Q1. Does Canada accept the nutrition information tables of other countries on foods sold in Canada?
No, the nutrition panels of other countries are not permitted on the labels of foods sold in Canada. The use of both the Canadian Nutrition Facts table and a nutrition information table from another country together is also not permitted.
The Food and Drug Regulations set out the manner in which energy and nutrient values must be declared, as well as the presentation and requirements for nutrient content claims and health claims. Subsection 5(2) of the Food and Drugs Act prohibits labelling that is contrary to the Regulations. Since the nutrition information requirements of other countries do not match the Canadian requirements, labels and advertisements with nutrition information other than that permitted by the Food and Drug Regulations are considered to be labelled or advertised contrary to Canadian legislation.
Q1. Do restaurants that provide nutrition information for menu items need to use the Nutrition Facts format?
The nutrition labelling regulations only require a Nutrition Facts table to be applied to pre-packaged foods. As restaurant-served food is not generally considered to be pre-packaged, these requirements do not apply. If a restaurant chooses to provide nutrition information, the CFIA encourages presenting the same information that would appear in the Nutrition Facts table, including energy and the 13 core nutrients.
However, with the exception of items that accompany meals such as salad dressings, crackers, creamers, etc. and pre-packaged individual servings that have not been subjected to a process to extend their durable life, pre-packaged foods sold in restaurants must carry a Nutrition Facts table in accordance with the requirements of the Food and Drug Regulations.
Q2. Do restaurants that also sell some of their products to take home need to show a Nutrition Facts table on these products?
Foods which are clerk-served or portioned for take-out or delivery are exempted from the requirements to show a Nutrition Facts table.
Prepackaged products, such as bottled BBQ sauce and salad dressings available for purchase by customers in the restaurant are required to show an appropriate Nutrition Facts table and comply with any applicable legislation.
Q3. Are there cases where it is mandatory to provide nutrition information for menu items?
When restaurants make nutrient content claims, biological role claims or health claims about their foods, they must provide the required accompanying information for comparative claims and a quantitative declaration of the energy or nutrient value that is the subject of the claim. Further information is available in Chapters 7 and 8 of the Guide to Food Labelling and Advertising.
Q1. Are foods packaged by a retailer exempt from showing a Nutrition Facts table?
Some retail-packaged foods are exempted from displaying the Nutrition Facts table, including the following cases:
- a fresh vegetable or fruit or any combination of fresh vegetables or fruits without any added ingredients, and with or without a protective coating;
- raw single ingredient meat, meat by-products, poultry meat, or poultry meat by-products, except if ground;
- raw single ingredient marine or fresh water animal products;
- food sold only in the retail establishment where they are made from its ingredients, including from premixes if an ingredient other than water is added during the preparation and processing;
- food 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;
- an 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; and
- sold only in the retail establishment where the product is packaged, if the product is labelled by means of a sticker and has an available display surface of less than 200 cm2.
A number of retail-packaged foods are required to show a Nutrition Facts table including, but not limited to:
- foods that are repackaged from bulk by the retailer in packages with an available display surface (ADS) greater than 200 cm2, such as deli meats, cheeses, candies, nuts, cookies, imitation seafood, etc.;
- foods carrying a nutrient content claim such as reduced fat cheese, low fat ham, reduced sodium turkey breast, lean chicken breasts, etc.;
- all ground meats and poultry meats;
- foods prepared by the retailer but contain no added ingredients other than water such as pre-frozen breads which are proofed and baked on the premises, muffins made from a premix where only water is added, etc.;
- foods containing the artificial sweeteners: aspartame, acesulfame potassium and sucralose such as candies and confectionary products;
- foods repackaged from bulk with added vitamins and minerals such as flour, skim milk powder, etc.;
- packages that use nutrient content claims or health claims.
For more exemptions and when exemptions no longer apply see Section B.01.401, FDR.
Q2. Given the complexity for labelling at retail, how can retailers incorporate the Nutrition Facts label?
Different options exist for foods packaged by retailers that must show a Nutrition Facts table, including using stickers with the appropriate Nutrition Facts table obtained from suppliers of bulk items (cold cuts, cheese, candies, etc.). Another option to explore includes on-site scale labels generating stickers with the appropriate Nutrition Facts table. Specific Nutrition Facts figures have been prescribed for foods packed at retail with an available display surface of 200 cm2 or more. In these cases, a bilingual standard format [Figure 3.3(B)] or, when appropriate, a bilingual simplified standard format [Figure 6.3(B)] must be used, as a minimum, to display the Nutrition Facts table. See B.01.454(5), and B.01.455(4),F DR for more information.
Q3. Does the Nutrition Facts table need to be displayed in both English and French on foods packaged at retail?
Certain exemptions from bilingual labelling exist for local foods sold within a local area in which one of the official languages is the mother tongue of less than 10% of the residents (B.01.012, FDR; section 6, Consumer Packaging and Labelling Regulations). If you are unsure whether this applies to your retail location, you can contact the nearest CFIA office to you. In areas that have been designated as bilingual (English and French), the Nutrition Facts must appear in both English and French.
Q1. Does the nutrition information have to appear in English and French on a food label?
Yes, the information in the Nutrition Facts table is mandatory information and is required to be shown in both official languages (English and French), unless the product is otherwise exempt from the bilingual labelling requirements under section B.01.012(2) of the Food and Drug Regulations.
B.01.450(6) & B.01.451 - Other Languages in the Nutrition Facts Table
Q1. Are other languages permitted in the Nutrition Facts table in addition to English and French?
The format and presentation of the Nutrition Facts table is specifically prescribed in Schedule L of the Food and Drug Regulations and there is no provision for the use of other languages within the table.
Although other languages are not permitted within the Nutrition Facts table, they could appear separately outside the Nutrition Facts table, provided the Nutrition Facts table is already shown in English and French on the label and the information does not violate the Food and Drugs Act and Regulations, the Consumer Packaging and Labelling Act and Regulations, or any other federal legislation.
For more information see Chapter 2 - Basic Labelling Requirements of the Guide to Food labelling and Advertising
Q1. How should the nutrient values for the Nutrition Facts table be determined?
It is the company's responsibility to ensure that the nutrient values presented in the Nutrition Facts table are accurate. There are different ways to generate these values including the use of validated analytical methods by in-house or accredited laboratories or calculation by using credible databases or software. Lab analysis is generally the most accurate method of determining the nutritional profile of a given food, however, calculation may also be used if the manufacturer is confident that the results are accurate. The manufacturer must take into account various factors when choosing how to determine the nutrition values including the nature of the food, possible processing losses, seasonal variations, geographical variations, variable formulations, and so forth. The manufacturer should choose the risk management strategy best suited to the foods to be labelled.
Q2. When rounding the data to be shown in the Nutrition Facts table, what rules apply?
Specific, detailed rounding rules for the absolute values and values expressed as % DV are found in column 4 of the tables to Sections B.01.401 (core values) and B.01.402 (triggered and optional values). Rounding should use the following guidelines:
- where the first number discarded is less than 5, the last digit retained should not be changed, e.g. 4.3 rounded to 4.
- where the first number discarded is more than 5, the last digit retained should be increased by 1, e.g. 4.7 rounded to 5.
- rounding a given number in more than one stage by the above rules may lead to error therefore it is recommended that rounding be done in one step, e.g. 12.51 rounded to 13.
Q3. How should the values for cholesterol be rounded?
The table to Section B.01.401 lists how to round the values in column 4. The rounding for cholesterol may not be clear and the following interpretation should be used:
- if the product meets the conditions set out in column 2 of item 27 in the table following B.01.513 for "free of cholesterol" round to 0 mg.
- if the amount of cholesterol is 2.49 mg or less, round to 0 mg.
- in all other cases, to the nearest multiple of 5 mg.
Q4. Should the energy value be calculated using the declared values (rounded) of protein, fat and carbohydrates, multiplying them by Atwater factors of 4, 9, 4 respectively and rounding off the total value obtained according to the rounding rules for Calories?
It is the manufacturer's responsibility to ensure that the declared energy value accurately reflects the energy content of the product. Although one option is to determine the energy value directly through analysis, manufacturers may calculate the energy value either by the actual (unrounded) nutrient content value for protein, fat and carbohydrate or the declared (rounded) values for these nutrients and then multiply them by the Atwater factors [see Table 6-8 of the Guide to Food Labelling and Advertising]. When deciding whether to use the un-rounded or rounded value, the manufacturer should consider the amount of energy that will fall within the acceptable tolerances, provide the greatest consistency on the food label, and prevent any unnecessary consumer confusion. The CFIA will be calculating the energy value of a food using un-rounded nutrient content values of protein, fat and carbohydrates as determined by laboratory testing.
Q5. Should the % Daily Value (DV) be calculated using the declared values (rounded) for each nutrient or the actual absolute amount before rounding for the Nutrition Facts table?
It is the manufacturer's responsibility to ensure that the declared nutrient value accurately reflects the nutrient content of the product. If the manufacturer wishes to calculate the % DV on rounded values then they can do so. When deciding whether to use the unrounded or rounded values, the manufacturer should consider the % Daily Value that will fall within the acceptable tolerances, provide the greatest consistency on the food label, and prevent any unnecessary consumer confusion.
Q6. If a product contains an un-rounded carbohydrate value of 0.483 g, is this value declared on the panel as 0 or 1?
Without knowing the variability of the lot, it is hard to provide a definitive answer. However, assuming lot variability has been taken into account and that this value accurately reflects the nutrient content of the product, it must be expressed as "0 g" since the raw value is less than 0.5 g.
Q7. How can I find a laboratory to analyze my product?
The CFIA recommends using an in-house or accredited laboratory that uses methods that have been validated for the food you want to have analysed. A list of accredited laboratories can be accessed through the Standards Council of Canada (SCC) web site at www.scc.ca
Q8. What are the methods of analysis that should be used to determine the nutrition values for the Nutrition Facts table?
The Food and Drug Regulations do not set out which lab methods are to be used to determine the nutrition values to put into the Nutrition Facts table. The CFIA currently uses AOAC Methods, 17th Edition, 1st Supplement, however, we will use new methodology as it becomes available. In-house methods validated through collaborative studies can also be used. The methods should be validated for the foods being analysed.
Q9. Are there any database systems approved or recognized by the CFIA?
The CFIA will not be approving or recognizing any database values or systems for use in generating nutrition data on foods. Manufacturers should research the available options if they choose to use databases or calculation software and ensure that the values generated accurately reflect the nutritional profile of the food being represented. In general, some analyses are recommended to verify the accuracy of the calculations resulting from the use of a database.
It is the manufacturer's responsibility to ensure that the nutrient values presented in the Nutrition Facts table are accurate.
Table Following B.01.401 - Item 5 - Trans Fat - Naturally occurring trans fat and Conjugated Linoleic Acid
Q1. Research shows that pure meats and some dairy products contain a level of naturally occurring trans fat (conjugated linoleic acid (CLA)). Can trans fat in these foods be labelled "0" when naturally occurring?
As CLA is conjugated it does not meet the trans definition in the Food and Drug Regulations (FDR), so should not make up part of the trans declaration. Laboratory analysis can distinguish between CLA and trans as defined and so would not include the amount of CLA as part of an analysis for trans.
However, most of the trans fatty acids naturally occurring in meat and dairy products are not CLA but trans as per the FDR definition and must be declared in the NFT. As defined in section B.01.001 of the regulations, trans fatty acids are "unsaturated fatty acids that contain one or more isolated or non-conjugated double bonds in a trans-configuration". This definition does not discriminate between "industrially made" and naturally occurring trans fatty acids.
Q1. Is it essential to have the nutritional value on spice blends - if all the ingredients are only spices?
If all the information required in the Nutrition Facts table can be expressed as "0", with the exception of serving size, as per B.01.401(2)(a) of the Food and Drug Regulations, the spice blends do not require a Nutrition Facts table.
Q1. Do added hydrogenated starch hydrolysates (HSH) trigger the requirement to declare the amount of sugar alcohols in the Nutrition Facts table?
Yes, hydrogenated starch hydrolysates (HSH) are a blend of sugar alcohols and higher polysaccharides. Section B.01.402 (6) requires the amount of any added sugar alcohols to be declared in the Nutrition Facts table. Since HSH is a mixture, the amount of sugar alcohols declared would reflect the contribution from sugar alcohols in the blend.
Q1. Do individual sugar alcohols have to be listed separately in the NFT along with the grams per serving of stated size or can they be shown collectively as Sugar Alcohols with the grams per serving of stated size and be included separately in the list of ingredients?
See item 12 in the table following B.01.402. Sugar alcohols can only be listed individually by name if there is only one present. Otherwise, they must declared in the NFT as "sugar alcohols" or "polyols"
Q2. With respect to B.01.402 requiring the declaration of polyols in grams in the Nutrition Facts table, must the amount of maltitol syrup be declared, or is it sufficient to declare the maltitol and other polyol content in the syrup in grams per stated serving size? If the amount of syrup is declared, it would include the water content of the syrup.
Declaring the amount of maltitol and other polyols in the syrup is sufficient. Maltitol syrup contains water, at least 50% maltitol, and could contain other ingredients such as the sorbitol and other sugar alcohols. The total amount of maltitol or polyols present in the maltitol syrup and other sources in the food must be declared in the Nutrition Facts table as polyols. The water content of syrup would not have to be declared. Maltitol syrup must still be declared in the ingredients list. For example, if a food contains maltitol syrup consisting of water, maltitol and sorbitol, the amount of each sugar alcohol in the syrup must be declared as polyols in the Nutrition Facts table. The same applies to sorbitol syrup.
Q1. Can a declaration of "percent calories from fat" be included in the Nutrition Facts table?
"% calories from fat" is not a permitted statement in Nutrition Facts table. However, the statements "Calories from fat" or "Calories from total fat" are permitted to be shown as additional information, as permitted by FDR B.01.402.
Q1. Is it acceptable to declare the form of amino acids in the nutrition information?
Amino acids are not permitted to be listed in the Nutrition Facts table. They may be declared outside of the Nutrition Facts table. Further information on the requirements for amino acid declarations can be found in 7.15.1 of the Guide to Food Labelling and Advertising. (updated 2006)
B.01.401(6) - Simplified Format -Voluntary declarations
Q1. Can values that are 0 and aren't required to be declared be included in the simplified format? e.g.. the value for sodium in a food that qualifies for the simplified format is 0 mg and the manufacturer wants to declare this voluntarily in the table.
Yes, this is acceptable.
B.01.401(6) - Simplified Format - Saturates and Trans
Q1. When the value for one of saturates or trans is 0 but the other is not, must both be declared in the simplified format?
Yes, because the daily value for these two nutrients is linked. This clarification is part of the Canada Gazette, Part I proposed amendments to the Food and Drug Regulations.
Q1. There is a difference in size for Nutrition Facts templates found in the "Adobe" format and the "Quark Express" format. Which is correct?
The Quark Express version is what the templates in the Tool Kit are printed from, and is the version that was created using the graphic specifications set out in the regulations. The PDF (Adobe) version is for illustrative purposes (because most people can easily open these files) but the dimensions may be slightly distorted compared to the original graphics. This is explained in 5.7 of the Guide and also in the Word document that is sent out when CFIA receives requests for the templates.
Q1. Can the Dual Format - Foods Requiring Preparation be used for products "as cooked" that do not add any ingredients, such as bacon as sold and as cooked? What about a product like sardines in oil, with the dual format being used for "as sold" and "as drained"?
Yes, the dual format can be used in these situations, as per the format specifications in the Food and Drug Regulations. As there are no ingredients added, the optional footnote that says ".....(naming the ingredient for preparation) adds xx Calories, xx g fat, etc.) does not apply. The serving size for the "as prepared" part includes the consumer friendly measure only, not the metric.
Q1. If the background of a package is the same colour as the box around the Nutrition Facts table (NFT) is a gap in the colour required to ensure the 0.5 rule box around the NFT is separately visible? Is it possible to leave it and have one continuous colour?
If the background colour is the visual equivalent of 100% black, it is acceptable that this be continuous with the 0.5 rule box around the NFT. This is because the background colour is outside of the NFT where the format specifications don't apply. However, if there is possibility the colour may bleed (or in printing terminology "get trapped") into the white NFT background this would not be acceptable as it would impact on the NFT meeting the format specifications.
Q1. Are the folded ends on a 1 pound foil wrapped package of butter considered part of the available display surface (ADS)?
In the samples evaluated, the folded ends were not considered part of ADS, as each of the 4 folds were too small of a continuous surface to be counted. Detailed information regarding ADS can be found in Section E of the Nutrition Labelling Toolkit.
Available Display Surface (ADS) for bacon boards
Q1. What is considered Available Display Surface (ADS) in the case of bacon board packages?
Available display surface in the case of bacon board packages is the total surface of the package, excluding the space occupied by the UPC code, the package seams, and a surface equivalent to the length of the package by the width of a strip of bacon, so that the customer is able to see the bacon. The space equivalent to the length of the package by the width of a strip of bacon is only excluded in the calculation of the ADS if indeed the package has such a window to display the bacon. (August 2004)
B.01.401 (2)(b)(iii) - meat and poultry
Q1. Kosher meat and poultry typically uses salt in a cleansing process , which is then rinsed off prior to sale. Is this still considered "single ingredient" meat ?
Salt used in the kosher process that is rinsed off the meat prior to sale, is typically present in such low residual levels that it would not be considered an ingredient. Under these circumstances, the exemption from the requirement for a Nutrition Facts table for raw single ingredient meats would continue to apply.
B.01.401(2)(b)(iii) and (v) - prepackaged barbequed poultry and meat at retail
Q1. Is pre-packaged poultry or meat barbequed on the retail premises exempt from nutrition labelling, if no additional ingredients are added?
The exemption provided by section B.01.401(2)(b (iii), Food and Drug Regulations (FDR) is for raw, single ingredient meat, meat by products, poultry and poultry by-products. If no ingredients are added to the barbecued poultry or meat, this exemption does not apply because the food is no longer raw. However in most cases, the above mentioned products that are roasted, barbequed or broiled and sold at the same retail premises have added seasonings and/or fat and/or glaze. Any ingredient added by the retailer would afford the product the exemption provided under section B.01.401 (2) (b) (v). If the ingredients are added by the supplier and the food is simply roasted, barbequed or broiled at retail, then this exemption does not apply.
B.01.401(2)(b)(iv) - marine and fresh water animals
Q1. Are combinations of raw, single ingredient marine or fresh water animal products also exempt from the Nutrition Facts table requirement as per B.01.401 (2)(b)(iv), e.g. a mixture of raw single ingredient shrimp and scallops?
B.01.401(2)(b)(iv) - smoked fish
Q1. Is smoked fish exempt from carrying a Nutrition Facts table under the raw single ingredient exemption?
No, smoked fish is not a single ingredient food. There is always smoke (which has to be declared) and salt added.
B.01.401(2)(b)(v) - retail prepared and processed
Q1. Does the exemption for products "sold only in the retail establishment where the product
is prepared and processed from its ingredients" include products which were not manufactured at retail but are simply individual bulk foods
combined together by the retailer into one package?
Examples: A multi-serving combination of rice, egg roll and chow mein; assorted varieties of buns; party trays of cheese or of a variety of olives,
sliced meats, nuts, etc.
When the retailer has created a package containing a combination of two or more individual foods, the resulting product is considered to be 'prepared and processed from its ingredients' and a Nutrition Facts table is not required.
In these situations the NFT is always an acceptable voluntary option. The tray of chow mein, egg roll and fried rice could provide an aggregate format NFT or a composite value using the standard format, or, pending the finalization of the proposed amendment, separate standard formats for each of the three foods.
In addition, if some of the foods packaged together at retail are exempt, there is no objection to a NFT being provided for only the non-exempt portion, e.g. fruit plate with dip that provides NFT fr the dip only (as the fruit is exempt). It must be clear that the NFT relates only to the dip portion of the product. This situation does not apply when the product is prepared and packaged at a location other than the retail establishment where it is sold, in which case the entire product requires nutrition labelling.
Notes: Individual foods packaged from bulk at retail, such as one variety of buns, the egg rolls alone etc., are required to have a NFT. Foods with an ADS less than 200 cm2 are exempt [B.01.401.2(b)(viii)], as are individual servings sold for immediate consumption [B.01.401.2(b)(vii)].
Q2. Are single ingredient products manufactured at retail exempt from a Nutrition facts table? (e.g.,fresh squeezed orange juice or peanut butter made solely from peanuts.)
Single ingredient products which have undergone transformation during preparation and processing at retail are exempt from a Nutrition Facts table. The exemption may be lost under the conditions in B.01.401(3), for instance if a claim such as "source of vitamin C" appears on the orange juice.
B.01.401(2)(b)(v) - products "completed" at retail
Q1. What sort of nutrition labelling is required on a product that is "completed" at the retail level? (Example: a cake fruit flan (white cake with icing and custard filling) shipped from the manufacturer to various retailers which, in turn, add fruit and glaze at the store level.)
No nutrition information is mandatory on the cake when it is sold to the consumer, as it is considered to be prepared and processed at the retail establishment, but the cake leaving the manufacturer requires nutrition information (as required for all foods for use in manufacturing other foods [B.01.404].)
B.01.401(2)(b)(vii) - individual servings for immediate consumption
Q1. Is refrigeration of an individual serving for immediate consumption considered to extend the durable life, such that the product would lose the exemption?
No, refrigeration is not considered a process to extend durable life. So the exemption applies to sandwiches or pre-packaged ready to eat salads etc., that are refrigerated if the product meets all the conditions of the "single serving for immediate consumption" exemption. However, freezing is considered a process to extend durable life. A process that extends durable life is meant to differentiate between food sold for immediate consumption in packaging like saran or cellophane wrap and pre-packaged foods that can be consumed after a longer period of time. A process to extend durable life date includes pre-packaged products with special packaging such as modified atmosphere packaging (i.e. sandwiches sold from a vending machine or mobile canteen)
Q2. Does the exemption for "individual servings sold for immediate consumption, not subjected to a process to extend durable life" apply to servings of individual foods only, or can it also apply to individual servings of entire meals?
The exemption applies to the product, not the individual food, so if the product is a lunch with a sandwich, fruit and carrot sticks, the entire product is exempt. This exemption applies to individual servings of food sold for immediate consumption providing that they have not been subjected to a process or special packaging, such as modified atmosphere packaging, to extend their shelf life. This exemption can be lost; conditions on losing the exemption are in B.01.401(3) Food and Drug Regulations
Q3. Does the exemption for "individual servings sold for immediate consumption, not subjected to a process to extend durable life" apply to foods that need to be heated, such as an individual serving of fresh pasta?
Yes. This exemption applies when the food is meant to be eaten shortly after purchase, even if heating is required. The durable life of the products covered by this exemption is short, so would not include the same food in frozen form.
B.01.401(3)(e) - Loss of Exemption - Sugar alcohols
Q1. Do sugar alcohols present in an otherwise exempt product trigger a loss of exemption from the requirement for a Nutrition Facts table?
Currently, the presence of sugar alcohols does not cause a loss of exemption from the requirement for a Nutrition Facts table under B.01.401(3), Food and Drug Regulations. However, this was an oversight and the proposal in Canada Gazette, Part I, Schedule 1416, (Volume 139, No. 19) May 7, 2005 (if approved) would correct this.
Pie crust (Note : this applies to pie crust - the reference amount for whole pies is listed separately in item 19)
Q1. How does one determine a single serving for pie crust if the reference amount is not given in grams or millilitres, only a fraction of a pie crust ? Item 20 of Schedule M for pie crust is 1/6 of a 20 cm crust or 1/8 of a 23 cm crust.
B.01.002A 2(b) or (c) require reference amounts in grams or millilitres to calculate single servings. As this does not apply in this case, B.01.002A(2)(a) must be used in this situation : the quantity of food that can reasonably be consumed by one person at a single eating occasion. This is determined based on presentation and amount, i.e. a tart shell with an area smaller than the reference amount (< 52 cm2) would be considered a single serving as would a shell presented as the basis of a single meal, e.g.. lunch-sized quiche shell
Q2. Would a granola bar with a net weight of 75 grams be considered a single serving, even though the reference amount for this type of product is 30 grams?
Section B.01.002A of the Food and Drug Regulations state that a serving of stated size shall be the quantity of the food in the package if the quantity of the food can reasonably be consumed by one person at a single sitting. In this case, the granola bar meets this condition so the serving size must be the entire content of the package, i.e. 75 grams.
Serving Size Declaration
Q1. What format can be used when declaring the serving size for condensed soups/juices when just water is being added?
Since water is the only ingredient added during preparation (and thus no change in the nutritional profile), the serving size as indicated for the Dual Format-Foods Requiring Preparation, may be used. (Section 5.6.3 of the Guide)
For example: Per ½ cup (125 mL) About 1 cup prepared
Q2. When stating serving size (as gram weight) for meat with bones (e.g., chicken wings or drumsticks), should it be specified that the serving size represents only the edible portion and not the bones?
The nutrient information presented in the Nutrition Facts table is based on a specific amount of food (edible portion). The words "edible portion" should be included to clarify that the weight of the serving includes only the portion of the food that is consumed, i.e. the chicken and not the bones of the chicken.
For example: "Serving Size 1 Drumstick (100g edible portion)"
"Pour" or "par" for the Nutrition Facts table serving size
Q1. When are "par" and "pour" used for the serving size in a French Nutrition Facts table?
"Par" and "pour" are synonyms and can usually be switched. "Pour" tends to be more widely used when there is a specific number of something, for example; "per 3 pieces" would be "pour 3 morceaux". If you had a ½ cup as your serving size you would be more likely to say "par ½ tasse". If you wanted to use "pour" for a serving size of a ½ cup you would need to say "pour une ½ tasse".
"Per approximately" or "per about" in the serving size
Q1. Can "about" or "approximately" be used in the consumer friendly measure for serving size (see column 3 (1)) ?
"per about 5 pieces (xx g)" , "per approximately 1 fillet (xx g) " or other similar declarations are allowed when there is variability in the consumer friendly part of the measure. It is not permitted for uniformly sized products, e.g. stacked potato chips, most cookies, crackers, etc.
Example: a box of 4 fish fillets, the net weight of the product is 500 g and each fillet is roughly 125 g. However, due to natural variation they are not completely uniform, one could be 115 g, another 135 g. In cases like this it is acceptable to use "per approximately 1 fillet (125 g)" which is meant to indicate to the consumer that 125 g is roughly the size of each individual fillet. The metric measure must be a precise number and the nutrient values must meet the compliance test for that metric value.
Ranges in the serving size
Q1. Is it acceptable to declare serving size in the following manner - "per 5-6 onion rings", "per 6-8 scallops"?
No. "About" or "approximately" (see above) sufficiently indicates to the consumer that the weight corresponds to roughly that number , allowing for variations in size of irregular pieces. A range in the serving size would increase the room for varied interpretations by the consumer (e.g. is that 4-6 big onion rings or 4-6 small ones? etc.) and would reduce the onus on the manufacturer to make as accurate a representation as possible.
Fluid Ounces as a Consumer Friendly Measure
Q1. Can fluid ounces be used as a consumer friendly measure or in addition to a metric measure?
No, fluid ounces can not be used as a consumer friendly measure or in addition to a metric measure. B.01.401 states that ONLY the information in the table following B.01.401 can be present in the Nutrition Facts table.
Use of "per 100 g" exclusively as the serving size
Q1. When can "per 100 g" be used on its own as the serving size declaration in the Nutrition Facts table, without a consumer friendly measure?
"per 100 g" can be used on multi-serving meats (e.g. roast beef), poultry (e.g. whole chicken), fish fillets, or catch weight meat, poultry or fish products that cannot divided up into pieces or slices of similar size. It can also be used on deli meats sold in chubs or industrial formats or on single serving containers when 100 g is the net quantity of the container. These situations are covered in Section C of the Tool Kit. Examples of products that may use "per 100 g" alone as the serving size declaration are:
- whole roast beef
- whole chickens
- whole turkeys
- chub/industrial format of salami or other deli meats
- steaks, pork chops, when multi-serving variable size
- side of salmon
- whole hams
- whole fish
- fish fillets (with the exception of uniform preportioned ones)
- mixed trays of drumsticks, thighs, chicken breasts
When "per 100 g" CANNOT be used exclusively as the serving size
Q1. When can "per 100 g" (or other metric weight) on its own NOT be used as the serving size declaration in the Nutrition Facts Table, i.e. a consumer friendly (visual) measure must be provided?
Anything other than the above Q & A. Examples of products that MUST include a consumer friendly measure as part of the serving size declaration, with examples, are:
- ground meat and poultry (e.g. per 1/2 cup (xx g))
- bacon (e.g. per 2 slices (xx g))
- beef jerky (e.g. serving about 1 piece (xx g))
- hamburger patties (e.g. per 1 patty (xx g))
- stewing meat (e.g. per 1 cup (xx g))
- prepackaged sliced deli meats (e.g. per about 2 slices (55 g))
- non-uniform chocolate Easter bunnies (e.g. per 1/4 package (xx g))
*Note: "about" or "approximately" may be used in the consumer friendly measure when the products vary in size and may not be exactly the weight indicated.*
Q1. Can companies use the Nutrition Facts table for a large egg on medium or small egg cartons?
No. For foods that are preportioned in units commonly consumed by a person (e.g. eggs), the serving size should be the unit or a multiple of the unit (e.g. 1 or 2 eggs). This means that for medium or small egg cartons, the serving size must be based on the size of the egg in the carton (i.e. small or medium eggs). Companies should not be using a serving size of "1 large egg (50 g)" on cartons of medium or small eggs.
The company has flexibility in determining if they want to use one or two eggs as the serving size. The serving size should be the amount of food that one adult would reasonably eat at one eating occasion (The recommended serving size for eggs is 50-100 g).
Q1. Can cheese use "per 30 g" or "per 100 g" (as the non-uniform meat can) only for the serving size or must a consumer friendly measure also be present?
Cheese requires a consumer friendly measure as part of the serving size statement. Options include "per x mm slice", "per x cm 3 cube", or for soft cheeses "per tablespoon" or "per x ml".
Q1. Can the U.S. common household measure be used in the serving size declaration in the Nutrition Facts table e.g. 1 cup (240 ml)?
Since Canadian measuring devices are used in Canadian homes, the common household measure declaration should be Canadian. Most measuring cups and spoons sold in Canada reflect the metric equivalents of the household measures , e.g. 250 mL for a cup and 15 mL for a tablespoon.
Meat, Poultry, their products and substitutes
Q1. What reference amount would be used for a corn dog on a stick (with breading)?
This product would have a reference amount of 100 grams (raw) or 60 grams (cooked) as it falls under item 93 of Schedule M of the Food and Drug Regulations which includes sausage meat with breading or batter
Q2. What would be the reference amounts for the following meat products:
- Stuffed turkey roast
- Stuffed chicken, such as Chicken Cordon Bleu
- Shish Kebabs and Souvlakis
- Roasts, such as Turkey or Chicken roasts
For stuffed turkey roast and stuffed chicken, the reference amount for Combination dishes not measurable with a cup, item 108 in Schedule M of the Food and Drug Regulations would apply, i.e., 140 grams without gravy or sauce and 195 grams with gravy or sauce.
Shish kebabs and souvlakis would also fall under this category if they are a combination of meat and vegetables. However, if the shish kebabs consists of only marinated meat, it is no longer a combination dish and the reference amount for cuts of meat, item 92 of Schedule M (125 grams raw, 100 grams cooked) would apply. Whole chickens and turkey roasts would also have a reference amount of 125 grams raw (or 100 grams cooked).
Items 4 to 6 - Ice cream cake
Q1. What is the reference amount for an ice cream cake that consists of a cake topped with ice cream and whipped topping? From Schedule M; is it a heavy, medium, light cake (items 4, 5, 6) or item #54 - frozen dairy desserts?
Frozen dairy desserts may include confections such as cake or cookie pieces when the product is primarily an ice cream product. When ice cream is one ingredient in a cake consisting of significant amounts of non-dairy ingredients as well, the cake is not considered a dairy product for the purposes of the Dairy Products Regulations. Therefore the reference amount for this product depends on the overall density of the product (grams per cubic centimetres) as set out in items 4, 5 & 6 of schedule M. The net quantity of this product should also be shown by weight.
Item 35 - Pastas without sauce
Q1. What reference amount is to be used for fresh pasta?
The reference amount for cooked pasta is to be used, item 35 in Schedule M of the Food and Drug Regulations - prepared pasta without sauce, 215 grams. If the fresh pasta is not in a ready to eat state and needs further cooking, the reference amount is the amount of fresh pasta required to make 215g cooked pasta.
Items 71 to 74 - Snails
Q1. What is the reference amount for snails?
They fall under marine and fresh water animals, items 71-74 as appropriate. This applies whether they are land or ground snails.
Items 105 and 106 - Seasoning Products with Salt
Q1. Do seasoning products with salt such as "vegetarian seasoning" use reference amount # 105 (1 g) , for salt, salt substitutes, and seasoned salt, or # 106 for spices and herbs?
They would fall under item 105. Products that consist only of spices and herbs and no salt would fall under reference amount 106.
Items 107 and 108 - Combination Dishes
Q1. If the combination dish is measurable with a cup but the net quantity and serving size are declared in grams, which reference amount would apply - the 250 mL reference amount for dishes measurable with a cup (item 107) or the 140 g (without gravy or sauce) or 195 g (with gravy or sauce) reference amount for dishes not measurable with a cup (item 108)?
In these situations, item 108 applies, i.e. 140 g without gravy or sauce or 195 g with gravy or sauce
Q2. What reference amount would be used for pasta/rice side dishes?
In the case of flavoured pasta and rice which contain additional ingredients (e.g., macaroni & cheese, rice with vegetables), they should be considered as combination dish with a 250 mL reference amount (item 107, Schedule M Food and Drug Regulations). The 250 mL reference amount refers to pasta/rice in its prepared form. Therefore, the amount of dry product (grams) needed to make 250 mL would be used as the reference amount.
However, if the flavour is infused into the pasta/rice dish and no other ingredients are present, then the reference amount would be:
- Pasta - 85g dry, 215g cooked (item 35)
- Rice - 45g dry, 140g cooked (item 34)
Item 108 - Pizza
Q1. Is pizza considered to be with sauce or without?
"With sauce" refers to products with a sauce topping, e.g. gravy, hollandaise sauce, or something like cabbage rolls sitting in sauce. Pizza would be considered a "without sauce" product, as would lasagna or other products with sauce in them.
Item 125 - Liquid Smoke
Q1. What reference amount should be used for liquid smoke? Liquid smoke is the concentration of the direct combustion of hardwood, hardwood sawdust or corncobs with water added.
This would fall under the category of minor condiments, item 125.
Item 126 - Pita Chips
Q1. What reference amount applies to pita chips?
Pita chips are considered snack foods and would fall under reference amount 126 (chips, pretzels, popcorn) as they are marketed and consumed in the same way as these foods.
Item 142 - Vegetables without sauce
Q1. What reference amount should be used for onion rings?
Although there is no specific category for onion rings, they would fall under item 142 vegetables without sauce, with a reference amount of 85 grams
Q2. What would be the reference amount for breaded zucchini sticks?
The reference amount for vegetables without sauce is to be used, item 142 in Schedule M of the Food and Drug Regulations - 85 grams. Other similar products, such as onion rings would fall under this category.
U.S. and Canadian Nutrition Facts tables
Q1. Do Canadian regulations permit both the US and Canadian compliant Nutrition Facts tables to appear on the same package (in the case of a product imported from the US) or is only the Canadian table permitted?
Only the Canadian Nutrition Facts table may be used to provide nutrition information in Canada. Nutrition labelling systems from other countries are not acceptable in Canada.
B.01.401 states that the label of a pre-packaged product shall carry a Nutrition Facts table that contains ONLY the information as set out in the Food and Drug Regulations. The Food and Drug Regulations (FDR) set out the manner in which energy and nutrient values must be declared. Subsection 5(2) of the Food and Drugs Act prohibits labelling that is contrary to the Regulations. Since the nutrition information requirements of other countries do not match the Canadian requirements, labels with nutrition information other than that permitted by the FDR and considered to be labelled contrary to Canadian legislation.
Q1. A registered processor custom processes sport caught fish. The product is never owned by the processor, they only charge a fee for the service of processing the fish for personal consumption by the fisher and the fish is returned to the fisher in a package. Is a Nutrition Facts table (NFT) required on these products?
No, there is no sale and no NFT is required. [B.01.004(2)]
Q1. What are the regulations regarding bulk? Must the Nutrition Facts table be applied directly onto the cases?
Shipping containers of product going to be sold in bulk at retail must carry a Nutrition Facts table (NFT), in the appropriate format as prescribed by B.01.401, Food and Drug Regulations (FDR) unless exempted by B.01.401(2). They are considered to meet the definition of pre-packaged foods in the FDR
*Note: Products offered for sale from bulk are not considered pre-packaged and therefore are not subject to the requirements of B.01.401. If the retailer pre-packages product from bulk, then these must carry an appropriate NFT.
Q1. When non-prepackaged foods provide nutrition information, must they use the Nutrition Facts table (NFT) format?
Although there are no requirements to provide a NFT for non-pre-packaged restaurant and food service foods, many establishments wish to provide this information on a voluntary basis. When showing the nutrition information for these foods, companies are strongly encouraged to show the same information that is provided in the NFT. The format requirements for pre-packaged foods do not apply to restaurant foods, so an alternate way of presenting the information is acceptable, such as the use of a table or chart, tray liners, menu boards, posters, leaflets or brochures available to consumers. The "Nutrition Facts" heading is an acceptable title for showing this information. For more information see the Information Bulletin regarding nutrition labelling and foods sold in restaurants and food service establishments.
Q1. Does the outer surface of an egg carton have to indicate that the NFT is found on the inside lid of the carton?
This section only applies to alternative methods of presentation when the outer ADS will not support a NFT. This is not a requirement for egg cartons when the NFT appears on the inside of the carton. As the inside of the carton would be considered to be part of the ADS, when used, there is no requirement for the producer to indicate that the NFT appears on the inside of the carton.
Q1. When making a comparative claim about milk products can milk be compared to a cream cheese product?
Cream cheese is not included in the milk products and alternatives group because of its low calcium and high fat content. Cream cheese falls under the category of "other foods" item (a) - foods that are mostly fats
Q2. Can a comparative claim be made between pretzels and foods from the bread and grain products food group?
No. Pretzels fall into the category of "other foods" item (c) - snack foods. Comparative claims may only be made between foods in the same food group. Pretzels must be compared to another food falling within the snack food subcategory of "other foods".
Q1. Some products are required to show certain content information that is not included in the Nutrition Facts table, either on the principal display panel or elsewhere on the label. For example, the amount of aspartame must be shown in milligrams per serving of stated size when added. Does the Nutrition Facts table have to be shown in addition to this information?
Yes, in general, the Nutrition Facts table is required on all prepackaged products, whether or not specific content information is otherwise required to be shown separately. For example, a beverage with added aspartame requires both a separate statement of the quantity of aspartame per serving of stated size as well as the Nutrition Facts table. If aspartame is added to a product that would otherwise be exempt from a Nutrition Facts table, the exemption is lost and the Nutrition Facts table must be displayed (B.01.401(3)(c), FDR). As aspartame is neither a core nutrient nor a permitted additional nutrient, the aspartame content statement must appear outside the Nutrition Facts table, grouped with the list of ingredients.
Note: The aspartame content is required to be shown in mg per serving of stated size. The serving size should be consistent with the serving size shown in the Nutrition Facts table.
More information on product specific labelling requirements can be found in the Guide to Food Labelling and Advertising.
Q2. Are quantitative statements for substances that are not recognized as nutrients, such as lycopenes and phytochemicals, allowed in the Nutrition Facts table?
No, only the nutrients shown in the tables to sections B.01.401 and B.01.402 of the nutrition labelling regulations in the Food and Drug Regulations are permitted to be shown within the Nutrition Facts table. Lycopene and phytochemicals are not listed in these tables. Quantitative declarations of these types of substances may be declared in grams or milligrams per serving of stated size elsewhere on the label, but not within the Nutrition Facts table.
Foods in Liquid
Q1. What is the basis of nutrition information for foods sold in liquids such as oil, brine, syrup?
Nutrition information is based on the edible portion of the food as sold. For foods sold in a liquid, the serving size should be based on the
typical consumption of the product.
- The liquids of pickles, artichokes, olives, etc. are packed is not normally consumed, therefore the nutrient information should be based on the drained product per pickle (xx g).
- The syrup in which canned fruit is packed is typically consumed with the fruit per ½ cup (xx ml).
- The oil in sardines or tuna is not typically consumed, therefore the nutrient information should be based on the drained product: per xx sardines (xx g) or for tuna in oil: per 1 can (xx g)
Meat - edible portion
Q1. With respect to meat and poultry, are the fat trim and skin considered part of the edible portion of the food and therefore count as part of the nutrition information?
Yes, for meat and poultry, the trim and skin are considered part of the edible portion if present when sold. The bone is not counted toward the values in the Nutrition Facts table.
Q1. Sodium erythorbate is commonly used in meat products as part of a binder or seasoning. Lab analysis may reveal high levels of vitamin C in these foods coming from the erythorbate. Should vitamin C from erythorbate be declared in the Nutrition Facts table (NFT)?
No, it should not be part of the NFT declaration. Erythorbate is not vitamin C as specified in D.01.003(1)(e) of the Food and Drug Regulations (FDR). It is an inactive form that does not have the same physiological effect. However, it may show up as vitamin C in lab analysis if the lab is not making this distinction. CFIA labs can make this distinction when necessary, depending on the product in question.
Q1. Can the aggregate format be used on a container that is used to package a variety of dips? The same Nutrition Facts table and package would be used each time with an indication of which values applied to the product in question.
This is acceptable as long as it is clear which nutrition information applies to which product. This applies to other products involving multi-use packages.
Q1. What is the difference between sections (1) and (2) of B.01.021?
B.01.021(1) is to cover off quantitative labelling of erythritol when there is no Nutrition Facts table (labelling under old regs). B.01.021(2) is to cover off labelling when there is a Nutrition Facts table (implied by wording when contrasted with subsection (1), but not clearly or explicitly stated). It requires declaration of erythritol with all the other sugar alcohols in the nutrition facts table as per item 12 of the table following B.01.402.
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