food contains less sugar than a similar food; the term "lightly sweetened" is considered to imply that the food contains less sugar than the regular counterpart which is "sweetened" (unqualified). As such, both fall under the requirements for sugars claims (B.01.300, FDR) and the policy for comparative claims (Section 6.1.9). "Lightly" would also be subject to the policy on light (Section 6.1.10).

Example:"lightly sweetened" yogurt.

6.2.4.4 Sweet, Sweetened

Where the term "sweet" or "sweetened" is used, a declaration of the sugars content on the label or in an advertisement is not required.

Rationale: Although technically, sugars claims trigger a declaration of the sugars content (B.01.300, FDR), these claims have been traditionally used on foods to indicate sweetness or sweetening. Consumers who are attempting to limit sugars, such as those with diabetes, are alerted to the high sugar content by the claim "sweetened". There is concern that some manufacturers may not indicate that the food is "sweetened" if such a claim triggered a declaration of the sugars.

Examples: Examples of "sweet" and "sweetened" claims not requiring sugars declaration include "sweetened apple juice", "sweetened condensed milk" and "sweet chocolate".

A claim referring specifically to a "sweet taste", such as "does not taste sweet", is considered to be a taste claim and would not trigger a sugars declaration.

6.2.4.5 Summary Table of Carbohydrate Claims

The following table provides a summary of the Regulations and guidelines pertaining to carbohydrate claims (see also Sections 6.1, 6.3 and 6.4).

* When claims are made on a label, unless otherwise specified, this information must appear on the label. For advertising claims, the required information must appear either in the advertisement or on the label.

6.2.4.6 Dietary Fibre and Novel Fibre

Dietary fibre is defined* as the endogenous components of plant material in the diet which are resistant to digestion by enzymes produced by humans. They are predominantly non-starch polysaccharides and lignin. The composition varies with the origin of the fibre and includes soluble and insoluble substances.

Fruits, nuts, legumes and cereals, when traditionally processed or prepared, are considered to be natural sources of dietary fibre. Their fibre content may be included in the declaration of total dietary fibre content.

Novel fibre or novel source is defined* as a food that has been manufactured to be a source of dietary fibre, and:

1. has not traditionally been used for human consumption to any significant extent; or
2. has been chemically processed (e.g., oxidized) or physically processed (e.g., very finely ground) so as to modify the properties of the fibre; or
3. that has been highly concentrated from its plant source.

(* These definitions were recommended by the Expert Advisory Committee on Dietary Fibre, 1985, reporting to Health Canada.)

Dietary fibre is associated with beneficial health effects, but these cannot be predicted from chemical analysis. It must be demonstrated that a novel fibre is safe and that it functions physiologically as dietary fibre for it to be considered a source of dietary fibre.

The safety of novel fibre sources must be established before they may be used as ingredients in foods.

The physiological efficacy of novel fibre sources as dietary fibre must be established before they may be claimed to be sources of dietary fibre in foods.

Once a novel fibre source has been successfully tested for efficacy, it may be considered an acceptable dietary fibre source. Otherwise, it is considered an unproven novel fibre and, if safe, may be used in foods but cannot be claimed to be a source of dietary fibre.

If a novel fibre source has been reviewed by Health Products and Food Branch of Health Canada and found acceptable, either as an ingredient only (safety demonstrated) or as a dietary fibre source (safety and efficacy demonstrated), the manufacturer will receive a "letter of no objection" indicating any restriction on its use. These letters of no objection are specific to the brand of the fibre source that was reviewed, unless otherwise specified.

Manufacturers considering the use of novel fibre sources and wishing further guidance in this regard are advised to contact the Health Products and Food Branch, Health Canada.

6.2.4.6.1 Dietary Fibre Sources in the List of Ingredients

In the case of ingredients manufactured to be sources of dietary fibre, such as novel fibre sources, the common name of the fibre ingredient in the list of ingredients should include:

• the name of the plant which is the origin of the fibre; and
• the specific part of that plant.

The term "fibre" may be included as part of the common name, if appropriate (e.g., the product is 90 percent fibre).

6.2.4.6.2 Dietary Fibre Content Claims

Descriptive claims may be made for foods which are considered to be sources of dietary fibre, either fibre-containing foods or novel fibre sources having been demonstrated to be sources of dietary fibre. The terms "good" and "excellent", because they imply a judgment regarding the nature and value of the fibre in addition to quantity, should not be used. If a food contains an unproven novel fibre source, the amount of fibre contributed by this ingredient should not be included in the declaration of the dietary fibre content, and no fibre claims may be made for it.

Where dietary fibre claims are made, the dietary fibre content of a food must be declared in grams per serving of stated sizes (for methods of analysis, see Section 6.4.4.3).

a) Descriptive Claims

No claim should be made regarding the fibre content of a food unless the food contains at least 2 g of dietary fibre per serving.

Foods (except meal replacements and formulated liquid diets) containing a minimum of 2 g of dietary fibre per serving may be described as a "source" of dietary fibre or as containing "moderate" amounts of dietary fibre.

Foods (except for meal replacements and formulated liquid diets) containing a minimum of 4 g of dietary fibre per serving may be described as containing "high" amounts of dietary fibre.

Foods (except for meal replacements and formulated liquid diets) containing at least 6 g of dietary fibre per serving may be described as containing "very high" amounts of dietary fibre.

b) Comparative Claims

Quantitative comparisons of the fibre content of foods of proven fibre value are considered to be misleading unless the fibres are:

• derived from the same plant sources and parts;
• in similar physical forms;
• incorporated into compositionally similar foods; and
• have been shown by the manufacturer to have similar physiological effects (see Claims for Physiological Effects of Fibre, Section 7.5.3).

c) Fibre in Meal Replacements and Formulated Liquid Diets

Statement or claims regarding dietary fibre content of meal replacements, including "fibre" as part of the common name, may be made only if human studies have shown that the fibre source has the beneficial effects attributable to the dietary fibre ingredient when consumed in the specific meal replacement. No claims for "moderate", "high" or "very high" source of dietary fibre may be made for any meal replacement (see Policy Respecting Dietary Fibre in Meal Replacements, Health Protection Branch, Health Canada, 1993).

6.2.4.6.3 Bran, Oat Bran, Corn Bran

Proposals for implied nutrient content claims are contained in the consultation documents on Nutrient Content Claims, January 1996, available from Health Canada and the Canadian Food Inspection Agency.

A statement or claim relating to the bran content of a food other than the listing of "bran" in the list of ingredients is considered to be a claim that the food is a source of dietary fibre (see Section 7.5.3). A food described as containing "bran" should contain at least 2 g dietary fibre from bran and bran-containing ingredients per serving of stated size. Where a source of the bran is named, the product should contain at least 2 g dietary fibre per serving from each named source, e.g., "wheat bran and oat bran pancakes" should contain at least 2 g dietary fibre from wheat bran and 2 g dietary fibre from oat bran. For all bran claims, the total dietary fibre content of the food is to be declared in grams per stated serving size (B.01.300, FDR).

Rationale: In a consumer survey entitled "Consumer Perceptions and Understanding of the Bran/Fibre Relationship"*, when asked to choose from a list of statements, consumers agreed that food products containing bran could be a "source of dietary fibre" (91 percent). When not offered a choice of statements, consumers associated bran with general health benefits, including promotion of regularity (51 percent). Therefore, it is concluded by government that consumers associate "bran" with dietary fibre and the beneficial effects attributable to dietary fibre. Hence, a bran claim constitutes a claim for dietary fibre. Similarly, it is believed that consumers expect foods named "bran" or "oat bran" to have the beneficial effects of these fibres.
(* Canadian Facts, 1990, presented to the Bran Consortium, Don Mills, Ontario.)

6.2.4.6.4 Wheat Bran

If the source of bran is not named, the term "bran" will be considered a reference to wheat bran. Wheat bran contains approximately 42 percent dietary fibre.

6.2.4.6.5 Oat Bran

Oat bran is defined as the product derived from the dehulled oat kernel (oat groat) which provides, on a dry basis, a minimum content of 13 percent total dietary fibre, of which at least 30 percent must be soluble fibre. The moisture content of the product is not to exceed 12 percent.

A product may be represented as a source of oat bran, provided it contains at least 2 g dietary fibre derived from oat bran meeting the above definition and oat-bran-containing ingredients.

6.2.4.6.6 Corn Bran

Traditionally, milled corn bran contains 60-65 percent dietary fibre. Products may be represented as sources of corn bran, provided the product contains at least 2 g dietary fibre from traditionally-milled corn bran.

6.2.4.6.7 Rice Bran

No dietary fibre claims may be made for rice bran, which is considered a safe food ingredient but whose efficacy as a source of dietary fibre has not been established.

6.2.4.6.8 Summary Table of Dietary Fibre Claims

The following table provides a summary of the Regulations and guidelines pertaining to dietary fibre claims (see also Sections 6.1, 6.3 and 6.4).

* When claims are made on a label, unless otherwise specified, this information must appear on the label. For advertising claims, the required information must appear either in the advertisement or on the label.

6.2.4.6.9 Information on Fibre Sources

The following table (from Health Products and Food Branch, Health Canada) provides a summary of the fibre sources. This table is current as of September 1995, and is subject to change.

¹ -- Figures in name refer to mean particle size as measured by the method of Mongeau, R. and Brassard, R., Cereal Chemistry 59 (5):413-417, 1982.

²-- Oat hull fibre has not been approved for use as a bulking agent for use in calorie reduction. Such a use would be suggested, for example, by the presence of a claim for calorie reduction achieved by means of the addition of oat hull fibre.

a -- Dietary fibre from novel fibre sources may not be calculated and declared in the nutrition labelling table of a food unless proof of efficacy as dietary fibre in the same type of food has been shown through clinical testing to the satisfaction of HPB and a letter of no objection has been issued. (See Food Directorate Guideline No. 9, "Guideline Concerning the Safety and Physiological Effects of Novel Fibre Sources and Food Products Containing Them", revised November 1994.)

b -- Dietary fibre from novel fibre sources may not be calculated and declared in the nutrition labelling table, regardless of their status in "Regular Foods" unless proof of efficacy as dietary fibre in the context of the meal replacement has been shown through clinical testing to the satisfaction of HPB and a letter of no objection has been issued. (See Policy Respecting Dietary Fibre in Meal Replacements, HPB, September, 1993.)

c -- A few examples of novel fibres* not currently recognized as ingredients or sources of fibre.

1. Fibre that has not traditionally been used for human consumption to any significant extent, for example:
   • cane sugar stalks
   • cocoa bean hulls
   • oat hulls
   • mucopolysaccharides (e.g. chitin) from shells of shellfish
   • wheat straw
2. Fibre that has been chemically processed, e.g. oxidized, or physically processed, e.g. very finely ground, so as to modify the properties of the fibre contained therein, such as:
   • finely ground wheat bran
   • bleached pea hulls (seed coats)
   • bleached wheat straw
3. Fibre that has been highly concentrated from its plant source, such as:
   • beta-glucans from barley and oats

d -- Some examples of food additives not currently recognized as fibre sources

• pectin
• carrageenan
• guar gum
• methylcellulose, carboxymethylcellulose, microcrystalline cellulose, etc.
• wood cellulose (powdered cellulose) [its use as a food additive is authorized under an Interim Marketing Authorization]

e -- Definition of dietary fibre:

"Endogenous components of plant material in the diet which are resistant to digestion by enzymes produced by man. They are predominantly nonstarch polysaccharides and lignin and may include, in addition, associated substances." (Health Protection Branch, Health Canada, I.L. No. 736, February 5, 1988.)

f -- * Novel Fibre: A "novel fibre" or "novel fibre source" means a food that is manufactured to be a source of dietary fibre, and:

1. has not traditionally been used for human consumption to any significant extent;
2. has been chemically processed, e.g. oxidized, or physically processed, e.g. very finely ground, so as to modify the properties of the fibre contained therein; or
3. has been highly concentrated from its plant source.