CFIA’s Phase III of Key Proposals to Modernize the Food Labeling System in Canada: Consultation Open
There are several initiatives currently underway to revise Canadian food labels. The proposed changes are included under the broad umbrella of Health Canada’s Healthy Eating Strategy, an effort to empower consumers to make healthier food choices by making food labels easier to read and understand.
Some of these changes are:
The changes in the last point, updated Canadian food labels, include some very prescriptive requirements that will change the look of a typical Canadian food label within the next 5 years. These changes include type sizes, footnotes, and various means to highlight key information in both the Nutrition Facts Table and the list of ingredients on the food label.
While these changes are significant, there are still several key items on the Canadian food label that are not addressed in the new rules. The CFIA’s Food Labelling Modernization Initiative (FLM) addresses changes that will be required to Canadian food labels above and beyond the changes to the NFT and ingredient listing. Some of these are:
Date marking – the FLM proposes to use Expiration Date, and when that is not needed, use Best Before Date. An “Expiration Date” must be declared when food must be consumed before a certain date to ensure its safety. The “Best Before Date” must be declared when an “Expiration Date” is not required. These changes will align Canadian requirements with the Codex Alimentarius Commission’s proposed revisions to date marking in the Codex General Standard for Labelling of Prepackaged Foods.
Storage conditions – to be declared on food labels if required to support the integrity of the food.
Legibility and Placement of Information – minimum type height, Upper and lower case letters, and adequate contrast have been proposed for common name, dealer information, and date marking.
Company information – under the newly proposed Safe Food for Canadians Regulations, importers of pre-packaged foods will be required to obtain a licence for this activity from CFIA. Under the FLM proposal, the name of the CFIA licence holder will be required on all imported food labels. Company information will also be expanded beyond the current company name, city and province (or city and country) to include at least one of the following: telephone, email or website.
Origin of Imported Food – the proposal is to require all wholly imported food products to include “Product of (naming the country)” information, on the principal display surface or adjacent to the dealer information. The use of “packaged by”, “manufactured by”, “prepared for” or “imported by/for” will be eliminated.
Improving Information on Key Ingredients – companies usually draw attention to the presence of specific ingredients in their products through the product name, ingredient claims or pictures. The current proposal will require the percentage of any ingredient highlighted through words or pictures on the label or in advertising to be declared in the ingredient list. Other restrictions on declaring flavouring of products will also be introduced.
There are other administrative changes in the proposal dealing with ingredient class names, composition and naming of standardized foods, standard food container sizes, and the use of Test Market Authorizations (TMAs) for short-term exemptions to current regulations.
All of these changes taken together will have a significant impact on Canadian food labels.
In addition, many companies are currently taking advantage of the TMA process to legally market certain food items that are outside the scope of the current Food and Drug Regulations.
If you are a stakeholder involved in the marketing of food or in production of food labels, you should take advantage of the current open consultation and make your views known.
These changes are all outlined in the Engaging on Key Proposals to Modernize the Food Labelling System Phase III Discussion Paper and Questionnaire, which can be found at http://www.inspection.gc.ca/food/labelling/labelling-modernization-initiative/consultations/engaging-on-key-proposals/eng/1476446324873/1476446325466.
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