Canadian Food Inspection Agency
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Decisions: Name and Address
Name and Address - Numerical Code as an Address
Question: Is it acceptable to use a numerical code to express the address of the person taking responsibility for the product?
Answer: No, a numerical code is not an acceptable means of expressing the address of the person taking responsibility for the product. For example, a French postal code in the example "P. Bureaux & Fils, Négociants à 12345 (France)" does not meet the requirements for the "identity and principal place of business" under section 10 (b) (i) of the Consumer Packaging and Labelling Act or section B.01.007 (1.1)(a) of the Food and Drug Regulations. A street or mailing address, such as a post office box, and/or a locality such as a city, town or village must replace "12345" in the example.
Name and Address - Obsolete name and Address
Question: When a legal agent purchases a business, is the new administrator allowed to use up all of the old labels bearing an obsolete name and address?
Answer: The company name declared on labels denotes responsibility and liability for a product. The principal place of business (address) declaration provides the location where a company can be contacted if there are problems. Taking these principles into consideration in the following situations, one of the following actions may be considered:
1. Company Changes Address
(A) Company and City Remain Same - Postal Code
Changes
In general, there is no objection to a company taking some time to get new
labels when it moves within a city if its company name remains the same but the
postal code changes, provided the company is listed in the current telephone
book under the same name as the one declared on the label. This would make the
company easily traceable.
(B) Company Remains The Same - City and Postal Code
Change
In general, we would not object to a company using labels with an obsolete
address for the time period covered by the company's mail-forwarding
instructions at the post office.
(C) Company Sold
( i ) In general, when Company A is sold to Company B, we would not object
to Company B using
Company A's old labels with Company A's valid
address provided there is a signed letter of
agreement between Company A and Company B to the effect
that:
- (I) Company A agrees to let Company B use its old labels and
- (II) Company B will take responsibility for a specified period of time for
all products packed
- under Company A's old labels.
- ( ii ) When Company A is sold to Company B and becomes a subsidiary of
Company B, no label
- change is needed provided the
subsidiary continues to use Company A's original name, the
- subsidiary continues to do business at Company
A's old address and the
- subsidiary uses Company A's brand name.
- ( iii ) When Company A sells a brand name (not its company) to Company B,
and Company B does
- business under Company B's name and address, new labels are required.
2. Company in Process of Going
Out-of-Business
When a company is in the process of going out-of-business, we do not, in
general, object to the use of existing labels during the transition period when
the company's business is winding-down. In the Processed Products
Regulations re-write, it is proposed that the plant registration be transferred
to the receivers for the time period required to wind-down a company's
business.
3. Company Gone Out-of-Business
When a company has gone out-of-business, the company's old labels are not
acceptable for use by any company.
4. Existing Products Already Sold To Distributors With Old
Labels
In general, we do not object to the labels that are on products which have
already been sold to distributors provided the information on them was true
when the products were packed.
