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Canada proposes FOP labeling to identify nutrients of public health concern

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Source: Verisk 3E

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Health Canada issued on 10 February 2018 a proposed rule to require front-of-package (FOP) labeling of prepackaged products under the Food and Drugs Regulations (FDR). Specifically, the Ministry recommends products to bear a nutrition symbol on the principal display panel (PDP) that indicates that the food product is high in one or more nutrient of public health concern, e.g., sodium, saturated fats and/or sugars. The labeling requirement would be triggered by the presence of the nutrient at or above a given threshold. The proposal also addresses fortification levels of milk, goat’s milk and margarine through augmented vitamin D content; and the prohibition of food products containing partially hydrogenated oils (PHOs). Lastly, the Ministry is also proposing to repeal additional labeling requirements for high-intensity sweeteners, e.g. aspartame, sucralose, acesulfame-potasium and neotame. New requirements would be implemented by 14 December 2022, which coincides with the end of the transition period of general nutrition labeling regulations. Comments are due on 26 April 2018.
                    
Verisk 3E Review
Products under scope are prepackaged meals. The proposal defines “prepackaged meals” as “a single-serving prepackaged product that requires no preparation other than heating.”
 
Highlights of the FOP Nutrition Symbol
 
Canada is proposing to adopt a mandatory “high-in” system for the three nutrients identified as a health concern, e.g. sodium, saturated fats and sugars. The system would require foods high in one or more of the three nutrients of concern to bear the nutrition symbol on the PDP. Projected threshold values for the nutrients of concern are:
  • Total sugars:
    • 15% of the daily value (DV) for prepackaged products intended solely for children one year of age or older but less than four years of age;
    • 15% of the DV for all other prepackaged products;
    • 30% of the DV for prepackaged meals and main dishes with a serving size of 200 grams (g) or more, combined with the adjustment for foods with small reference amounts;
  • Total saturated fats:
    • 15% of the daily value (DV) for prepackaged products intended solely for children one year of age or older but less than four years of age;
    • 15% of the DV for all other prepackaged products;
    • 30% of the DV for prepackaged meals and main dishes with a serving size of 200 grams (g) or more, combined with the adjustment for foods with small reference amounts;
  • Total sodium:
    • 15% of the daily value (DV) for prepackaged products intended solely for children one year of age or older but less than four years of age;
    • 15% of the DV for all other prepackaged products;
    • 30% of the DV for prepackaged meals and main dishes with a serving size of 200 grams (g) or more, combined with the adjustment for foods with small reference amounts;
Please refer to Part 1 of the “Table of Daily Values” here.
 
Presentation of the Nutrition Symbol
 
The symbol must be presented with one or more words that indicate the prepackaged product is high in saturated fats, sodium or sugars; and an attribution of message to Health Canada, all surrounded by a solid-line border. Language requirements are also proposed and must be presented using either the standard format (e.g., two separate versions, one in English and one in French) or the bilingual standard format (e.g., words on the symbol are in both official languages, where the order of the languages may be reversed as prescribed by the FDR). Nutrition symbol content must be readable from left to right and parallel to the base of the package. Location of, and restrictions to, the nutrition symbol are also in place.
 
Exemptions to the Nutrition Symbol Requirement
 
The following prepackaged products would be exempted from the nutrition symbol requirement:
  • Fresh, frozen or canned vegetable or fruit, or a combination of these;
  • Products with a display surface of less than 15 squared centimeters;
  • Food portions solely intended to be serve at commercial enterprises;
  • Milk, partly skimmed milk, skim milk, goat’s milk, partly skimmed goat’s milk, skimmed goat’s milk, (naming the flavor) milk, (naming the flavor) partly skimmed milk, (naming the flavor) skim milk or cream sold in a refillable glass container;
  • Non-flavored whole and partly skimmed milk, obtained from any animal in liquid or powder form;
  • Whole eggs, fresh or in liquid, frozen or dried form;
  • Sweetening agents, including maple sugar and maple syrup;
  • Salt for table or general household use, celery salt, garlic salt and onion salt;
  • Individual rations for use in military operations; and
  • Products intended solely for infants less than one year of age, a formulated liquid diet, a human milk substitute, a food represented as containing a human milk substitute or a food represented for use in a very low energy diet.
The following prepackaged products would be exempted if they do not carry a nutrition facts table:
  • Beverage with an alcohol content exceeding 0.5%;
  • Raw single ingredient meat, meat by-product, poultry meat or poultry meat by-product that is not ground;
  • Raw single ingredient marine or fresh water animal product;
  • Product sold only in the retail establishment where it is prepared and processed from its ingredients, including from a pre-mix if an ingredient other than water is added to the pre-mix during the preparation and processing of the product;
  • Product sold only at a road-side stand, craft show, flea market, fair, farmers’ market or sugar bush by the individual who prepared and processed the product;
  • Individual serving that is sold for immediate consumption and that has not been subjected to a process to extend its durable life, including special packaging;
  • Product sold only in the retail establishment where it is packaged, if it is labeled by means of a sticker and has an available display surface of less than 200 square centimeters; and
  • Product with an available display surface of less than a 100 square centimeters.
Comparative Analysis: U.S. and Canada
 
Commonality is often observed among U.S. and Canadian regulations. Yet, food labels on prepackaged products are unique in Canada. For instance, Canada requires dual language labeling and the use of the metric system.
 
With the proposal on FOP labeling, Canada resumes uniqueness to its nutrition labeling system, since only a handful of countries have adopted mandatory or voluntary FOP labeling. Notable FOP nutrition symbol schemes have been observed for the United Kingdom, Australia, New Zealand, France, Chile, Ecuador and Mexico. The U.S. has yet to provide an equivalent requirement for foods containing nutrients of public health concern.
 
Other Notable Revisions
 
The Ministry is also revising the FDR with the intent of incorporating by reference the “Table of Permitted Nutrient Content Statements and Claims” and Part 1 of the “List of Contaminants and Other Adulterating Substances in Foods.” As a result of the latter, the Ministry is moved to remove references to partially hydrogenated oils (PHOs) from the FDR as these are now referenced in the “List of Contaminants and Other Adulterating Substances in Foods.”
 
Verisk 3E Analysis
 
Health Canada will transition into full implementation of the nutrition symbol requirements by 14 December 2022.
 
Comments are due by 26 April 2018, and must cite the Canada Gazette, Part I, and the date of the publication of the proposed rule. Comments may be submitted by email to LRM_MLR_consultations@hc-sc.gc.ca or mailed to Mr. Bruno Rodriguez, Director, Office of Legislative and Regulatory Modernization, Health Canada, 11 Holland Avenue, suite 14, Ottawa, Ontario, K1A 0K9.

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