available here - Canadian Health Food Association

December 3, 2014
Cost-Benefit Analysis Survey for Nutrition Labelling
In accordance with the requirements found in the Cabinet Directive on Regulatory Management, the “One-forOne” Rule, and the Small Business Lens, Health Canada is required to assess the costs and benefits of all regulatory
proposals. The purpose of the attached survey is to obtain quantifiable data for the Cost-Benefit component of the
Regulatory Impact Analysis Statement that will be written in support of the proposed changes to the food
regulations with respect to the presentation of the Nutrition Facts table and ingredients list. For this reason, please
be as specific as possible about what you believe the costs and/or benefits would be in response to each part of
the survey.
We ask that the survey be returned no later than December 24, 2014.
Thank you.
Scope of the Market:
What food industry or industries is your company involved in?
What is the total number of SKUs produced by your company? Please only include items that require a
Nutrition Facts table and ingredient list in accordance with the Food and Drug Regulations.
A Small Business is defined as “Any business, including its affiliates, which has fewer than 100 employees or
generates between $30,000 and $5 million in annual gross revenue.”
Does your company meet the Canadian government’s definition of a Small Business? (Yes/No)
In which province/territory are you located?
For Industry Groups:
Please provide the name of your organisation: __________________________.
How many companies and producers does your organisation represent?
What approximate percentage of the total number of companies and producers in your food industry is
represented by your organisation?
Label Costs:
Please consider what your company currently spends on labelling to comply with the CURRENT Food and Drug
On a per average SKU basis, what does your company CURRENTLY spend during a normal label life-cycle on:
Ingredient Plates:
Nutrient Analysis:
Label Materials:
Software Updates/Upgrades:
Graphic Design:
What is the average total cost of nutrition and ingredient labelling per SKU?
10. What is the current life-cycle of your product labels? In other words, how often does your company change
label designs outside of regulatory amendments within the Canadian market?
Synthetic Colour Certification:
11. Does your company submit synthetic food colours for certification to Health Canada? This question refers to
provisions within the Food and Drug Regulations which stipulate that all synthetic colour lots must be certified
by Health Canada officials.
12. Who in your company (i.e. their position) is involved in the certification of synthetic colours used in food
products? Please provide their estimated salary and number of FTEs.
13. How often does your company send out synthetic colour lots to be certified by Health Canada?
14. What is the time delay between submitting a lot for certification and receiving a response/approval from
Health Canada?
15. Are there any other costs associated with the certification of synthetic food colours? If yes, please list and
describe them.
Impact of Proposed Regulations:
This next section of questions requires your input on how the PROPOSED changes to the Nutrition Facts table and
ingredient list labelling could affect your label costs.
Please refer to the Current (Figure 1) and Proposed (Figure 2) Nutrition Facts table as well as the existing and
proposed formatting (Figure 3) for the ingredient list below:
Figure 1. Example of the Current Nutrition Facts Table
Core list of Calories and 13
nutrients always declared
Actual amount of the nutrient in
the stated serving of the food is
listed for macronutrients and
Figure 2. Proposed Changes to the Nutrition Facts Table
The nutrient information is based on
a specified amount of food as sold
(serving size)
% Daily Value (% DV) indicates the
amount of the nutrient relative to the
Daily Value
Serving size information would be moved to the right hand side of the table.
“Amount” would be removed from the fourth row of the table thus, leading to increased space availability
to show a larger, bolded “Calories” declaration.
Fat, saturated fat, trans fat, sodium and sugars, which are nutrients of public health concern related to
excessive intake, would be positioned between the “Calories” and a thick line that separates them from
fibre and the vitamins and minerals of public health concern.
Cholesterol, carbohydrate and protein are not considered nutrients of public health concern, and along
with fibre, would not require a mandatory % DV declaration. However, these four nutrients would appear
either above (cholesterol and carbohydrate) or below (fibre and protein) the thick line.
Removal of mandatory declaration for Vitamin A and C, while including mandatory Vitamin D and
Potassium declaration in absolute amounts.
Delete the thin lines between fat and saturated / trans, as well as between carbohydrate and sugars.
Under the current regulations, only the % DV declaration is required for the mandatory and voluntary
vitamins and minerals, with the exception of sodium and potassium that also require the declaration of
amounts by weight. Health Canada is proposing to extend this requirement to all mandatory and
voluntary vitamins and minerals.
Adding a footnote at the bottom of the Nutrition Facts table that would explain the meaning of the % DV
benchmark levels and that would read: “5% DV or less is a little; 15% DV or more is a lot”. An asterisk (*)
beside the % Daily Value title at the top of the table would refer consumers to the footnote.
Figure 3. Proposed Changes to the List of Ingredients
Thin rule outlining the space around the information to form a box; specifications for a maximum box
Bolded title “Ingredients” on its own line.
Requiring black print on a white or neutral background.
Font type and size consistent with the direction set out in the Food and Drug Regulations for the Nutrition
Facts table including the use of a capital for the first letter of each main ingredient.
Bullets to separate each main ingredient.
In addition, when a “Contains” statement is provided to further alert consumers of the presence of
priority allergens, gluten sources or added sulphites, this information would be required to be within the
ingredient box. This would also be the requirement for precautionary allergen labelling "May Contain"
Grouping all sugar-based ingredients in parentheses following the common name “sugars”, placed in the
list of ingredients based on their total relative contribution to the food.
16. Considering the proposed changes listed above, on a per average SKU basis, what is your company anticipating
to spend to comply with the regulatory changes on (you may state these costs as a total cost or as an
increment relative to your responses to Questions #8 and #9):
Ingredient Plates:
Nutrient Analysis:
Label Materials:
Software Updates/Upgrades:
Graphic Design:
17. What is your ANTICIPATED average total cost of nutrition and ingredient labelling per SKU when considering
the new, proposed nutrition labelling regulations?
18. At this time a coming-into-force period (i.e. transition period) has not been established by Health Canada.
When considering your average total anticipated cost per SKU, please describe how your costs could change
under the following scenarios:
Coming into Force Period
Total Cost per SKU
18 Months
36 Months
60 Months
Environment and Waste Considerations:
19. Does your company track or document waste due to changes in packaging at the point of manufacturing? If
no, please skip to Question #21.
20. When considering the life-cycle of your product labels and the proposed regulatory changes described above,
please describe your company’s potential waste costs under the following scenarios:
Coming into Force Period
Waste Costs
18 Months
36 Months
60 Months
Other Cost and Benefit Considerations:
21. Are there any costs that have not been addressed/considered in this survey? If yes, please list them and
provide detailed costs.
22. There a number of costs that are industry specific that may not be addressed within this survey. If you have
any industry specific costs, please list them and provide detailed costs.
23. Please provide any additional information on the anticipated benefits associated with the proposed regulatory
changes described above.