Nutrition Labelling and Claims Regulations - Frequently Asked Questions
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Frequently Asked Questions (PDF Version)
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Nutrition Labelling
Implementation Date
Prohibitions, Exemptions and Voluntary Nutrition Labelling
Prepackaged foods
Non-prepackaged foods
Natural health products
and drugs
Ingredients for manufacturing
other foods
Multi-serving ready-to-serve
foods
Voluntary nutrition
labeling
Serving Size and Reference Amounts
Calorie and Nutrient Declarations
Mandatory declaration
of additional information
Units of declaration
Rounding and calculations
Source of labelling
values (database/laboratory)
Nutrition Facts Table Format
Available display surface
Table size
Placement and orientation
Bilingual requirements
Font and abbreviations
Nutrient declarations
in advertisements
Small Packages
Prepackaged Individual Portions of Food
Foods with Little Nutritional Value (simplified
format)
Foods Requiring Preparation (dual format)
Assortments of Different Foods (aggregate
format)
Foods Used in Different Amounts (dual
or aggregate format)
Nutrition Claims
General
Nutrient Content Claims
Food composition criteria
Labelling requirements
Conditions for Advertising
Light claims
Reference amounts
Health Claims
Food composition criteria
Wording Requirements
A. Nutrition Labelling
1) Implementation Date
i) Question:
Must all labels printed after December 12, 2002 have the new nutrition
labelling format, or can the old formats continue to be used until December
12, 2005?
Answer: The old format can be used until December
12, 2005 (or for small manufacturers until December 12, 2007). However,
compliance with the new Nutrition Facts table becomes mandatory immediately
when a label or advertisement displays one or more
of:
- the expression "nutrition facts", "valeur
nutritive" or "valeurs nutritives";
- the health claims in Column 1 of the table following Section B.01.603;
- the nutrient content claims regarding % fat free, trans
fatty acids, and omega fatty acids (Column 4 for items 15, 16, and 22
to 26 of the table following Section B.01.513) (Schedule L).
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2) Prohibitions, Exemptions and Voluntary Nutrition Labelling
a) Prepackaged foods
i) Question:
Must all prepackaged foods carry a Nutrition Facts table?
Answer: A number of prepackaged foods that have
specific nutrition labelling requirements under the Food
and Drug Regulations, are prohibited from
carrying a Nutrition Facts table and from using the phrase "Nutrition
Facts", "valeur nutritive", or "valeurs
nutritives". They include: formulated liquid diets, human
milk substitutes, foods represented as containing a human milk substitute,
meal replacements, nutritional supplements and foods represented for use
in very low energy diets [B.01.401(5)].
The manufacturer of foods used solely in the manufacture of other foods
(B.01.404), and multiple-serving, ready-to-serve foods to be served by
an institution, an industrial or commercial enterprise (B.01.405) must
provide the required nutrition information, but it does
not have to be in a Nutrition Facts table format.
Finally, some foods are exempted from carrying any
nutrition information [B.01.401(2)]. They include:
- Foods for which all mandatory nutrients may be expressed as "0"
(e.g., spices);
- Beverages with an alcohol content of more than 0.5%;
- Fresh vegetables or fruits, with no added ingredients;
- Raw single ingredient meat, meat by-product, poultry or poultry meat
by-product (but not if the meat or poultry is ground);
- Raw single ingredient marine or freshwater animal products;
- Foods sold at retail where the product is prepared and processed,
unless it is made from a premix with only water added;
- Foods sold at a roadside stand, craft show, flea market, fair, farmers'
market or sugar bush by the person who prepared and processed them;
- Individual servings of food sold for immediate consumption, such as
salads and sandwiches, that have not been treated or packaged to extend
their durable life;
- Foods sold at retail where the product is packaged, if the product
is labelled with a sticker and the package has an available display
surface of less than 200 cm2;
- One bite confections;
- Prepackaged individual portions of food solely to be served with meals
or snacks by a restaurant or other commercial enterprise;
- A variety of cow and goat milk products sold in refillable glass containers.
ii) Question:
Are prepackaged fresh eggs exempt from nutrition labelling?
Answer: No, prepackaged fresh eggs are not exempt
from nutrition labelling.
iii) Question:
Why is there an exemption from nutrition labelling for foods made from
a premix that are prepared and sold at retail, if an ingredient other
than water is added to the premix [B.01.401(2)(b)(v)]?
Answer: This exemption was made in recognition
of the difficulties associated with the accurate labelling of foods prepared
with limited standardization and measures of control at the retail level.
iv) Question:
When nutrition information is provided on a food that is consumer served
from a bulk bin at retail, must the information be presented in the format
specified?
Answer: Foods sold from bulk bins in retail stores
are not considered to be "prepackaged" and are therefore exempt
from most federal labelling requirements. However, nutrition information
may be provided voluntarily for bulk foods.
When it is, the nutrition labelling format specified in the Regulations
must be used [B.01.401(3)(e)].
It should be noted that shipping containers of bulk product sold to the
retailer must carry a Nutrition Facts table in the appropriate format
("prepackaged product" B.01.001).
v) Question:
Why don't the mandatory nutrition labelling regulations apply to liquor
(i.e., beer, spirits, etc.)?
Answer: The labeling of alcoholic beverages is
a complex matter, with implications for trade, jurisdiction, health, etc.
No plans are currently underway in Canada for requiring nutrition labelling
on such products.
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b) Non-prepackaged foods
i) Question:
Are food service beverage portion cups (e.g., coffee cups) exempt from
nutrition labelling?
Answer: Yes, because they are not considered
to be "prepackaged" foods and are therefore exempt from labelling
(B.01.001). However, sealed portion cups of juice and cartons of milk
are prepackaged foods and must be fully labelled, including a Nutrition
Facts table.
ii) Question:
Are cheese and meat sold at a deli counter required to carry a Nutrition
Facts table?
Answer: Packages of cheese and meat sold to a
retailer for use at a deli counter must carry a Nutrition Facts table.
If these products are cut and packaged prior to sale in the retail store,
they also require a Nutrition Facts table [B.01.401(1)]. However, if they
are cut and/or packaged at a customer's request, they are not regarded
as prepackaged products and do not require nutrition labelling.
iii) Question:
Is a dehydrated soup that is sold to a retail/grocery facility where it
is rehydrated with water and then sold as an individual serving of food
for immediate consumption (e.g., at a soup bar) required to have nutrition
labelling?
Answer: The package of dehydrated soup sold to
the retailer is a prepackaged product and requires a Nutrition Facts table.
However, the individual serving of rehydrated soup sold to a customer
for immediate consumption requires no labelling,
whether it is preportioned or not [B.01.401(2)(b)(vii)].
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c) Natural health products and drugs
i) Question:
Is nutrition labelling required on a product that is registered as a drug
or a supplement, such as a traditional herbal medicine?
Answer: No, the nutrition labelling regulations
apply only to products meeting the definition of food under the Food and
Drugs Act.
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d) Ingredients for manufacturing other foods
i) Question:
Are ingredients for use in manufacturing other foods
exempt from nutrition labelling?
Answer: The nutrition information for a prepackaged
product that is intended solely for use as an ingredient
in the manufacture of other products by a commercial or industrial
enterprise or institution (e.g., restaurant, cafeteria, hospital, or manufacturer,
including a retail manufacturer) (B.01.404):
- must provide all of the nutrition information
required by B.01.401 and B.01.402;
- may provide additional information (B.01.402);
- must declare the nutrients in absolute
amounts per gram or per 100 grams, or per millilitre or per 100 millilitres,
depending on the net quantity of the product.
In addition:
- the nutrition information must accompany
each delivery of the product; either on the label, on a specification
sheet, a work sheet, a bill, etc.;
- information on serving of stated size and percentages of daily values
are optional;
- the numeric quantity of the nutrients must not
be rounded;
- the nutrition information is not required
to appear in a Nutrition Facts table format.
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e) Multi-serving ready-to-serve foods
i) Question:
Are multi-serving ready-to-serve foods, intended
for commercial enterprises or institutions, exempt from nutrition labelling?
Answer: The nutrition information for a prepackaged
product that is a multiple-serving ready-to-serve
food, that is intended solely to be
served in a commercial or industrial enterprise or institution (e.g.,
hospital, restaurant, cafeteria) (B.01.405):
- must provide all of the required information
outlined in B.01.401 and B.01.402;
- may provide additional information (B.01.402);
- is not required to appear in a Nutrition
Facts table format.
- must accompany each delivery of the product
either on the label, on a specification sheet, a work sheet, a bill,
etc.
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f) Voluntary nutrition labeling
i) Question:
If a manufacturer chooses to provide nutrition labelling voluntarily on
a food that is otherwise exempt, must the labelling regulations be followed?
Answer: Yes. Exempted foods may voluntarily
provide the Nutrition Facts table, as long as all applicable nutrition
labelling regulations are followed [B01.401(3)(e)].
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3) Serving Size and Reference Amounts
i) Question:
When a food such as cake or pizza is divided into pieces before consumption,
how should the serving size be declared ?
Answer: The serving size used must be stated
in a commonly used fraction followed by the corresponding metric weight,
e.g., ¼ pizza (150 g).
ii) Question:
When a food is sold as individual pieces (e.g., cookies, bagels), must
both the number of pieces per serving and their metric measure be declared,
e.g., 2 cookies (32 g)?
Answer: Yes, the number of pieces in a serving
should be stated as the commonly used unit, so the example of 2 cookies
(32 g) is fine (Table following B.01.401 item 1).
iii) Question:
Does the serving size of ice cream have to be declared in both volume
and weight?
Answer: No, the metric unit used for the serving
size of a food, (except for pickles, olives and fruit for garnish or flavour,
e.g., maraschino cherries), must be the same as the unit used to declare
the net quantity of the food as offered for sale (B.01.002A).
Since ice cream is sold by volume, the serving size declaration must
include a household measure followed by the volume in milliliters in brackets,
e.g., ½ cup (125 ml). If a metric measure is used as the household
measure (e.g., 125 ml), it does not have to be repeated in brackets.
iv) Question:
Must the reference amount of a food, as identified in Schedule M in the
Regulations, be used as the serving size?
Answer: No, the reference amount does not have
to be used as the serving size. Serving sizes may be determined by the
manufacturer, but it is recommended that they be chosen from within the
ranges set out for the product category in the Canadian Food Inspection
Agency's Guide to Food Labelling and Advertising.
The ranges of the serving sizes listed in the Guide encompass the reference
amount.
v) Question:
Why were the reference amounts for snack foods and soft drinks increased?
Answer: One of the uses of the reference amounts
established in the Regulations is to determine what constitutes a single
serving container of a food [B.01.002A(2)]. Over the past few years there
has been a noticeable increase in the size of single serving containers
of snack foods and carbonated and non-carbonated beverages on the market.
Based on nutrition labeling consultations, it was agreed that consumers
need nutrition information based on the entire content of a package likely
to be consumed as a single serving. With the growing concern about obesity,
it is particularly important that consumers have clear information on
the calorie content of the foods they consume. Therefore, to reflect the
changes in the market place, the reference amounts were increased for
snack foods from 30 g to 50 g and for carbonated and non-carbonated beverages
from 250 ml to 355 ml.
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4) Calorie and Nutrient Declarations
a) Mandatory declaration of additional information
i) Question:
When is a declaration of potassium required in the Nutrition Facts table?
Answer: A declaration of potassium in the Nutrition
Facts table is required as follows:
- if potassium is added as a mineral nutrient to a food, such as a fruit
drink;
- when a nutrient content claim or health claim related to potassium
is made;
- when any form of potassium salts, including additives, are added to
a food and the label contains a claim for salt or sodium.
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b) Units of declaration
i) Question:
Can absolute amounts of vitamins and mineral nutrients be stated in the
Nutrition Facts table? If not, where do the regulations say that they
cannot?
Answer: On those foods requiring a Nutrition
Facts table, vitamins and mineral nutrients must be expressed as a % Daily
Value per serving of stated size within the Nutrition Facts table [B.01.401(1)].
However, amounts of vitamins and mineral nutrients can be stated elsewhere
on the label, provided they are declared in the appropriate units as set
out the Table I to Division 1 and Table I to Division 2 of Part D of the
Food
and Drug Regulations [B.01.301(1)(b)].
ii) Question:
What is the Daily Value and why are nutrients now expressed in the % Daily
Value?
Answer: The Daily Values comprise two sets of
dietary standards: the reference standards for fat, saturated and trans
fat, cholesterol, carbohydrate, fibre, sodium and potassium [B.01.001(2)]
and Recommended Daily Intakes for vitamins and mineral nutrients (Part
D of the Food
and Drug Regulations, Table
I to Division 1, and Table I to Division 2).
The % Daily Value shows the percent (or how much) of the reference Daily
Value of a nutrient in the stated serving of food. By using the % Daily
Value, consumers can tell if this amount is high or low. For example,
by looking at a product with 2 mg of iron and 10 g of fat, per stated
label serving and a % DV of about 15% for both nutrients consumers can
tell that both values are relatively high.
iii) Question:
Is there a minimum amount of trans fatty acid
content needed to trigger a mandatory declaration in the Nutrition Facts
table?
Answer: No, a declaration of trans
fat must always appear in the Nutrition Facts table, even if it can be
expressed as "0". If a food meets the conditions for a simplified
declaration and when the simplified format is used, trans
fat may appear within the statement "not a significant source of
(naming the omitted nutrients)" [B.01.401(6)].
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c) Rounding and calculations
i) Question:
If a product contains an un-rounded carbohydrate value of 0.483 g, is
this value declared in the Nutrition Facts table as 0 or 1?
Answer: Since it is less than 0.5 g, it is declared
as "0" (Table following B.01.401 Item 9 Column 4).
ii) Question:
What are the rounding rules for a product with less than 2 servings per
container?
Answer: Such products would be identified as
a single serving, when the package contains less than 200% of the reference
amount (if the reference amount is less than 100 g or 100 ml), or when
it is less than 150% of the reference amount (if the reference amount
is more than 100 g or 100 ml (B.01.002A). In all other cases the serving
size would be rounded to 2. For example, a 284 ml can of peas containing
200 ml of drained peas may be labelled with a 125 ml serving size. Since
the can contains more than 150% of the 125 ml reference amount, the number
of servings in the can would be rounded to 2.
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d) Source of labelling values (database/laboratory)
i) Question:
Can manufacturers use databases to generate their Nutrition Facts information?
Answer: Manufacturers are responsible for ensuring
the accuracy of the nutrient information on their product labels, and
it is their choice how they determine the nutrient content. If a manufacturer
chooses to use an ingredient database to calculate nutrient information,
he should be assured of the accuracy of this information, and that it
is representative of the company's food products and food ingredients.
In general, some analyses are recommended to verify the accuracy of the
calculations resulting from the use of a database.
ii) Question:
If products are imported from the US, is it necessary to have Canadian
labs verify the nutritional content of the products?
Answer: No, as long as US manufacturers are aware
of differences between Canadian and US requirements and supply the information
on the basis of Canadian requirements.
iii) Question:
What laboratories should be used for product analysis?
Answer: It is suggested that the laboratory or
laboratories chosen are accredited by the Standards Council of Canada
( http://www.scc.ca).
The laboratory chosen should also be accredited for the particular analysis
involved, and the methods used should be validated for the food matrix
being tested. A guidance document for generating accurate nutrition labelling
values is presently being developed by Health Canada.
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5) Nutrition Facts Table Format
a) Available display surface
i) Question:
The size of the Nutrition Facts table is dependent on the available display
surface. What is meant by the available display surface?
Answer: The available display surface (ADS) is
essentially the total surface area of a container, including the bottom,
that is available for labelling. With an ornamental container it includes
the total surface of the bottom, or of both sides of tag attached to the
container. With a package that cannot be labelled, the ADS consists of
both sides of a tag attached to it.
The ADS does not include the area of a package
to which a label cannot be physically applied, or which the consumer is
unable to view easily under customary conditions of purchase. It also
does not include the area covered by the Universal Product Code, or any
part of a package, other than a single serving container, that will be
destroyed when the package is opened (B.01.001).
ii) Question:
Are cellophane windows on boxes considered to be part of the available
display surface?
Answer: Yes, cellophane windows are included,
since they are potentially available for labelling (B.01.001).
iii) Question:
Is an open window on a package (i.e., no cellophane) part of the available
display surface?
Answer: No, since an open window is not available
for labelling (B.01.001).
iv) Question:
Are parts of a label that are destroyed upon opening, such as a tear strip
or the neck label of a salad dressing jar, considered to be part of the
available display surface?
Answer: Any part of the package that is destroyed
upon opening, such as a tear strip or a label on a bottle that is torn
when the bottle is opened, is not included in the ADS, unless
the product is a single-serving package (i.e., the contents can reasonably
be eaten by one person on a single occasion).
v) Question:
Is the available display surface based on the current label size (e.g.,
the sticker on top of a tray of cookies, or a spot label on a bottle)
or do you have to increase the label size if there is room on the container
for a larger label?
Answer: The available display surface is based
on the size of the package, not on the size of the current package label.
If there is not enough room on the present label to display the required
size of the Nutrition Facts table, based on the total available display
surface of the package, a larger label will have to be made.
vi) Question:
Can the date code area on a package be excluded from the available display
surface?
Answer: No, the only areas that can be subtracted
from the available display surface are the areas occupied by the Universal
Product Code (UPC) and the area of a tear strip on packages that are not
single-serving containers (B.01.001).
vii) Question:
When calculating the available display surface for a carbonated soft drink
bottle, would the cap be considered part of the calculation?
Answer: Yes, unless
the label cannot be physically applied or the information cannot be legibly
set out on the cap surface.
viii) Question:
Why is the space required for ingredient listing not removed from the
calculation of ADS since the listing is mandatory?
Answer: The requirement that no more than 15%
of the available display surface of a food label needs to be used for
the Nutrition Facts table was based on the manufacturer's need for adequate
room for placing all of the other mandatory and the non-mandatory information
on the label.
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b) Table size
i) Question:
Is there a minimum size for the Nutrition Facts table?
Answer: Yes, once an appropriate format type
for the Nutrition Facts table has been selected, i.e. a standard (horizontal),
simplified standard (horizontal) dual or aggregate formats (Tables to
sections B.01.454 to B.01.459, and B.01.461 to .B.01.464), the minimum
size will be the largest version of the selected format which does not
exceed 15% of the available display surface, and that can be applied on
a continuous display surface.
When none of the applicable format variations specified in the tables
would fit within 15% of the available display surface, other options may
be considered, including formats with reduced leading, the linear format,
a simpler format type than the dual or aggregate formats and alternative
methods of presentation such as the inner side of the label.
Nutrition labeling on packages with an available display surface less
than 100 cm2 is discussed under section 6 on small packages.
ii) Question:
Is there a maximum size for the Nutrition Facts table?
Answer: No, the Nutrition Facts table can be
larger than the minimum size specified in the Regulations, as long as
all the characters are enlarged proportionally [B.01.450(3)(b)].
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c) Placement and orientation
i) Question:
A container has two equal surfaces suitable which are used as principal
display panels (PDP). The side panels and ends are not large enough to
accommodate the Nutrition Facts table. What options are there for placement
of the table?
Answer: The Nutrition Facts table will have to
be placed on either, or both of the large panels.
ii) Question:
When can the inner side of the label be used to display Nutrition Facts?
Answer: The inner side of a label may be used
for the Nutrition Facts table when none of
the applicable format variations in the tables following sections B.01.454,
B.01.455, B.01.461 or B.01.462, (namely standard and simplified formats
both for adults and for children under two years of age), would fit in
any orientation on a continuous display surface which occupies 15% or
less of the available display surface of the package.
The dual and aggregate format cannot be used on the inner side of a label
except for an assortment of foods that have
different nutritional values and that are not intended to be eaten at
the same time [B.01.457(2)(b)(iii), B.01.463(2)(b)(iii)].
If the Nutrition Facts table is placed on the inner side of the label,
a statement regarding the location of the table (in not less than 8 point
type), must be placed on the outer side of the label [B.01.466(2)].
iii) Question:
Can the Nutrition Facts table be placed on the inside of the carton of
prepackaged fresh eggs?
Answer: The Nutrition Facts table may
be printed on the underside of the lid of the egg carton (pulp flat, foam
flat, clear plastic), since the underside of the lid is considered as
part of the available display surface when any
information (e.g., nutritional, promotional or otherwise) is printed on
it (B.01.001).
iv) Question:
Can the Nutrition Facts table be placed on the bottom of a container?
Answer: Yes, as long as
a label can be applied or printed on it and
the contents of the package will not leak or be damaged if the package
is turned over to view the table (B.01.001).
v) Question:
What are some examples of products that might leak out or be damaged when
a package is turned over?
Answer: Pies (e.g., fruit, lemon, custard), decorated
cakes, some pre-packaged meats on foam trays covered with transparent
film, cartons of milk, cream and juice.
vi) Question:
Please clarify the meaning of B.01.452(3) Subsection (1) regarding the
orientation of a Nutrition Facts table that is set out on the top or bottom
of a prepackaged product.
Answer: When the Nutrition Facts table is displayed
on either the top or the bottom of a package, it may be oriented in any
manner without regard for any other information appearing on the label
of the package.
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d) Bilingual requirements
i) Question:
Are shipping containers required to carry bilingual nutrition labelling?
Answer: The Nutrition Facts table on a shipping
container destined to a commercial or industrial enterprise or institution
can be in English or French only, provided
that the shipping container and its contents are not resold as a one unit
prepackaged product to a consumer at the retail level [B.01.012(11)].
Note: Quebec may have additional language
requirements which can be accessed at http://www.olf.gouv.qc.ca/.
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e) Font and abbreviations
i) Question:
What is meant by 8 point type and 12 point leading? How is leading measured?
Answer: "Point" is a printer's unit
of measurement, for both type size and line spacing, equal to 0.351 mm
(1/72 inch). This definition is consistent with current norms in desktop
publishing. So 8 point type measures 2.81 mm in height.
"Leading" (line spacing) is a measure from the baseline of
the letters in one line of type to the baseline of the letters in the
line of type above it. So 12 point leading measures 4.21 mm.
ii) Question:
What font is allowed for use on the Nutrition Facts table?
Answer: The Regulations require that the characters
in the Nutrition Facts table "be displayed in a single standard sans
serif font that is not decorative" [B.01450(3)(a)], such as Helvetica,
Arial and Universe. The use of serif and fancy type fonts is not permitted.
iii) Question:
What abbreviations can be used in the Nutrition Facts table?
Answer: The following abbreviations are permitted
(Table following B.01.401). Their use should be limited to those labels
where the full words will not fit.
- "Vit" for Vitamins
- "% DV" for % Daily Value *
- "% VQ for % valeur quotidienne*
- tsp for teaspoon: (English only)
- tbsp for tablespoon: (English only)
- c. à thé or
cuil. à thé for cuillère à
thé: (French only)
- c. à soupe or
cuil. à soupe for cuillère à soupe
(French only).
In addition the following metric symbols must be used in the Nutrition
Facts table:
- kJ for kilojoule
- mg for milligram
- g for gram
- mL or ml for millilitre
* If this term is abbreviated in the subheading, it must be asterisked
to a statement for the full term at the bottom of the table.
iv) Question:
Is a bilingual version of the linear format allowed?
Answer: No. A bilingual linear format is not
permitted because it greatly compromises legibility. However, to save
space, both the French and the English information in the linear format
may appear in a single "box", with one language above the other
(not mixed together) (See note to Figure 16.1 of Schedule L).
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f) Nutrient declarations in advertisements
i) Question:
Do advertisements for foods including point of sale information, web sites
and recipe booklets need to provide nutrition information in any special
format?
Answer: Food advertisements are never required
to provide nutrient information in a Nutrition Facts table. However, if
a nutrient content claim, a biological role claim or a health claim is
made in an advertisement for a specific food, and the nutrition information
required to support the claim is not on the food label, this information
must be provided in the advertisement [B.01.312(1), B.01.503)(1)©),
B.01.601(1)(b)].
In addition, when the manufacturer makes
the claim in an advertisement for a prepackaged food that would otherwise
be exempt from nutrition labelling, the Nutrition Facts table must
be provided on the food label [B.01.401(3)(e)(ii)].
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6) Small Packages
i) Question:
Is a Nutrition Facts table required on a small package with less than
100 cm2 available display surface ?
Answer: No, unless:
- the product contains an added vitamin or mineral nutrient [B.01.401(3)(a).
- a vitamin or mineral nutrient is declared as a component of one of
the ingredients, other than flour [B.01.401(3)(b)];
- the product contains aspartame, sucralose or acesulfame-potassium
[B.01.401(3)©)];
- the label or advertisement placed by the manufacturer refers to the
energy value, core nutrients (table to B.01.401) or additional nutrients
(table to B.01.402), or their constituents (except in a common name
used in the ingredient list, and for information required by Division
12 on prepackaged water and ice) [B.01.401(3)(e)(I)].
- the label or advertisement by the manufacturer contains a representation
that expressly or implicitly indicates that the food has particular
nutritional or health-related properties, including nutrient content
claims (table following B.01.513), health claims (table following B.01.603),
biological role claims (B.01.311), vitamin claims (D.01.006) and mineral
claims (D.02.004) [B.01.401(3)(e)(ii)];
- the label or advertisement by the manufacturer contains a health-related
name, statement, logo, symbol, seal or approval or mark [B.01.401(3)(e)(iii)].
- the label or advertisement by the manufacturer contains the phrase
"nutrition facts", "valeur nutritive"
or "valeurs nutritives [B.01.401(3)(e)(iv)].
ii) Question:
What are the nutrition labelling requirements on a small package if a
nutrient content claim such as "a good source of protein" is
made on the label or in an advertisement?
Answer: When such a claim is made on the label
or in an advertisement by the manufacturer, the Nutrition Facts table
must be provided on a tag attached to the package, a package insert, the
inner side of a label, a fold-out label, an outer sleeve, an over wrap
or a collar.
If the Nutrition Facts table is placed on a package insert or on the
inner side of the label, a statement regarding the location of the table
must be placed on the outer side of the label [B.01.466(2)].
iii) Question:
When there is no nutrition labelling on a package because the package
is too small to accommodate it, where can the consumer obtain the information?
Answer: Consumers can obtain the nutrition information
about the food from the manufacturer who is required to provide an indication
on the label, in a type size not less than 8 point type, of how they may
obtain the nutrition information. The manufacturer can provide either
a toll free number or the company postal address [B.01.467(3)(b)]. A manufacturer
may also provide a website address, but this cannot substitute for either
the required toll free number or the postal code. The information must
be provided in either official language as requested by the consumer.
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7) Prepackaged Individual Portions of Food
i) Question:
Are single-serve portion pack products required to carry Nutrition Facts
labelling?
Answer: Yes, unless they are solely intended to
be served by a restaurant or other commercial enterprise as an accompaniment
to meals or snacks (e.g., creamers, crackers, vinegar, etc.) [B.01.008(2)(b)];
or, if the container in which they are sold has an available display surface
of less than 100 cm2 and carries no nutrition claims, and there
is no nutrient added to the product (B.01.467).
ii) Question:
If a nutrient content claim is made on single serve portion pack product,
is a Nutrition Facts table required?
Answer: Yes, unless the product is an individual
package such as a creamer, crackers, etc. that is served by a restaurant
or other commercial enterprise with meals or snacks [B.01.401(2)(c)(ii)].
iii) Question:
Are there specific rules for stating the serving size for the nutrition
labelling of single serving containers and when they must apply?
Answer: Yes, the serving size for nutrition labelling
must equal the net quantity of the food in
the package in the following three cases:
- if the quantity of food can reasonably be consumed by one person at
a single sitting [B.01.002A(2)]
- if the reference amount of the food is less than 100 g or 100 ml,
and the package contains less than 200%
of that reference amount [B.01.002A(2)(b)].
- If the reference amount is 100 g or 100 ml or more, and the package
contains 150% or less of that reference amount [B.01.002A(2)(c)].
iv) Question:
How must the serving size of single-serve prepared
foods be declared?
Answer: The serving size must be given in both
a commonly used unit as well as a metric measure. If the food is sold
by weight, the metric portion of the serving size would be declared in
grams; and if it is sold by volume the serving size would be in milliliters.
The serving size of a prepared food, packaged in an amount that could
reasonably be consumed by one person in a single meal, would be the net
weight or volume the package contents, as sold. The commonly used unit
would be the whole package, e.g., 1 package (225 g), 1 can (355 ml).
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8) Foods with Little Nutritional Value (simplified
format)
i) Question:
What is meant by "not a significant source of" nutrients?
Answer: For the purposes of nutrition labelling,
an amount that can be described as "not a significant source of"
is an amount of a nutrient that can be declared as "0" in the
Nutrition Facts table, based on the specified rounding rules (Column 3
of the tables to B.01.401 and B.01.402).
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9) Foods Requiring Preparation (dual format)
i) Question:
For products such as cake mixes and condensed cream soups, where the addition
of ingredients such as milk, eggs, etc. is required to prepare the final
product, is the use of the dual format mandatory?
Answer: The Regulations require a declaration
of nutrition information for the product "as sold". Information
on foods "as prepared" is optional. Therefore the dual format
is optional [B.01.406(5)].
It should be noted that the Regulations do not provide for the use of
the dual format for foods for children under 2 years of age because there
is a large variation in the preparation of foods, such as infant cereals
which require different dilutions for different age groups [B.01.406(6)].
ii) Question:
If you have a product that can be prepared in two or more ways with different
ingredients for each, can three or more columns be provided using the
dual format option?
Answer: The Regulations require nutrition information
only on the food "as sold". However, the nutrient content of
a food prepared in different ways can be presented in additional columns
using the dual format, but the headings of the columns should clearly
indicate how the preparations differ.
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10) Assortments of Different Foods (aggregate format)
i) Question:
For a variety box of chocolates, can you average the nutrient composition
of the chocolates and present this in a Nutrition Facts table?
Answer: The manufacturer may choose to use one
of the following:
- a Nutrition Facts table based on a weighted average of all the chocolates
in the assortment [B.01.406(4)];
- an aggregate table (i.e., a Nutrition Facts table with nutrient content
information and % Daily Values in separate columns for each variety.
ii) Question:
Does a package containing two or more separately packaged foods that each
carries a Nutrition Facts table, require a Nutrition Facts table on the
outer package?
Answer: Unless the Nutrition Facts tables on
the individual packages are clearly visible through the outer package,
the Nutrition Facts table is required on the outside of the prepackaged
product (B.01.001 "available display surface").
iii) Question:
For "variety pack" foods, the Regulations require an aggregate
format if the nutrition information for each product is different. What
format can be used if the nutrition information for each is the same?
Answer: When the foods in a variety pack have
the same nutritional content, only one set of values is required and the
standard, horizontal or linear format of the Nutrition Facts table can
be used, depending on the available display surface of the package [B.01.406(3)(b)].
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11) Foods Used in Different Amounts (dual or aggregate
format)
i) Question:
If you have foods that can be served in different amounts depending on
their use, such as mini egg rolls, pizza rolls, and stuffed pastry, how
can the Nutrition Facts table be presented?
Answer: The Regulations allow for an optional
display of information on the basis of different serving sizes or amounts
of a food. For example, when foods are promoted both as appetizers (hors
d'oeuvres) and as a combination dish, the dual or aggregate format can
be used to display nutrition information in more than one column. One
column could be based on the serving size when used as a combination dish,
and the other on their serving size as appetizers, with both expressed
as number of units followed by the metric measure [B.01.406(7)].
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B. Nutrition Claims
1) General
i) Question:
Are nutritional supplements and meal replacements, which are exempt from
having a Nutrition Facts table, allowed to make nutrient content claims
and health claims?
Answer: Nutrient content claims for vitamins
and mineral nutrients are permitted on nutritional supplements and meal
replacements (D.01.004, D.02.002). However, nutrient content claims and
health claims provided in the table following sections B.01.513 and B.01.603,
which are based on both a serving size and a reference amount established
for the food category (Schedule M of the Regulations), may not be made
at this time since no reference amounts have been established for these
products.
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2) Nutrient Content Claims
a) Food composition criteria
i) Question:
May a "fat free" nutrient content claim be made on a product
that contains 0.4 g per serving of total fat, consisting of 0.2 g of saturated
fat, and 0.2 g of trans fat?
Answer: Yes, the claim "fat free" is
permitted on a food that contains less than 0.5 g fat per
reference amount and per serving of stated size. Since this product
contains 0.2 g saturated fat and 0.2 g trans
fat and these nutrients cannot be declared as "0", a declaration
of "0" for fat within the Nutrition
Facts table is not permitted (B.01.401 Table Item 8). Therefore, the declaration
for fat in the Nutrition Facts table would
be 0.4 g fat.
ii) Question:
If a low fat claim is made on a food that requires further preparation,
e.g., the addition of milk and margarine, can that claim still be made
even though it may no longer qualify for the claim after preparation?
Answer: Yes. However, in order not to mislead
the consumer, the label should clearly indicate that the claim applies
to the food as sold and whether there are directions for preparing the
food, so that it meets the requirements of the claim.
iii) Question:
Why is only one amount of cereal (30 g) considered when setting conditions
for protein claims?
Answer: It was decided that no changes would be
made to the criteria for protein claims until the WHO/FAO completed its
review of protein rating requirements. Until then a 30 gram amount of
cereal will continue to be used as the basis for protein claims.
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b) Labelling requirements
i) Question:
Is it correct to say that nutrient content claims and the statements they
trigger (e.g., 50% less calories than product X), should be in the same
type size and without any intervening material?
Answer: Yes, the Regulations require that claims
identified in B.01.513, and the statements they trigger, must be in the
same size type with no intervening printed, written or graphic material,
both on food labels (B.01.504) and in advertisements (B.01.505 and B.01.506).
ii) Question:
Does section B.01.504 mean that if a nutrition claim is made on the label
it may be put on the package more than once? If so, does it have to be
complete in both locations? For example, could you put only the claim
on the main panel and then repeat the claim plus all of the triggered
information on another panel?
Answer: B.01.504 requires that when a nutrition
claim is placed on a food label it must be in the wording and format prescribed
in B.01.513. Although the claim may appear more than once on the label,
the triggered nutrition information is not required more than once, but
it must be placed either adjacent to the most prominent claim on the principal
display panel (PDP), or if no claim is made on the PDP, adjacent to the
most prominent claim elsewhere on the label.
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c) Conditions for Advertising
i) Question:
Since single ingredient raw meat is exempted from nutrition labelling
requirements, are organizations such as food marketing boards allowed
to make nutrient content claims, health claims or health check logos on
point of sale materials?
Answer: Yes. Exempted products for which claims
are made by a third party do not lose their exemption. However, the advertisement
must include a declaration of the nutrient that is the subject of the
claim [B.01.503(1)(c).
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d) Light claims
i) Question:
When is it possible to claim that a food is "light"?
Answer: The claim "light" is allowed
to indicate a fat or energy reduction in a food, provided that the following
information is provided on the label or advertisement for the food:
- the similar reference food;
- the amounts of the foods being compared (if the amounts are not equal);
- the difference in energy value or fat content between the compared
foods, per serving of stated size, expressed as a % or fraction, or
in Calories or in grams (Table following B.01.513, Item 45).
"Light" can also be used to describe sensory characteristics
of a food, provided that the characteristic is clearly identified with
the claim (e.g., light tasting, lite coloured).
There are also a few foods for which this claim may be made without additional
labelling requirements, provided that the food meets the conditions for
the claim set out in the applicable regulations:
- light beer (B.01.502)(2)(j)
- light salted fish (B.01.502)(2)(k)
- light maple syrup (B.01.513(2)(a)
- light rum (B.01.513(2)(b)
- fruit canned in light syrup (B.01.502(2)(b)
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e) Reference amounts
i) Question:
What is the difference between a non-carbonated beverage and a fruit drink
beverage?
Answer: These two names may be synonymous except
when fruit drinks are represented for use as substitutes for fruit juices
(Items 23 and 83 of Schedule M).
ii) Question:
Can nutrient content claims be made for a food for which there is no established
reference amount?
Answer: No, when the compositional criteria for
nutrient content claims and health claims are based on a reference amount,
these claims cannot be made on foods.
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3) Health Claims
a) Food composition criteria
i) Question:
Can a frozen, prepared, single-serve food item that contains "one
serving of vegetables" be permitted to make the claim for "A
diet rich in a variety of vegetables and fruit may help reduce the risk
of some cancers"?
Answer: No, this claim can be made if the product
is a fruit or vegetable, (excluding potatoes, yams, cassava, plantain,
corn, mushrooms, mature legumes, and fruits and vegetables used as condiments)
that contains nothing other than sweetening agents, food additives, salt,
herbs, spices, seasonings and water (Table following B.01.603 Item 4).
ii) Question:
When health claims requiring 10% of the weighted Recommended Nutrient
Intake (RNI) of a vitamin or mineral nutrient are made (B.01.603), are
the nutrients added during the enrichment/ fortification of a food product
included in the nutrient profile of the food?
Answer: Yes, since health claims are based on
the combination of inherent and naturally occurring nutrient content of
the food plus those nutrients added for purposes of enrichment or fortification.
iii) Question:
How are the outstanding generic health claims going to be addressed by
Health Canada, and what are the timelines?
Answer: The generic health claims, involving
fat and cancer, fibre and cancer, and soluble fibre and heart disease
were not supported by reviewers. A review of the generic claims involving
diets rich in fruits, vegetables and whole grain cereal is in its final
stages. It should be noted that all new claims will require an amendment
to the Regulations before they can be used.
An interim guidance document for the submission of new generic diet
related claims is in place. Enquiries and submissions for such claims
may be sent to healthclaims_submissions@hc-sc.gc.ca.
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b) Wording Requirements
i) Question:
Can the order of the sentences in the health claims (B.01.603) be reversed,
so that the nutrient content claim precedes the health claim?
Answer: No, since the exact order and wording
of permitted health claims for foods is specified in the Food
and Drug Regulations (Table following B.01.603), and these claims
can not be reworded or paraphrased.
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C. Differences Between Canada and the US
i) Question:
What are the differences between the Canadian and the US Nutrition Facts
table?
Answer: Some elements of the Nutrition Facts
table are mandatory in the US but are optional in Canada: e.g., servings
per container, Calories from fat, the footnote on percent Daily Value.
Other differences include: the Daily Values for vitamins and minerals,
some of the rounding rules, and the labelling of trans
fat.
ii) Question:
How do Canada and the US differ in the labelling of trans
fat?
Answer:
- In both Canada and the US, the Regulations require the declaration
of trans fat. However, in Canada, both the
amounts of saturated and trans fat are combined
for the calculation of the % Daily Value whereas in U.S. the Daily Value
applies only to saturated fat.
- In Canada, the statement "Not a significant source of trans
fat" may be used only when the simplified format is allowed, whereas
in the US, it may be used as soon as trans
fat may be expressed as zero.
- The rounding rules for trans fat differ
between Canada and the US.
iii) Question:
What is Health Canada's rationale for developing more restrictive criteria
for making saturated and trans free claims
in Canada compared to the US?
Answer: The levels established for fats and trans
fat are in line with the Nutrition Recommendations for Canadians, and
are consistent with current knowledge respecting their nutritional effects.
iv) Question:
How do the Canadian rounding rules for the Nutrition Facts table differ
from those of the US?
Answer: There are a few differences in rounding
between Canada and the US. Two examples include:
- In Canada, total fat must be declared as zero when the product contains
less than 0.5 g fat and contains less than 0.2 g of each saturated and
trans fatty acids per serving and per reference
amount. In the US the only requirement for declaring the total fat as
zero is that the product must contain less than 0.5 g. fat per serving.
- In Canada, saturated fat must be declared as zero when a food contains
less than 0.2 g per serving and per reference amount. The same rule
applies to trans fat. In the US the threshold
level for both saturated fat and trans fat
is 0.5 g per serving.
v) Question:
If a product is to be sold in Canada and the US, will that product have
two separate nutrition facts tables due to the different rounding and
Daily Value rules?
Answer: No, only Nutrition Facts tables that
comply with the Food
and Drug Regulations
may appear on food labels in Canada. As the American format does not meet
the Canadian requirements, it cannot be used on foods sold in Canada (B.01.401).
vi) Question:
Is Health Canada planning on working with the US to harmonize the Nutrition
Facts table?
Answer: Increasing the compatibility of these
Regulations with those of the US, to the greatest extent possible, continues
to be a clear objective of Health Canada. However, emerging science, health
concerns and differences in diet (e.g., content of trans
fat in the Canadian diet) continue to limit the extent of harmonization,
as do Canadian bilingual requirements and some differences between the
units of measurement used in both countries.
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