936081 Airport Road, Mulmur ,Ontario, L9V 0L3
Tel: (705) 435-2041 / Fax: (705) 435-1467
president@legalsuites.com
Comprehensive Information
• Food Suite® Know-How
resource sampler
• Allergen Labelling References
• CFIA’s Guide to Food Labelling
and Advertising
• National Organic Standards &
Regulations
• CFIA’s Highlighting of
Ingredients
• Web resources
• Contact Links
and more….
The objectives…
• Key considerations and definitions
• Applicability, exemptions and special
considerations.
• Location considerations.
• Presentation considerations and specifications
• Formatting with proper nomenclature, including
collective and class terminology.
• Component declarations and exemptions.
• Ingredient options and further considerations
such “processing aids”.
• Allergen Labelling (new regulations)
FOCUS
Our focus
is on
federal
legislation.
General:
1. Levels of Government
There are numerous acts
and regulations that govern
food in Canada. These
include legislation
administered and
enforced by federal and
provincial jurisdictions.
FEDERAL
continued…
Foundation
PROVINCIAL
2. Legislations
3. Classification
FOCUS
Our focus
is on
federal
legislation.
continued…
General:
There are numerous acts
and regulations, (federal
and provincial), that require
a food to include a list
ingredients. The Food and
Drug Regulations however
prescribe in detail how to a
list of ingredients needs to
be and may presented.
Foundation
1. Ingredient List Basics
2. Legislation
3. Highlighting of
Ingredients
Federal (all foods & beverages)*
Municipal
Regulations
Municipal
inspection
and requirements are
essentially
an
extension
of
Provincial
authority.
 Domestic, Imports & Exports
 Retail & Institutional
 Fresh & Manufactured
Provincial (some foods & beverages)




Dairy Products / Dairy Substitutes
Environmental (packaging, recyclable, redemption)
Alcoholic Beverages
Provincial Meat
Municipal (some foods & beverages)
 Foodservice / In Store Bakery / Manufacturing
Meet
the
FEDS
Health Canada (HC)…
Canadian Food Inspection Agency (CFIA)
HC
Focus on
Health
Products
and Food
Branch
&
Public
Health
Agency of
Canada
continued…
Health Canada presides over…

Food and Drugs Act and Regulations
(Provisions relating to public health, safety and nutrition)








Food Additive Use
Nutrition Labelling
Nutrient Content & Health Claims
Food Fortification
Novel Foods
Nutrition Supplements.
Herbs and Botanicals (drug or natural health product)
In the case of foods more of a technical resource
and support role, but no inspection or
enforcement – CFIA manages the later for HC.
CFIA
CFIA
created in
1997 by an
Act of
parliament
bring
certain
disciplines
of Ag Can,
Health
Can and
Fisheries
Can under
one
agency.
Canadian Food Inspection Agency (CFIA)…






Over all foods.
From gate (inputs) to plate (outputs).
Front line inspection and service organization for
food and agricultural industry.
Responsible for administration and enforcement of
numerous Federal commence Acts & Regulations.
Enforces the Food and Drug Act and
Regulations and the Consumer Packaging and
Labelling Act and Regulations (sections applicable to food).
Sub domains:
Meat, Processed Fruit & Vegetables, Dairy, Fish, Fair Labelling, etc.
continued…
CFIA
Specific
web
resources
available
for most
divisions
within
CFIA.
Canadian Food Inspection Agency (CFIA)…
 Divisions…






continued…
Fair Labelling Practices
Meat & Poultry
Process Fruit and
Vegetable Program
Fish Products
Egg and Processed Egg
Program
Agri-Food Products
FDR…
 Is the umbrella law governing
all foods in Canada.
Exit
FDA&R
e.g.
structure



It is not a paramount Act.
It is however a criminal law
Meat, Fish, Processed Fruit and
Vegetable, Dairy & Manufactured Foods
Prescribes (highlights):
 Food additive use and limitations.
 Nutrient fortifications (range and limits).
 Packaging, labelling, coding, etc.
continued…
Food & Drug Regulations Highlights (FDR):
FDR
Governs
many
other
matters
related to
food safety
and
labelling.
continued…







Governs basic labelling.
Governs food additives.
Governs vitamin and mineral fortification.
Governs ingredient labelling.
Governs nutrition labelling.
Governs nutrient content & health claims.
Governs percent protein labelling on
certain meat products.
 Governs durable life dating on retail
packaged foods.
FDR Structure:
 ACT
EXIT
Food Suite
Consolidat
ed edition.

Enabling the regulations
 REGULATIONS



Divided into Parts A, B, C, D, etc.
Further divided into Divisions 01, 02, 03, etc.
Further divided into section 001, 002, 003,
etc.
Part B (Division 1)
continued…
Section 3.1 (Drug Type Representations):
continued…
3. (1) No person shall advertise any food, drug,
cosmetic or device to the general public as a
treatment, preventative or cure for any of the
diseases, disorders or abnormal physical states
referred to in Schedule A.
(2) No person shall sell any food, drug, cosmetic or
device
(a) that is represented by label, or
(b) that the person advertises to the general
public as a treatment, preventative or cure for
any of the diseases, disorders or abnormal
physical states referred to
in Schedule A.
Section 5.1 (Misrepresentation):
5. (1) No person shall label, package, treat, process,
sell or advertise any food in a manner that is
false, misleading or deceptive or is likely to
create an erroneous impression regarding its
character, value, quantity, composition, merit or
safety.
(2) An article of food that is not labelled or
packaged as required by, or is labelled or
packaged contrary to, the regulations shall be
deemed to be labelled or packaged contrary to
subsection (1).
continued…
Ingredient List…
 FDR as well as other regulations requires a
list of ingredients on a packaged food when
more than one ingredient is present, but the
FDR is where much of the technical
considerations are prescribed.
 Recipe of an Ingredient List…
Ingredient:
continued…
Component:
• Know-how
• Information
The following foods shall carry a label when offered for sale…
Reference
B.01.003
FDR
continued…
(a) all prepackaged products other than
(i) prepackaged confections, commonly known as one bite
confections, that are sold individually, and
(ii) prepackaged products consisting of fresh fruits or fresh
vegetables that are packaged in a wrapper or confining
band of less than 1/2 inch in width;
(b) meat and meat by-products that are barbecued, roasted or
broiled on the retail premises; and
(c) poultry, poultry meat or poultry meat by-products that are
barbecued, roasted or broiled on the retail premises;
(d) horse-meat or horse-meat by-product;
(e) any substance or mixture of substances for use as a food
additive or food additive preparation; and
(f) flour and whole wheat flour that has been treated with
gamma radiation from Cobalt 60 Source.
Reference
B.01.008
FDR
Applicability [B.01.008(1)] …

Where a prepackaged product consists of more
than one ingredient, a list of all ingredients and
their components, if any, are required to be
declared on the label.
Hint: Think that all foods require an ingredient list, then
determine what exemption maybe applicable.
Reference
B.01.001
FDR
continued…
Prepackaged Product [B.01.001]…

Means any food that is contained in a package
in the manner in which it is ordinarily sold to or
used or purchased by a person.
o
o
Excludes: Clerk serve
Includes: Non retail institutional packages
Other Label Exempt Prepackaged foods…
 * prepackaged confections, commonly known
as one bite confections, that are sold
individually, and
 * prepackaged products consisting of fresh
fruits or fresh vegetables that are packaged
in a wrapper or confining band of less than
1/2 inch in width;).
continued…
* These prepackaged foods are exempt altogether from labelling
under B.01.003(a) - FDR.
Phosphate
& Water
Added
Meats
Need list of
ingredients
when not
cured and
packaged
from bulk
at retail.
continued…
B.01.008(2)(a) to (e) Ingredient List Exemptions:
(a) prepackaged products packaged from bulk on retail premises,
except prepackaged products that are a mixture of nuts;
(b) prepackaged individual portions of food that are
served by a restaurant or other commercial
enterprise with meals or snacks;
(c) prepackaged individual servings of food that are prepared by a
commissary and sold by automatic vending machines or mobile
canteens;
(d) prepackaged meat and meat by-products that are barbecued,
roasted or broiled on the retail premises;
B.01.008(2)(a) to (e) Ingredient List Exemptions:
Additional
Slide.
(e) prepackaged poultry, poultry meat or poultry meat by-products
that are barbecued, roasted or broiled on the retail premises.
(f) Bourbon whisky and prepackaged products subject to
compositional standards in Division 2; or
(g) prepackaged products subject to compositional standards in
Division 19.
continued…
B.01.008(7)&(8)&(10)&(11)] Specific Exemptions:
(7) wax coating compounds and their components are not required
to be shown on the label of a prepackaged fresh fruit or fresh
vegetable as an ingredient or component thereof.
(8) sausage casings are not required to be shown on the label of
prepackaged sausages as an ingredient or component thereof.
(9) hydrogen, when used for hydrogenation purposes, is not
required to be shown on the label of any prepackaged product as an
ingredient or component thereof.
(10) components of ingredients of a sandwich made with bread are
not required to be shown in the list of ingredients on the label of the
sandwich.
continued…
Reference
B.01.001
FDR
Ingredients Definition…
 Means an individual unit of food that is
combined as an individual unit of food with one
or more individual units of food to form an
integral unit of food that is sold as a
prepackaged.
Component Definition…
continued…
 Means an individual unit of food that is
combined as an individual unit of food with one
or more individual units of food to form an
integral unit of food that is sold as a
prepackaged.
Reference
B.01.001
FDR
Agricultural Chemical Definition…

Means any substance that…
(a) is used or represented for use in or upon a food during production, storage or
transport, or
(b) has been registered under the Pest Control Products Act and the use of which
results or may reasonably be expected to result in a residue for such substance or
a derivative thereof in or upon foods, and includes any pesticide, plant growth
regulator, fertilizer, adjuvant, carrier or ingredient used with such a substance,
But does not include any…
continued…
(c) food additives, other than those listed in the tables to Division 15,
(d) nutritive material that is used, recognized or commonly sold as an article or
ingredient of food,
(e) vitamin, mineral nutrient or amino acid,
(f) spice, seasoning, flavouring preparation, essential oil, oleoresin or natural extractive,
(g) food packaging material or component thereof, or
(h) drug recommended for administration to animals that may be consumed as food;
Reference
B.01.001
FDR
continued…
Food Additive Definition…

Means any substance the use of which results, or
may reasonably be expected to result, in it or its byproducts becoming a part of or affecting the
characteristics of a food, but does not include.
(a) any nutritive material that is used, recognized, or commonly sold
as an article or ingredient of food,
(b) vitamins, mineral nutrients and amino acids, other than those
listed in the tables to Division 16,
(c) spices, seasonings, flavouring preparations, essential oils,
oleoresins and natural extractives,
(d) agricultural chemicals, other than those listed in the tables to
Division 16,
(e) food packaging materials and components thereof, and
(f) drugs recommended for administration to animals that may be
consumed as food;
Health
Canada
Marketing
Authorization
MA Food
Additives
MA (Marketing Authorization) …




MA - IbR
continued…
Under the FDR (new).
Provide Health Canada authority to issue exemptions
from regulations on prohibitions found in either the
FDA or the FDA.
MAs can be used to define classes, set
conditions and incorporate documents by
reference (IbR) - (new).
MAs are ministerial regulations , not Governor in
Council Regulations, (GICR). They do not need to be
formalized like GICR, but certain Mas will be appear
in Canada Gazette II and be annexed to the FDA.
Jobs,
Growth
and Longterm
Prosperity
Act
MA & IbR - History…


Bill C-38

continued…
The authority for Health Canada to issue MA,
(Marketing Authorizations), and incorporate
documents, (IbR), by reference in the FDA was
provided in amendments to the FDA as enacted by
the Jobs, Growth and Long-term Prosperity Act.
The Bill was assented to June 29, 2012. Health
Canada issued the first MA related to food additives
on October 25, 2012.
Formal GIC regulations need to be made in order to
repeal the food additive tables from the FDR.
Health
Canada
Temporary
Marketing
Authorization
Health
Canada
TMA
Energy
Beverages
TMA (Temporary Marketing Authorization) …







continued…
Under the FDR.
Provide Health Canada authority to issue exemptions
from regulations.
Purpose is gather information in support of regulatory
change
Requires a formal submission to designated authority
Requires a reporting obligation by the applicant
Typically offered for 2 years or more (e.g. 5 years for
energy beverages)
Examples include calcium fortification of orange juice
(Historical) and Energy Beverages.
Note
TMAs
use to be
rare, e.g.
calcium
fortified
orange
juice
(now
under an
IMA).
IMAs are
now
replaced
by MAs.
continued…
TMA (continued) …







BACKGROUND
Under the FDR.
Provide Health Canada authority to issue exemptions
from regulations.
Purpose is gather information in support of regulatory
change
Requires a formal submission to designated authority
Requires a reporting obligation by the applicant
Typically offered for 2 years or more (e.g. 5 years for
energy beverages)
Examples include calcium fortification of orange juice
(Historical) and Energy Beverages.
Note
TMAs
are not
suited for
food
additive
or novel
food
issues, as
there is a
level
safety
needed to
issue
TMAs.
continued…
TMA (continued) …






BASIC CONSIDERATIONS
A TMA will identify the food authorized in
the TMA. Only that food is eligible for sale.
A TMA will have a set period time,
(generally up to 24 months)
A TMA only authorizes the applicant to sell
a food product named therein.
A TMA may limit the area of sale of the food.
A TMA may limit the quantity of food that may be sold.
A TMA may assign reporting obligations during the
course of the IMA period.
Reference
B.01.001
FDR
Food Colour Definition…
 Means those colours permitted for use in or
upon food by Division 6 - FDR.
Unstandardized Food…
 Means any food for which a standard is not
prescribed in this Part, (meaning Part B – FDR)
Exit FDR
B.01.002 FDR
continued…
Standardized Food (B.01.002 – FDR)…
 Means any food for which a standard is
prescribed in Part B – FDR. Marked as “[S]”.
Grouping
The
ingredient
list will
need to be
grouped
together
with other
required
elements,
unless
otherwise
provided
for. (e.g.
aspartame
, allergen
contains).
Ingredient Presentation Specs [B.01.005 / B.01.008]…
FEATURE…
REQUIREMENT…
Format
As required in FDR.
Location
Anywhere on label / package but bottom panel.
Type Size
Minimum 1.6 mm, (1/16 inch), based on lowercase “o”, or
height of uppercase letters if all uppercase letters are
used.
Type Face
Regular or bold.
Language
English and French unless exempt.
Note: Federal English and French requirements relate to mandatory
information. Québec requires French to be at a minimum of equal
prominence to any other language.
Typography – Type Face…
 A regular typeface is acceptable. The
declaration can be in uppercase or lowercase,
or a combination thereof. A sans serif typeface
may lend itself better to providing a more clear
and legible declaration. However, the
regulations do not specify or restrict typefaces.
continued…
Typography – Type Height…
Other
Regulations
Other regs
like the
MIR do
specify a
1/16 inch
minimum
for the list
of
ingredient.
continued…
 The precise type height is not specified in the
regulations. As a rule of thumb the type height
should be no less than 1/16 inch (1.6 mm),
based on the lower case “o” where mixed case
letters may be used.
 The FDR sates
A.01.016. All information required by these Regulations to appear on a
label of a food or drug shall be
(a) clearly and prominently displayed on the label, and
(b) readily discernible to the purchaser or consumer under the customary
conditions of purchase and use
Typography – Type Height…
 Excerpt from the Consumer Packaging and
Labelling Regulations…
16. Notwithstanding section 15, where the area of the principal display
surface of a container is 1.55 square inches (10 square centimetres) or
less, and where all the information that is required by the Act or these
Regulations to be shown on a label is shown on the principal display
panel, such information, other than the information in the declaration of
net quantity, may be in letters of not less than 1/32 inch (0.8 millimetre) in
height.
continued…
Heading…
 The heading “Ingredients” is not specified in the
regulations. It is however a customary practice
for which consumers are accustomed too, and
as such would be considered good labelling
practices to use.
Highlighting…
continued…
 Highlighting of ingredients to over-emphasize
their presence is considered inappropriate. In
certain cases this may lead to the misrepresentation of the character or value of the
product, as defined in section 5.1 of the FDA.
Grouping Example…
 The list below
should de declared
as shown to the
right.
continued…
INGREDIENTS: Orange juice,
water fruit pectin, citric acid,
malic acid, sucralose,
acesulfame-potassium,
potassium citrate, ascorbic
acid (vitamin C), beta
carotene, thiamine
hydrochloride (vitamin B1),
folic acid.
18 mg acesulfame-potassium
and 5 mg sucralose per 250
mL
Order of Presentation…
continued…
 Displayed in descending order of proportion by
weight or,
 As a percentage of the prepackaged product
 In both cases (order or percentage) the
information is based on the ingredient as
added to the food.
 Water: May on an administrative basis be
declared in its descending order of proportion
based on the finished food, as opposed to
when it is added. Technically there is no
regulatory provision for this practice.
Order Options…
The following may be shown at the end of the
ingredient list in any order…
(a)
(b)
(c)
(d)
continued…
(e)
(f)
(g)
(h)
spices, seasonings and herbs, except salt;
natural and artificial flavours;
flavour enhancers;
food additives, except ingredients of food additive
preparations or mixtures of substances for use as a food
additive;
vitamins;
salts or derivatives of vitamins;
mineral nutrients; and
salts of mineral nutrients.
Breaking
Out
To break
out
components
an declare
them as
ingredients
requires
knowledge
as to there
proper
order in
the list.
continued…
Component Declaration [B.01.008(5)]…
 Immediately after the ingredient, in a clear
manner to identify that they are components of
that ingredient. This is generally done be
enclosing them in parenthesis.
 Displayed in descending order of proportion by
weight.
 Components may be broken out, (generally
speaking here in relation to the parenthetical
declaration), and declared as ingredients in
their respective descending order of proportion
or as a percentage.
Example of Component Declaration…
INGREDIENTS: WATER, CHEDDAR CHEESE (MODIFIED MILK
INGREDIENTS, SALT, BACTERIAL CULTURE, CALCIUM CHLORIDE,
MICROBIAL ENZYMES, COLOUR), SALT, NATURAL FLAVOUR,
SPICES.
CHEESE SAUCE EXAMPLE
INGREDIENTS: WATER, MODIFIED MILK INGREDIENTS, SALT,
BACTERIAL CULTURE, CALCIUM CHLORIDE, MICROBIAL
ENZYMES, COLOUR, NATURAL FLAVOUR, SPICES.
Reference
B.01.001 &
B.01.010
FDR
Nomenclature…
 Common Names: Ingredients and
Components are declared by their proper
common name as defined in B.01.001 and
B.01.010.
Example: Hydrolyzed soy protein
 Collective Names: As per B.01.010(3)(b)
Exit FDR
B.01.009 FDR
continued…
Example: Vegetable oil / sulphites / modified milk
ingredients
 Class Names: As per B.01.010(4)
Excludes ingredients referred to in B.01.009(1)
Example: Concentrated fruit juices
Reference
B.01.001 &
B.01.010
FDR
Component Exemptions from Declaration…
 Listed in B.01.009 (1) and (2)
 Components of ingredients of a sandwich
made with bread are not required to be shown
in the list of ingredients on the label of the
sandwich [B.01.008(10) - FDR]
Component Exemptions Revoked …
continued…
 Listed in B.01.009 (3), (4) and (5)
(e.g. Salt in seasonings, Peanut oil in flavours)
 If it is a food allergen, gluten source or
sulphites (required to be declared).
Specific Labelling Considerations…
 Processing Aids: There is no explicit definition in
the FDR concerning “processing aids”. CFIA
administratively defines these in the GTFLA,
(2.8.3).
 Food Additives: Food additives are not processing
aids.
Excerpt
2.8.3
GTFLA
continued…
Excerpt
2.8.3
GTFLA
continued…
Specific Labelling Considerations…
Available
on HC web
site
continued…
 Health Canada:
A policy document,
“Policy for
Differentiating Food
Additives and
Processing Aids”, has
been drafted by HC in
December 2008.
Specific Labelling Considerations…
 Differentiating Food
Additives and
Processing Aids:
The image to the right is an
excerpt of the decision tree
for evaluating what processing
aids are. A review of the entire
HC document, Differentiating
Food Additives and
Processing Aids”, is essential.
continued…
NFT
Nutrition
Facts
Table
continued…
Special Considerations…
 Sugar Alcohol [B.01.401 – FDR: Where the
food contains added sugar alcohols such as
but not limited too sorbitol, maltitol, xylitol,
lactitol, mannitol, etc., the amount of the sugar
alcohol or alcohols must be expressed in the
NFT in grams per serving of stated size.
Special
Considerations
Continued
Note: This
does not
apply in
respect of
the
ingredient
"enriched
flour".
continued…
 Vitamins & Minerals [B.01.401, D.01.007(1) & D.02.005(1)]:
o Where the vitamin or mineral is a component of
an ingredient referred to in B.01.009, and is
declared on the label, the following would apply.
• the vitamin is declared by its common name within
parentheses immediately following the declaration of the
ingredient;
• the total content of the vitamin in the prepackaged
product is declared in accordance with section
D.01.005; and
• all components of the ingredient are declared.
o Nutrition Facts: Where a vitamin or mineral nutrient is
declared in the list of ingredients, the NFT must
include that nutrient.
Ingredient Omissions or Substitutions [B.01.011(1)]…
 It is possible to omit an ingredient or component, or
substitute an ingredient or component in a
prepackaged product under the following conditions.
Example:
vegetable
oil
continued…
o The ingredient or component may be omitted, even though it is declared.
o The ingredient or component may be substituted with another, (within a 12
month period), as long as it is shown in the label that the ingredient or
component may be omitted and ingredient or component, which is
therefore substituted.
o The ingredients or component omitted/substituted are declared in
descending order of proportion as they likely occur in the 12 month period.
o This is applicable where the omission or substitution is based on
acceptable manufacturing practices. It is also subject to section 5.1 of the
FDA, which deals with misrepresentation.
Ingredient - Varying Proportions [B.01.011(2)]…
 It is possible to vary the proportion of ingredients or
components as they are declared on the label under
the following conditions.
o It is clearly stated on the label that such variance of the
ingredient in the list of ingredient may occur.
o The ingredients or component subject to variances are
declared in descending order of proportion as they likely
occur in the 12 month period.
o This is applicable where the variance is based on
acceptable manufacturing practices. It is also subject to
section 5.1 of the FDA which deals with misrepresentation.
continued…
Food & Drug Regulations [Federal]:
New regulations amend or add to the current FDR.
Principally, but not exclusively to part B.
Applicability:
Applies to all “prepackaged” food to which
defined food allergens, gluten sources and
sulphites are deliberately present as an
ingredient or a constituent of an ingredient.
continued…
Note: the term “prepackaged” includes both retail and
non retail foods.
Exemption
Revoked
If a list of
ingredients
is
voluntarily
declared,
the
allergen,
gluten and
sulphite
regulations
kick in.
continued…
Non - Applicability: The regulations do not apply...
 When a food allergen or gluten source is present as
result of cross contamination.
 In the case of beers subject to standards in
B.02.130 (Beer) or B.02.131 (Ale, Stout, Porter,
Malt Liquor) – FDR, where a list of ingredients is not
shown on the label.
 In the case of a prepackaged product exempt from
the declaration of a list of ingredients in
B.01.008(2)(a) to (e), except when a list of
ingredients is shown on the label.
B.01.008(2)(a) to (e) exemptions:
continued…
(a) prepackaged products packaged from bulk on retail premises,
except prepackaged products that are a mixture of nuts;
(b) prepackaged individual portions of food that are
served by a restaurant or other commercial
enterprise with meals or snacks;
(c) prepackaged individual servings of food that are prepared by a
commissary and sold by automatic vending machines or mobile
canteens;
(d) prepackaged meat and meat by-products that are barbecued,
roasted or broiled on the retail premises;
(e) prepackaged poultry, poultry meat or poultry meat by-products
that are barbecued, roasted or broiled on the retail premises.
Vintage
Wine
CFIA
excuses
vintage
wines
made
before the
allergen
labeling
came into
effect from
allergen
labelling.
Other Exempt Prepackaged foods…
 * prepackaged confections, commonly known
as one bite confections, that are sold
individually, and
 * prepackaged products consisting of fresh
fruits or fresh vegetables that are packaged
in a wrapper or confining band of less than
1/2 inch in width;).
* These prepackaged foods are exempt altogether from labelling
under B.01.003(a) - FDR.
Specific Examples of Applicable Products…
 * Bourbon whisky and prepackaged products
subject to compositional standards in
Division 2, (e.g. wine).
 * Prepackaged products subject to
compositional standards in Division 19
(vinegars).
* These foods are exempt from declaring a list of ingredients, but if
food allergens, gluten sources or sulphites are present these must be
identified.
Question
Is a
soybean
oil that
does not
contain
and soy
protein a
food
allergen?
Answer
NO. By
FDR
definition.
continued…
Food Allergen Definition [B.01.010(6) - FDR]:
“food allergen” means any protein from any of the
following foods, or any modified protein, including any
protein fraction, that is derived from any of the
following foods:
(a) almonds, Brazil nuts, cashews,
hazelnuts, macadamia nuts,
pecans, pine nuts, pistachios or
walnuts;
(b) peanuts;
(c) sesame seeds;
(d) wheat or triticale;
(e) eggs;
(f) milk;
(g) soybeans;
(h) crustaceans;
(i) shellfish;
(j) fish; or
(k) mustard seeds.
Reference
B.01.010(6)
FDR
Wheat
Includes
cereal
plants from
the genus
“Triticum”,
which
includes
kamut,
spelt, etc.
continued…
Common Food Allergen Names…
FOOD ALLERGEN…
NAMING CONSIDERATIONS*…
(a) almonds, Brazil nuts, cashews,
hazelnuts, macadamia nuts, pecans, pine
nuts, pistachios or walnuts; (b) peanuts;
(e) eggs
Singular or plural as shown
(c) sesame seeds
“sesame”, “sesame seed” or
“sesame seeds”
(d) wheat or triticale; (f) milk
as shown
(g) soybeans
“soy”, “soya”, “soybean” or
“soybeans”
(k) mustard seeds.
“mustard”, “mustard seed” or
“mustard seeds”
Common Food Allergen Names…
Reference
B.01.010(6)
FDR
FOOD ALLERGEN…
NAMING CONSIDERATIONS*…
(h) crustaceans
the name of the crustacean
e.g. shrimp
(i) shellfish
the name of the shellfish
e.g. oyster
(j) fish
the name of the fish
e.g. anchovy
* The manner in which the English food allergen term is to be shown
in a list of ingredients or in a contains statement is prescribed in the
FDR. The same is true for the French food allergen terms.
Question
Is barley
flour when
present in
wheat flour
a gluten
source?
Answer
YES. By
FDR
definition.
Gluten Source [B.01.010(6) - FDR] :
“gluten” means any gluten protein from the grain of any of
the following cereals, or from the grain of a hybridized
strain that is created from at least one of the following
cereals:
(i) barley,
(ii) oats,
(iii) rye,
(iv) triticale,
(v) wheat.
It includes any modified gluten protein, including any gluten
protein fraction, that is derived from the grain of any of the
cereals referred to above or from the grain of a hybridized
strain referred to above.
Common Gluten Source Names…
Reference
B.01.010(7)
FDR
GLUTEN SOURCE…
NAMING CONSIDERATIONS*…
(i) barley,
(ii) oats,
(iii) rye,
(iv) triticale,
(v) wheat.
The cereal name as shown is to be used in
the case of gluten from, or derived from, the
named grain of these sources, (e.g. “oats”).
The cereal names as shown is to be used in
the case of gluten from, or derived from, a
hybridized strains of these sources, (e.g.
“barley” and “rye”).
* The manner in which the English food gluten source term is to be
shown in a list of ingredients or in a contains statement is
prescribed in the FDR. The same is true for the French gluten
source terms.
Food Allergen & Gluten Sources…
Reference
B.01.010(8)
FDR
 Declare by common allergen or gluten source name.
 Declare food allergen or gluten source in either…
 the list of ingredients or
 an allergen contains statement
 An allergen contains statement is optional, unless…
Reference
B.01.010(9)
FDR
continued…
 it is, or is present in, an ingredient not shown
in list of ingredients, (e.g. “wine (sulfites)”), or
 it is, or is present in, a component and neither
the component nor the ingredient of the
component it is present in, is shown in the list
Reference
B.01.010.1
(8) FDR
Allergen & Gluten Labelling …
 When declared in list of ingredients the allergen or
gluten source must be shown in parenthesis
immediately after …
 an ingredient, if it is that ingredient, is present
in a component where the component is not
declared or is otherwise present in the
ingredient, (e.g. “butter (milk)”, “flavour (soy)”)
 a declared component, if it is that component
or is present in that component
continued…
Reference
B.01.010.1
(10) FDR
Allergen & Gluten Labelling (continued)…
 When declared in list of ingredients the allergen or
gluten source need not be shown in parenthesis
immediately after the ingredient or component if…
 the allergen and gluten source name already
appears as part of an ingredient or component
common name, (e.g. “wheat flour”)
 is already shown in parenthesis of another
ingredient or component
 appears in a contains statement
Allergen
Naming
Option
INGREDIENTS: WHEAT FLOUR, BUTTER (MILK), SUGAR, CORN
STARCH, SOY LECITHIN, DRIED COCONUT (CONTAINS
SULPHITES), SODIUM CASEINATE (MILK), BARLEY MALT FLOUR.
INGREDIENTS: FLOUR (WHEAT), BUTTER (MILK), SUGAR, CORN
STARCH, SOY LECITHIN, DRIED COCONUT (CONTAINS
SULPHITES), SODIUM CASEINATE, BARLEY MALT FLOUR.
 Wheat flour can be named as “flour”, (B.13.001 – FDR), but
it must be identified as “wheat” in either the name, in
parenthesis or in a contains statement.
continued…
INGREDIENTS: FLOUR, BUTTER, SUGAR, CORN STARCH, SOY
LECITHIN, DRIED COCONUT (CONTAINS SULPHITES), SODIUM
CASEINATE, BARLEY MALT FLOUR.
CONTAINS WHEAT, MILK, SOY, BARLEY, SULPHITES.
Allergen
Soy
Lecithin
INGREDIENTS: WHEAT FLOUR, BUTTER (MILK), SUGAR, CORN
STARCH, SOY LECITHIN, DRIED COCONUT (CONTAINS
SULPHITES), SODIUM CASEINATE (MILK), BARLEY MALT FLOUR.
INGREDIENTS: WHEAT FLOUR, BUTTER (MILK), SUGAR, CORN
STARCH, SOY LECITHIN, DRIED COCONUT (CONTAINS
SULPHITES), SODIUM CASEINATE, BARLEY MALT FLOUR.
 Sodium caseinate is also a milk allergen but is already
covered as butter is identified as a milk allergen.
 Soy lecithin is an allergen and is thus so labelled and must
appear in a contains statement , when used.
Allergen
Milk
Common
Name
continued…
INGREDIENTS: WHEAT FLOUR, BUTTER, SUGAR, CORN STARCH,
SOY LECITHIN, DRIED COCONUT (CONTAINS SULPHITES),
SODIUM CASEINATE, BARLEY MALT FLOUR.
CONTAINS WHEAT, MILK, SOY, BARLEY, SULPHITES.
Allergen
Fish
Naming
INGREDIENTS: WHEAT FLOUR, BUTTER (MILK), SUGAR, CORN
STARCH, GELATIN (SARDINE), SODIUM CASEINATE (MILK),
BARLEY MALT FLOUR, CARAMEL COLOUR.
 The source of the gelatin is fish, (sardine). As such the name
of the fish needs to be included in parenthesis or in a
contains statement .
 Barley is a gluten grain and as such must be identified bay
its common gluten name. If a contains statement is included
it must also be shown there.
Gluten
Naming
continued…
INGREDIENTS: FLOUR, BUTTER, SUGAR, CORN STARCH,
GELATIN, SODIUM CASEINATE, BARLEY MALT FLOUR, CARAMEL
COLOUR.
CONTAINS WHEAT, MILK, SARDINE, BARLEY.
Question
If a
coconut
ingredient
contains
added
sulphites,
(less than
10 ppm in
finished
food), do
sulphites
need to be
declared?
Answer
YES. Not
exempt in
FDR.
Sulphites:
“sulphites” means one or more food additives that are
listed exclusively in column I of item 21 of the table to
paragraph B.01.010(3)(b), see below, and are present
in a prepackaged product.
one or more of the following food additives, namely,
•
•
•
•
potassium bisulphite,
potassium metabisulphite,
sodium bisulphite,
sodium dithionite,
•
•
•
•
sodium metabisulphite,
sodium sulphite,
sulphur dioxide
and sulphurous acid
Reference
B.01.010.2
(6) FDR
Common Sulphite Names…
SULPHITE TERMS…
NAMING CONSIDERATIONS*…
“sulfites”, “sulfiting agents”,
If shown in the list of ingredients or in a
“sulphites” or “sulphiting agents” contains statement.
“potassium bisulphite”,
“potassium metabisulphite”,
“sodium bisulphite”, “sodium
dithionite”, “sodium
metabisulphite”, “sodium
sulphite”, “sulphur dioxide” or
“sulphurous acid” (as applicable).
Alternatively way to be shown a list of
ingredients, except if “sodium
dithionite”, “sulphur dioxide” or
“sulphurous acid” is shown, it must be
followed in parentheses by one of the
names “sulfites”, “sulfiting agents”,
“sulphites” or “sulphiting agents”.
* French sulphite nomenclature is also prescribed.
Reference
Sulphite Labelling Required…
Exempt
under
B.01.009 &
B.01.008
FDR
 When present in prepackaged food at a level of 10
ppm or more, when otherwise exempt from
declaration in a list of ingredients, sulphites may be
shown in either...
Reference
B.01.010.2
(3) FDR
continued…
 the list of ingredients or
 an allergen contains statement
 When present in prepackaged food, regardless of its
level, if not otherwise exempt from declaration in a
list of ingredients, sulphites must be shown in...
 the list of ingredients
Reference
Exempt
under
B.01.009
& B.01.008
FDR
Reference
B.01.010.2
(9) FDR
Sulphite Labelling Required (continued)…
 When present in a prepackaged food, at a level of 10
ppm or more, if not otherwise exempt from
declaration in a list of ingredients, sulphites must be
shown in...
 the list of ingredients
and in addition thereto in…
 an allergen contains statement, when a
contains statement is show
continued…
Reference
Exempt
under
B.01.009
& B.01.008
FDR
Reference
B.01.010.2
(9) FDR
Sulphites Labelling …
 When declared in list of ingredients, may be declared
at the end of the ingredient list in any order.
 When sulphites are declared in list of ingredients, if
otherwise exempt from declaration, must be shown...
 in parenthesis after the ingredient it is a
component of or
 at the end of the ingredient list in any order
 When declared in list of ingredients in any other
case, it must be shown…
continued…
 at the end of the ingredient list in any order
Sulphites Labelling (continued)…
Reference
B.01.010.2
(10) FDR
 When sulphites are shown individually in a list of
ingredients, by the name “sodium dithionite”, “sulphur
dioxide” or “sulphurous acid”, it need not be followed
in parenthesis by the terms “sulfites”, “sulfiting
agents”, “sulphites” or “sulphiting agents” if….
 one of the common terms above is already
declared in parenthesis of or in the common
name of another sulphite additive
 sulphites are declared in the contains
statement
Non Allergen
Soybean
Oil
INGREDIENTS: WHEAT FLOUR, BUTTER (MILK), SUGAR, CORN
STARCH, SOYBEAN OIL, SODIUM CASEINATE (MILK), BARLEY
MALT FLOUR, CARAMEL COLOUR.
 Refined soybean oil with no protein is not an allergen and
would not be included in a contains statement if one is
included on a label.
 Caramel colour contains sulphites, but is exempt from
declaration in B.01.009 – FDR, and sulphites in the
prepackaged food is less than 10 ppm. As such it is not
declared nor added a contains statement.
Sulphite
< 10 ppm
continued…
INGREDIENTS: FLOUR, BUTTER, SUGAR, CORN STARCH,
SOYBEAN OIL, SODIUM CASEINATE, BARLEY MALT FLOUR,
CARAMEL COLOUR.
CONTAINS WHEAT, MILK, BARLEY.
Sulphites
< 10 ppm,
not
exempt
from
declaration
INGREDIENTS: WHEAT FLOUR, BUTTER (MILK), SUGAR, CORN
STARCH, SOY LECITHIN, DRIED COCONUT (CONTAINS
SULPHITES), SODIUM CASEINATE, BARLEY MALT FLOUR.
CONTAINS WHEAT, MILK, SOY, BARLEY.
 Sulphites are a declared component of the dried coconut. It
is not exempt from declaration. It may however be declared
at end of the ingredient list. It is not shown in the “contains”
statement since it is not present in the food at a level of 10
ppm or more.
continued…
INGREDIENTS: WHEAT FLOUR, BUTTER (MILK), SUGAR, CORN
STARCH, SOY LECITHIN, DRIED COCONUT, SODIUM CASEINATE,
BARLEY MALT FLOUR, SULPHITES.
CONTAINS WHEAT, MILK, SOY, BARLEY.
Sulphites
Common
Name
INGREDIENTS: WHEAT FLOUR, BUTTER (MILK), SUGAR, CORN
STARCH, SOY LECITHIN, DRIED COCONUT (SULPHUR DIOXIDE
(SULFITE)), SODIUM CASEINATE, BARLEY MALT FLOUR.
CONTAINS WHEAT, MILK, SOY, BARLEY.
 Sulphites are a declared as a component of the dried
coconut, by a formal food additive name. In such a case it
must still be described as a sulphite by a common sulphite
name. It may also be declared at the end of the list of
ingredients in any order. If less than 10 ppm it should not
appear the contains statement.
continued…
INGREDIENTS: WHEAT FLOUR, BUTTER (MILK), SUGAR, CORN
STARCH, SOY LECITHIN, DRIED COCONUT, SODIUM CASEINATE,
BARLEY MALT FLOUR, SULPHUR DIOXIDE (SULFITE).
CONTAINS WHEAT, MILK, SOY, BARLEY.
“Contains” Statement…
 When a “contains” statement is used it must…
Reference
B.01.010.3
FDR
 appear immediately after the list of
ingredients, if there be one, without
intervening printed, written or graphic material
 must include all source names of allergens,
gluten sources and sulphites*, (once), even if
already declared in the list of ingredients
* Sulphites may only appear in the contains statement if present in the
prepackaged food at a level of 10 ppm or more.
FDR SECTION
continued…
SUMMARY OF CHANGES
B.01.008(5)(a) Placed priority on having allergen and gluten source
appear immediately after an ingredient, as opposed to a
component of an ingredient.
Item 30 and “(c)” changed to be spelled as “hydrolyzed
B.01.009(1)
B.01.009(3)(c) plant protein”. The French version will read in the singular
« protéine végétale hydrolysée ».
B.01.010(3)(a) Item 8 changed to require the source of all hydrolyzed
plant protein to be declared in a list of ingredients.
B.01.010(3)(a) Item 20 and 21 changed to require the source of all
starch and modified starch to be declared in a list of
ingredients.
B.01.010(3)(a) Item 22 added requirement to name source of all lecithin
declared in a list of ingredients.
FDR SECTION
SUMMARY OF CHANGES
B.01.010(3)(a) Item 23 and 24 added requirement to name source of all
crustaceans and shellfish in a list of ingredients.
B.13.011
Added “Corn Starch” as standard name.
B.24.018
Modified “gluten free” claim to be consistent with the
absence of gluten as defined in B.01.010.1(1).
D.01.007(1)(a) Placed priority on having allergen and gluten source
D.02.005(1)(a) appear immediately after an ingredient, as opposed to a
vitamin or mineral nutrient.
B.01.010(3)(b) Amended item 21 to permit sulphites and sulphiting
agents to also appear as sulfites or sulfiting agents.
Current Policy…
continued…
 Applies to food allergen, gluten sources and
sulphites not added to food but ones that could be
present in the food due to legitimate unavoidable
circumstances, (e.g. cross contamination).
 Cautionary allergen labelling is not prescribed by
current regulations nor is it captured under the new
food allergen labelling regulations.
 CFIA and Health Canada recognize that cautionary
allergen labelling is an appropriate risk management
tool under appropriate circumstance.
Standardization …
X
Represents
the food
allergen
 CFIA and Health Canada prefer the following…
 “may contain [X]”
 The current policy does not prohibit other statements,
but does expect them to be truthful, clear and nonambiguous, and that they are not used as a
substitute for Good Manufacturing Practices.
 Future guidelines may insist on more prescription,
(uniformity).
Future …
 Health Canada is currently reviewing the use of
cautionary allergen labelling.
 Future developments will likely include additional
guidelines by CFIA and Health Canada, but could
also include regulations.
 The current policy principles, (see below), will guide
future developments.
 to minimize risks associated with inadvertent
consumption of undeclared food allergens and added
sulphites in food; and
 to maximize choice of safe and nutritious foods for
consumers with dietary restrictions.
Reference
CFIA`s
Highlighted
Ingredients
& Flavours
Guidelines
What these Guidelines Capture…
 Common food representations concerning the
highlighting of ingredients, components, class of
ingredients or flavours outside of a list of ingredients
on a label or in advertising, that are valuable,
beneficial or otherwise desirable for the purposes of
satisfying hunger, thirst, taste or texture. They are not
paramount to prescribed regulations, (artificial
flavour, mixed nuts, etc.)
(e.g. Honey Chicken Wings)
continued…
 Highlighting can be works, images or other forms of
graphics.
Reference
CFIA`s
Highlighted
Ingredients
& Flavours
Guidelines
continued…
What these Guidelines do not Capture…
 Traditional seasoning representation related to
herbs/spices and seasoning ingredients such as leeks,
onion, garlic, hot peppers, etc.
 Highlighting of nutrients
 Highlighting of phytochemicals (whether added or
naturally occurring)
 Prescribed requirements in other regulations,
(e.g. identification of artificial flavour by vignette
under CPLA&R)
Reference
CFIA`s
Highlighted
Ingredients
& Flavours
Guidelines
continued…
Similar Ingredients…
 It is important to understand the highlighted
ingredient and all other ingredients that might be
considered similar ingredients as these will influence
the nature of how such claims may be made. .
 Similar ingredients can serve the same purpose or
primary function of the highlighted ingredient.
Effectively, a similar ingredient can substitute for he
highlighted ingredient.
Reference
Imitation Ingredients…
CFIA`s
Highlighted
Ingredients
& Flavours
Guidelines
NOTE: When there has been no
highlighting of the real ingredient,
a product may contain a similar
ingredient that imitates the real
ingredient without indicating its
presence.
continued…
Imitation Ingredients…
Product Name
Ingredients
Status
“Chocolate Chip
Cookie”
when made with chocolate chips;
with or without a vignette of the
cookie.

“Chocolate Chip
Cookie”
when made with chocolate chips
and compound chocolate; with or
without a vignette of the cookie.

Options: change name to…
“Cookie” or
“Chocolatey Chip Cookie” or
“X % Chocolate Chip Cookie”.
Reference
CFIA`s
Highlighted
Ingredients
& Flavours
Guidelines
continued…
Similar Ingredients (majority)…
Product Name
Ingredients
Status
“Seafood and Crab
Salad”
when made with 20 % cod, 20 %
pollack and 20 % crab

“Seafood and Crab
Salad”
when made with 30 % cod, 20 %
pollack and 10% crab). Not
acceptable as crab is not most
prominent.

Options: change name to…
“Seafood Salad” or
“Pollack, Cod & Crab Salad” or
“Seafood & Crab Salad - 10 % Crab” or
“Seafood and 10 % Crab Salad”.
Similar Ingredients (not the majority)…
Product Name
Ingredients
Status
“Butter Cake”
made with 7 % butter & 3 % canola oil.
(Combined weight is 10 %, butter is more than
half the combined weight of the fat ingredients)

“Butter Cake”
made with both butter and other fat or
oil ingredients (5 % butter and 8 %
canola oil)
(Combined weight of fat ingredients is 13 % of
formula, butter is less than half the combined
weight)

Options: change name to…
“Butter Flavoured Cake”
Flavour Ingredients…
Product Name
Ingredients
Status
“Blueberry
Flavoured
Muffin”
with either artificial or natural blueberry
flavour
(with a blueberry vignette, and no pieces of
blueberry pictured in product – vignette
qualified with artificial flavour when added)

“Blueberry
Muffin”
with artificial and/or natural blueberry
flavour
(with no blueberry vignette, and no pieces of
blueberry pictured in product)
– expect at least 2% real blueberry

Options: change name to…
“Blueberry Flavoured Muffin” or
“Blueberry Muffin - 0 % blueberries”
Reference
CFIA`s
Highlighted
Ingredients
& Flavours
Guidelines
continued…
Exceptions…
 8.1 Raisin Bread (FDR) B.13.025. [S].
 8.2 Whole Wheat Bread (naming the percentage)
FDR B.13.026. [S].
 8.3 Specialty Breads (B.13.029, FDR)
 8.4 Specialty Bakery Products - 5.3
 8.5 Incidental Additions - 5.2 & 5.3
 8.6 Traditional Flavour Statements - 5.4
(Chocolate cake)
 8.7 Fruit & Juice Drinks 5.3
(Juice drinks declare percent juice - main panel)
Reference
Presentation Considerations…
CFIA`s
Highlighted
Ingredients
& Flavours
Guidelines
 Additional information such as percentage
declarations, statements indicating the
presence of similar ingredients or additions
for the purpose of flavouring are considered
prominently displayed when they are easily
legible, in distinct contrast to other printed
material and either in the common name of
the food or adjacent to the highlighting such
that a consumer would easily be able to see
and relate them.
continued…
Reference
CFIA`s
Highlighted
Ingredients
& Flavours
Guidelines
continued…
Presentation Considerations (continued)…
 With multiple highlighting of an ingredient
(claim, vignette, and common name),
additional information that is prominently
displayed only needs to appear once, in close
proximity to the most prominent highlighting.
 A prominent and descriptive common name is
often all that is required to clarify highlighting.
 Referenced ingredients should be stated in
descending order of proportion by weight as is
the case with the list of ingredients.
Reference
CFIA`s
Highlighted
Ingredients
& Flavours
Guidelines
continued…
Presentation Considerations (continued)…
 All portions of the common name must be in a
type height lo less than ½ the type height of the
largest portion and no smaller than 1.6 mm based on
the lower case "o" .
 For legibility and avoidance of misleading
consumers, the type height of additional information
should at least meet the smallest of either:
• One-half of the highlighted ingredient's claim or;
• The minimum type height required for the numerical
portion of the net quantity statement [14(2), CPLR].
• Never any less than 1/16 inch (1.6 mm).
Reference
Percentage Statements…
CFIA`s
Highlighted
Ingredients
& Flavours
Guidelines
 A percentage statement is another option in certain
cases where this can provide clarity.
 Percentage statements are based on the weight of
ingredients before they are combined to make the
food. The percent is based on the weight of the food.
Some exception to this rule do exist.
 See guidelines on Exemptions and Specific Situations.
continued…
Reference
CFIA`s
Highlighted
Ingredients
& Flavours
Guidelines
continued…
Prominently…
 Information will be considered ‘prominently displayed’ when it
is in bold faced type, in a height not less than that required for
the numerical portion of the net quantity statement.
(a) 1/16 inch (1.6 millimetres), where the principal display surface of the
container is not more than 5 square inches (32 square centimetres);
(b) 1/8 inch (3.2 millimetres), where the principal display surface of the
container is more than 5 square inches (32 square centimetres) but not
more than 40 square inches (258 square centimetres);
(c) 1/4 inch (6.4 millimetres), where the principal display surface of the container
is more than 40 square inches (258 square centimetres) but not more than
100 square inches (645 square centimetres);
(d) 3/8 inch (9.5 millimetres), where the principal display surface of the
container is more than 100 square inches (645 square centimetres) but not
more than 400 square inches 25.8 square decimeters);
(e) 1/2 inch (12.7 millimetres), where the principal display surface of the
container is more than 400 square inches (25.8 square decimeters).
END
INGREDIENT CLAIMS
Negative Ingredients Claims [4.3 GTFLA]..
 General: While a statement could
be “factual”, it could still be
misleading if it gives the impression
that food differs from other similar
foods, when it does not,
(“preservative free” when food is
not permitted to contain
preservatives”). Careful, case by
case review is always needed.
Excerpt 4.3
GTFLA
continued…
1. Negative
2. No Preservatives
3. No MSG
4. Pure
5. No Artificial Flavour
6. No Artificial Colour
7. Natural
Negative Ingredients Claims [4.3 GTFLA]…
 Basic Considerations:
 Claim Must be True: The ingredient/substance must be
totally absent unless physiologically insignificant levels
can be substantiated.
Excerpt 4.3
GTFLA
continued…
Example: A claim may be false where it gives the impression that the
food does not contain the ingredient but naturally contains the
ingredient, (“no added water” in a tomato sauce which is
predominately naturally occurring water from tomatoes.
Negative Ingredients Claims [4.3 GTFLA]…
 Basic Considerations:
 Claim Must not be Misleading: Claims can be factual,
but still be misleading. Where a claim implies “false
uniqueness” it is misleading.
Excerpt 4.3
GTFLA
continued…
No Preservatives Claims [4.3.1 & 2 GTFLA]…
 General: Preservatives, in the context of “no
preservatives added” or “no preservatives”, refers
to preservatives recognized by Division 16 – FDR.
 Basic Considerations:
continued…
 Absence of Preservative: The food must not contain
directly or indirectly added preservatives, even if it is
exempt from declaration in a list of ingredients. This also
applies to the use of preservatives at some stage in the
processing of the food, even when the additive
degrades, (e.g. ascorbic acid in juices).
 Naturally Occurring Preservatives: Claims would be
factual where the preservative is naturally occurring,
(e.g. benzoates in fruit juice ingredients).
No Preservatives Claims [4.3.1 & 2 GTFLA]…
 Basic Considerations (continued…):
 Salt, Sugar and Vinegar: These are not considered
preservatives. Acetic acid, (Division 16 – FDR), is a
class I preservative.
 Liquid Wood Smoke: This is not considered a
preservative for labelling purposes.
 Manipulation: Claims would not be factual where other
ingredients are used to functionally substitute for
preservatives, (e.g. cultured dextrose/milk containing
increased levels of peptides and propionic, butyric and
lactic acids).
continued…
No Preservatives Claims [4.3.1 & 2 GTFLA]…
 Basic Considerations (continued…):
 Multi-Functional Additives: Certain Division 16 food
additives have are recognized as preservatives, but also
for other functions such as acidulation, dough
conditions, nutrient sources, etc.). When such additives
are present for functions other than for preservatives a
claim to the effect that the food does not contain
preservatives may be made. Conditions apply.
continued…
No Preservatives Claims [4.3.1 & 2 GTFLA]…
 Basic Considerations (continued…):
 Multi-Functional Additives Examples:
continued…
Additive
Possible Functions
Ascorbic Acid
Preservative, dough conditioner, nutrient
Acetic Acid
Preservative, pH adjusting agent
Citric Acid
Preservative, culture nutrient, pH adjusting agent ,
sequestering agent
Lecithin
Preservative, emulsifier, release agent
Tartaric Acid
Preservative, pH adjusting agent
No Preservatives Claims [4.3.1 & 2 GTFLA]…
 Basic Considerations (continued…):
 Multi-Functional Additives Labelling: When a no
preservative claim is made for a multi functional additive
that has been added to the food for a function other than
a preservative, the claim may be made if the function of
the additive is clearly identified in the list of ingredients.
Excerpt
4.3.1
GTFLA
continued…
No MSG Claims [4.3.3 GTFLA]…
 General: Claims such as "contains no MSG", "no
MSG. added" and "no added MSG" are permitted
where the food does not contain MSG or other
sources of free glutamates.
 Basic Considerations:
 MSG: The acronym “MSG” is suitable when used
outside a list of ingredients. Within a list of ingredients
the additive, when present, is declared as “monosodium
glutamate”.
 Sources of Glutamates: While it may be factual to state
that a food does not contain added MSG, it is considered
misleading when free glutamates are present.
continued…
No MSG Claims [4.3.3 GTFLA]…
 Basic Considerations [continued…]:
 Example Sources of Glutamates other than MSG:
Ingredients that are sources of free glutamates
Foods with naturally occurring free glutamates
hydrolysed vegetable protein
Tomatoes and tomato juice
soya sauce and fermented soy products
grapes and grape juice
autolysed yeast extracts
other fruit juices
sodium caseinate
cheeses (e.g. Parmesan and Roquefort)
mushrooms
continued…
Pure Claim [4.10 GTFLA]…
 General: Claims to the effect that a product is
“pure” or “100% pure” is generally limited to foods
or ingredients that are not compounds or
mixtures, or to those in which substances or
ingredients are understood to be part of the food,
(e.g. milk chocolate).
 Basic Considerations:
 Food vs Ingredients: Pure claims can relate to a food or
an ingredients thereof. In the case of a claim related to
an ingredient, the food itself may not be pure, but the
ingredients may be.
continued…
Pure Claim [4.10 GTFLA]…
 Basic Considerations [continued…]:
continued…
 Highlighting of Ingredients : When highlighting pure
ingredients the claim could also be subject to CFIA’s
guidelines on highlighting of ingredients.
 Context Sensitive: Pure claims can be context sensitive.
For example a sausage is a multi-ingredient food. It is
misleading to refer to a sausage as “pure”. It is however
OK to state “100 pure beef sausage” where the sausage
is made exclusively with meat from beef.
In the case of a reconstituted juice beverage it would not
be appropriate to describe it as “pure” where it contains
natural flavours. However, it is possible to claim that the
beverage is made with “100% pure orange juice from
concentrate” if this be the case.
Pure Claim [4.10 GTFLA]…
 Basic Considerations:
 Standardized Foods:
Pure claims can be made for certain multi-ingredient
standardized foods that do not include “may contains”.
Excerpt
Div 4 FDR
continued…
For example “pure milk chocolate”
should comply with the standard
to the extent that it does not
contain any “may contain
additives”, (e.g. emulsifying
agents, etc.), and to which the
ingredients that are used
themselves are pure, (e.g.
chocolate, milk sugar, etc.).
No Artificial Flavour…
Excerpt
Div 10
FDR
continued…
• General: This claim is subject considerations of “negative
claims” as per the GTFLA.
 Basic Considerations: To be truthful, the food
would not contain any synthetic or imitation
flavour, whether added directly to the food or
indirectly via another ingredient.
No Artificial Colour Added…
Exit
Div 6 FDR
 General: This claim is subject considerations of
“negative claims” as per the GTFLA.
 Basic Considerations: To be truthful, the food
would not contain any synthetic colour additive.
The food may however contain a natural colour,
(from natural sources).
Example: A food which contains “COLOUR (EXTRACTIVES OF
ELDERBERRY AND CHOKEBERRY)” claims “NO ARTIFICIAL
COLOUR ADDED”. Since the source of the colour is natural the
claim may be made.
continued…
Natural [4.10 GTFLA]…
 General: Natural claims, (e.g. "Nature", "natural",
"Mother Nature", "Nature's Way“), are among
some of the most difficult claims to qualify. CFIA
has expressed their criteria for such claim in
Chapter 4.7 – GTFLA. The general definition of
natural is shown below.
continued…
Natural [4.10 GTFLA]…
 Basic Considerations:
 Natural Production Claims: The claims referred to here
are not related to natural production claims for animals
or products derived from animals. Such claims have their
very own unique considerations. The use of natural
claims has additional considerations when used on a
label of a meat or poultry product.
 US FDA & USDA Natural: A food which meets FDA’s
criteria for natural or even the more stringent threshold
criteria of USDA would not automatically satisfy
Canadian guidelines.
 Food with Food Additives: The presence of a food
additive in a food precludes the use of a “natural” claim.
continued…
Natural [4.10 GTFLA]…
 Basic Considerations:
Exit 4.7
GTFLA
continued…
 Natural Food Additives & Nutrients: While the presence
of a food additive precludes a ‘natural’ claim, it may be
possible to state the food contains or is made with
“natural ingredients”, where the food additive or nutrient
is derived from natural sources.
 Processing Considerations: A natural claim can be made
for a food or its ingredients that are minimally processed.
However, where the processing affects the natural
character of the food, the claim may not be made. To
this extent CFIA has provided guidance in the GTFLA.
Natural [4.10 GTFLA]…
 Basic Considerations [continued…]:
continued…
 Natural Flavour: Where the flavour is derived from natural
sources the food may be claimed to contain “natural
flavour”. Where natural flavours contain food additives,
including extraction solvents, the food to which the flavour is
added to may not be claimed as “natural”. Also, it may not
be claimed to contain “natural ingredients”, unless all food
additives in the flavour are derived form natural sources.
 Complex Flavours: Enzymatic flavours, reaction
flavours, processed flavours or nature-identical flavours
have not been generally established as “natural”. These
are reviewed by CFIA on a case-by-case basis. Nature
identical flavours are typically synthetic. Some enzyme
modified cheese flavours could be natural flavours.