Upcoming Front of Package Label Regulations

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Upcoming Front of Package Label Regulations

What’s going on?

Major changes are coming to the Canadian food industry. There is a rising global epidemic of chronic diseases known as non-communicable diseases (NCDs) which kill 38 million people a year according to the World Health Organization (WHO) and are the leading cause of premature death and disability. Though there are genetic and environmental factors which are can be causal factors in developing these diseases, many risk factors are modifiable. Most NCDs are caused by tobacco use, harmful use of alcohol, physical inactivity, and unhealthy diet, all of which are modifiable behaviours. At the United Nations General Assembly High-Level Meeting on the Prevention and Control of Non-Communicable Diseases in 2011, heads of state and governments committed to an action plan to develop policies to address the issues of NCDs. After all, NCDs do not only affect individuals with the disease, but they also reduce global and national economic output, strain health systems, and can drive households and individuals into poverty. They are a greater threat to the global economy than fiscal crises, natural disasters, and pandemic influenza.  

The Canadian Government is in the process of adopting policies to promote healthy diets in consumers by promoting a reduction in sodium, eliminating trans fats, and limiting the marketing of unhealthy food and beverages to children. One of the major changes coming is new Front of Package labelling requirements.

Front of Package Labelling Requirements

The front of package is the first point of interaction between the consumer and the food product. The hope is that by presenting relevant information regarding the contents of pre-packaged foods in a way that is easy to understand, consumers will be able to make informed decisions about their food choices.

According to the Canada Gazette “the proposed thresholds for prepackaged products would align with 15% of the Daily Value (DV) for each nutrient of concern, based on the reference amount for the food or the serving of stated size that appears in the Nutrition Facts table, whichever is greater, or per 50 g for foods that have a serving of stated size and reference amount less than 50 g and that contain at least 5% of the DV of the nutrient of concern per reference amount or serving of stated size, whichever is greater.” Packages for products that meet or exceed these thresholds for the nutrient of concern will be required to display a symbol indicating this to the consumer.

A standardized family of symbols have been developed to clearly inform consumers if a product meets or exceeds prescribed thresholds for sodium, sugar, and/or saturated fats.  The symbols will be required to be displayed on the top 25% of the package to ensure easy visibility. The sizing of these symbols is will be proportionate to the package. For small packages, an alternative symbol has been created to ensure maximum clarity even at small sizes. There will be a minimum buffer zone around the symbols, and any other nutritional or health claims are not to be placed in the proximity of the symbols so as not to distract from their message. Additionally, imitation symbols are also prohibited, again, to prevent distraction. In other words, the symbols must be clear, visible, and unobstructed so that the consumer is immediately aware that the product they are looking at is high in these nutrients

Some products will be conditionally or fully exempt from these rules.  

Conditionally Exempt: 

  • Alcohol- to avoid giving the impression that there is any positive nutritional benefit 
  • Raw single meat ingredients, meat by-products, poultry, poultry by-products that are not ground, or raw single ingredient marine and freshwater animal products 
  • Products prepared and processed with ingredients at a retail location including from a pre-mix if an ingredient other than water is added. This is due to difficulties labelling food prepped with limited standardization and to avoid having a negative impact on small businesses. 
  • Products sold only at roadside, craft show, flea market, fair, farmers market, or sugar bush by the person who prepared and processed the product. This is to alleviate the negative impact of the symbols on small businesses.  
  • Products sold only in the retail establishment where packaged if labelled by means of a sticker and on the display surface is less than 200cm2. This is due to space constraints and technical limitations negative impact of retail scale labels for printing and to alleviate the symbols on small businesses. 
  • Products with an available display surface of less than 100cmdue to space constraints. 

Fully Exempt: 

  • Fresh, frozen, or canned vegetables and fruits without any added ingredients except water and approved food additives. These are a staple of a healthy, balanced diet.  
  • Products with an available display surface of less than 15cm2 because the package is too small to display these symbols in a way that clearly communicates their message.  
  • Individual portions of food that are solely intended to be served by a restaurant or other commercial enterprises with meals or snacks as packages are generally too small for the symbol.  
  • Cow or goats milk products sold in refillable glass containers. This is because the available labelling space is limited to the lid. Additionally, this aims to alleviate the impact on small businesses.  
  • Non-flavoured whole and partially skimmed milk obtained from any animal in liquid or powder form. Whole milk because it is recommended as the main milk source if an older infant is no longer breastfed. 2% milk is exempt because it is recommended in the Canadian Dietary Guidance. Skim milk and 1% milk do not need to be exempt because they would not meet the threshold of “high in saturated fat” symbol. 
  • Whole eggs (fresh, liquid, frozen, or powdered). 
  • Sweetening agents such as sugar, honey, syrups, molasses. These products are mostly or all sugars and are used by consumers for sweetening purposes. It would thus be redundant to label these as high in sugar. 
  • Salt for general household use including celery salt, garlic salt, and onion salt. It would be redundant to label salt as high in sodium. 
  • Individual rations for military use as the symbol would discourage this population from eating their rations that have been formulated specifically for their needs. 
  • Any foods used for special dietary use such as formulated liquid diets, foods represented for use in a very low energy diet, human milk substitutes, and foods represented as a human milk substitute. These are formulated specifically in the FDR to fulfil the nutritional needs of vulnerable groups. Thus, it could potentially be very damaging to include these labels on these products.  

Solutions

While these changes aim to aid consumers in making healthy choices that will benefit them in the long term, they also create some significant challenges within the industry as formulators begin to search for alternatives to salt, sugar and trans fats to keep their products tasting delicious, without compromising consumer health. Currently, these proposed policy changes are live for consultations on the Canadian Gazette and will be until April 26th. Results of these consultations will be shared later in 2018 and are anticipated to come into effect very soon after.  

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2018-04-10T11:51:10+00:00