Health Claims

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Diet-related health claims

(Naming the food) Health Claims

Type size requirements

Health claims grouped with nutrient content claims

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Diet-related health claims on pickles

Q1. Would the health claim "A healthy diet rich in a variety of vegetables and fruit may help reduce the risk of some types of cancer" be acceptable on pickles?

Pickles do not qualify for the health claim as they are condiment type vegetables [item 4(b)(ii)], which are excluded from carrying the claim. (Note: They are included in the Processed Products Regulations along with relishes and chutneys).

(Naming the Food) Health Claims

Q1. What is considered to be appropriate for use in the description of the food in the "Naming the Food" part of certain diet related health claims prescribed in the table following B.01.603 in the Food and Drug Regulations (FDR)?

"Naming the food" requires, at a minimum, the common name of the food. If the nutrient content claim portion of the health claim does not apply to all foods of that type, then a brand name may accompany the common name. If other information is required to distinguish the food from another similar food with the same common name and brand name, other information may be permitted as part of the description of the food.

For example "A healthy diet low in saturated and trans fat may reduce the risk of heart disease. Johnny's 100% fat-free turkey breast is free of saturated and trans fat" to distinguish the food from Johnny's regular turkey breast with 4% fat.

If the nutrient content claim portion describes all foods of that type, then "Naming the food" must be stated in such a way as to indicate that the claim characterizes all foods of that type. A brand name may not be used to name the food. This is consistent with the requirements set out in section B.01.511, FDR.

For example, "A healthy diet low in saturated and trans fat may reduce the risk of heart disease. Applesauce is free of saturated and trans fats."

It is not appropriate to use a brand name or trade name only to name the food. For example, the use of a brand name only in the following claim would not be acceptable as the brand name does not name the food. "A healthy diet low in saturated and trans fat may reduce the risk of heart disease. Johnny's is free of saturated and trans fat." (February 2005)

Type size requirements for diet-related health claims

Q1. There seems to be no regulation that requires all the elements of a health claim to appear in the same size and prominence on a label or in an advertisement.

The omission of this requirement was an oversight when the regulations were published. Health Canada has proposed a regulatory amendment to require that all of the words of the health claim be the same size and prominence (Canada Gazette, Part I, Schedule 1416, (Volume 139, No. 19)). At this time the CFIA encourages all parties to show all elements of the diet-related health claim in the same size and prominence.

Health claims and nutrient content claims together

Q1. Can a health claim that includes a nutrient content claim be followed by an additional nutrient content claim? (e.g., "naming the food is low in cholesterol.")

Yes, it can follow the claim if there is no change in the intent or nature of either the diet-related health claim or the nutrient content claim. The full common name of the food must be used. However, this claim may not be interposed within the prescribed wording of the health claim.