For many years, significant changes to Canadian food labelling requirements have been discussed. The discussion has centered on streamlining food labelling requirements and ensuring that the requirements meet the growing consumer awareness of the importance of, and information to be found on, food labels and increased consumer knowledge surrounding daily nutritional needs. These discussions have been supported by educational initiatives – by governments, industry and industry groups – promoting the review and assessment of food labels as part of the consumer purchasing process and food choice decisions.
Five regulatory consultation initiatives were announced by Health Canada in the summer of 2014; the consultation process has now ended. The initiatives all originated from the Bureau of Nutritional Sciences within the Food Directorate of Health Canada’s Health Products and Food Branch (although Health Canada and the Canadian Food Inspection Agency work closely on such initiatives). The consultations were based on five key labelling initiatives.
Display of nutrition and other information on food labels
The proposed changes to the formal technical requirements for the disclosure of nutrition information on Canadian food labels focus on increasing the prominence of the reference to calories in the Canadian nutrition facts table; grouping certain nutrients together for greater clarity; explaining the reference to daily values on nutrition facts tables; declaring amounts of vitamins and minerals in foods by weight; standardising the format and improving the legibility of ingredient lists (historically an issue of concern for regulators); and providing for the addition of a box for (optional) information on the bioactive components added to foods.
The proposed changes are designed to facilitate a consumer’s review of the nutrition facts table and to ensure that important information (calories, serving size, etc.) stands out and catches a consumer’s eye. The emphasis on calories is intended to make it easier for consumers to monitor their daily caloric intake (with the ultimate goal of helping consumers to limit their consumption of excess calories).
The proposal also focuses on the grouping of ‘nutrients of public health concern’ – essentially requiring nutrients to be grouped together where the possibility of excessive intake is a common concern. These nutrients would include fat, saturated fat, trans fat, sodium and sugars. ‘Nutrients of concern’ would be grouped higher on the nutrition facts table and placed separately from nutrients such as fibre, vitamins and minerals – where the concern relates not to ‘over’ but rather ‘under’ consumption by Canadians.
One of the changes that has received significant comment has been the proposal to require information on the amount of ‘added sugars’ in the food product and/or adding a per cent daily value reference to ‘total sugars’ on the food label. This change is intended to allow Canadian consumers to identify whether (or not) there is a large amount of added sugar in a food product.
The proposed changes include presenting ingredients differently on product packaging. While ingredients must already be listed in descending order of presence in the food (by weight), there are no current regulations around type height (other than minimum type height). Small or difficult-to-read lettering and poor colour contrast are two issues of concern to Health Canada. The proposal would require a consistent format across all ingredient listing – including an ingredient box, black print on a white (or neutral) background, and font type and size requirements. Allergen labelling statements, when required, would have to be included in the ingredient box.
Finally, the proposal considers the development of a voluntary information box to highlight additional information concerning product ingredients. This voluntary information box would be subject to the same, or similar, labelling requirements (focusing on clarity and ease of access to information).
All in all, the proposal, if implemented as proposed, would require the reconstruction of virtually every food label in Canada.
Declaration of core nutrients in the Canadian nutrition facts table
The second labelling initiative would require micronutrients – some of which raise a public health concern associated with inadequate intake – to be listed on Canadian nutrition facts tables for prepackaged foods. The Canadian proposal is consistent with a similar proposal in the United States.
Under the proposal, vitamin D and potassium would be added to the micronutrients that are subject to mandatory declaration, vitamins A and C would be removed from the mandatory declaration and the requirements for calcium and iron to be included in the nutrition facts table would be retained. As with the proposal on the display of nutrition information on labels, this initiative would require greater disclosure of added sugars and total sugars, and it would require all sugars to be grouped together under one ingredient. Health Canada would also establish a daily value for total sugars which would, in turn, provide information concerning the amount of total sugar in a serving size of food as a percentage of the total daily value of sugar. Combined with the requirement to group all sugars together, this proposal would provide an ‘at a glance’ resource for sugar disclosure.
Changes to the daily values for use in nutrition labelling
Health Canada has outlined a number of changes to the reference values used to calculate the percent daily value for certain nutrients. These are similar to recent changes proposed in the United States (and provide further evidence of harmonisation efforts in food labelling).
Under the proposal, Health Canada would continue to use a population coverage approach to set daily values for vitamins and minerals. However, instead of basing the analysis on a population two years of age and older (as is currently the case), the values would be set based on a population four years of age and older. Two additional daily value classification levels would be created – one for infants (6 to 12 months) and a second for toddlers (1–3 years) – to reflect the different eating patterns of these two groups.
The proposal references specific changes that would be made in connection with certain nutrients of public health concern (such as fat, saturated fat, trans fat and sugars). Sodium is also included as a nutrient of public health concern; Health Canada proposes that the reference limit be reduced from the current daily value of 2400mg to an upper limit of 2300mg per day.
Serving size guidance
Health Canada proposes standardised label serving sizes using reference amounts. At the moment, food labels reflect a common household measure (number of slices, number of crackers, and so on) and a metric measure (grams, etc.). The common household measure would appear first followed by the metric measure in parenthesis. The proposal includes three new guidelines for the calculation of serving size.
Revisions to reference amounts
The final label initiative relates to revisions to upgrading reference amounts for the purpose of calculating serving sizes on nutrition facts tables. The theory behind setting reference amounts is that that amount would represent the amount of food typically eaten at one sitting. (One of the goals for this proposal is to ensure that the reference amounts are comprehensive and actually do reflect the amount of food that a Canadian would eat at one sitting – ice cream, for example, was cited in the proposal as one of the foods for which the reference amount does not currently reflect the higher volume typically consumed in one sitting.)
Several policy threads run through all of the five consultations. All of the consultations reflect an effort to act in a coordinated fashion with foodlabelling initiatives being undertaken in the US. The consultations demonstrate a regulatory priority to ensure not only that food labels are readily understood by consumers when they make purchasing decisions, but also that nutrients of public health concern are grouped in such a manner as to enable consumers to have ready access to consumption information. This in turn allows consumers to monitor caloric consumption more closely and to monitor their consumption of fats, sugars, sodium and other key components of concern. Finally, all the consultations reflect a modernization goal – ensuring that serving size reference amounts reflect current consumption patterns, that upper limits for vitamins and minerals reflect current scientific data and that nutrients of public health concern are considered in the context of Canada’s food labelling requirements.