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Canada Moving Forward on Front-of-Pack Labeling

  • Pursuant to its mandate under the Food and Drugs Act, Health Canada is responsible for setting safety and nutritional quality standards for all foods sold in Canada.  Health Canada achieves this goal by setting standards under the Food and Drug Regulations which are enforced by the Canadian Food Inspection Agency.

  • On October 24, 2016, Canada’s Minister of health announced that Canada’s food labeling requirements would be revised as a part of the Healthy Eating Strategy for Canada.  This program has brought changes to labeling and disclosure requirements such as what needs to be disclosed on a food product’s label and how that information is to be conveyed (e.g. increased contrast between ingredients and background, mandatory font size requirements, etc.).

  • One of the key initiatives under the Strategy involves Front-of-Pack (FOP) labeling. Health Canada states that while existing nutrition labeling tools are very useful to many consumers when making food purchasing decisions, some consumers find the information provided too complex to understand and use. To help address this, Health Canada is proposing to introduce FOP labeling requirements on prepackaged foods high in sodium, sugars and saturated fat.   The objectives of FOP labeling are to:

    • Provide quick and easy guidance to encourage consumers to make informed choices about foods in relation to sodium, sugars and saturated fat; and

    • Encourage the availability of foods lower in these nutrients, thereby reducing risks to health.

  • November 22, 2017 USDA FAS GAINS Report indicates that Canada has moved on to the next step of implementing a new mandate that will require food manufacturers to use FOP symbols to warn consumers about high levels of sugars, sodium or saturated fat with the label design process slated to be well under way shortly (bidding on a graphic design contract for the labels just closed in October).  Health Canada is planning to implement FOP labeling requirements in 2021, alongside previously approved changes to nutritional labeling.

  • It remains to be seen how the new requirements will mesh with the widely accepted Facts Up Front voluntary labeling initiative spearheaded by the Grocery Manufacturing Association (GMA) and the Food Manufacturing Institute (FMI).

© 2017 Keller and Heckman LLP

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Keller and Heckman offers global food and drug services to its clients. Our comprehensive and extensive food and drug practice is one of the largest in the world. We promote, protect, and defend products made by the spectrum of industries regulated by the U.S. Food and Drug Administration (FDA), the European Commission and Member States authorities in the European Union (EU) and similar authorities throughout the world. The products we help get to market include foods, pharmaceuticals, medical devices, veterinary products, dietary supplements, and cosmetics. In addition...

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