Chapter 7 - Packaging and labelling

7.1 Introduction

The purpose of this chapter of the Meat Hygiene Manual of Procedures is to elaborate on the regulatory requirements related to packaging, labelling and recipes of edible meat products prepared in federally registered establishments or imported.

The Label and Recipe Registration Unit (LRRU) is responsible for the registration of labels and recipes in accordance with Section 110 of the Meat Inspection Regulations, 1990.

All label and recipe registration requests for meat products from federally registered establishments or imported are to be directed to:

Label and Recipe Registration Unit
CFIA
1431 Merivale Road
Ottawa, ON K1A 0Y9

Section 7.4 outlines the label and recipe registration procedure.

For labels not requiring label registration, please see Annex F.

7.2 Applicable legislation and references

The following references are applicable to the packaging, labelling and recipes of meat products either prepared in federally registered meat establishments or imported:

  1. The Meat Inspection Act and Regulations
  2. The Consumer Packaging and Labelling Act and Regulations
  3. The Food and Drugs Act and Regulations
  4. The Canada Agricultural Products Act and Regulations made thereunder
  5. The Guide to Food Labelling and Advertising
  6. The CFIA Meat Cuts Manual
  7. The Nutrition Labelling Tool Kit
  8. The Weights and Measures Act and Regulations

To reduce the volume of this chapter, the information contained in these reference materials will not be repeated in detail.

7.3 Types of containers and labels

Packaging materials shall not impart any undesirable substance to the meat product, either chemically or physically, and shall protect the food product sufficiently to prevent contamination. Containers must be included in the Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products.

7.3.1 Types of containers

Basically, there are two types of containers: retail containers and non-retail containers.

  1. Retail containers:

    Bags
    Casings (natural and artificial)
    Cartons
    Mono-cups
    Folders
    Glass jars
    Pouches
    Cans
    Wraps

  2. Non-retail containers:

    Tanker trucks
    Combo bins
    Tanks
    Bags, including stockinettes
    Wraps
    Cartons
    Cans

7.3.2 Types of labels

The LRRU distinguishes the following types of labels and refers to them under the following codes. These codes may be included by the applicant on the CFIA/ACIA 1478. (Annex A)

A Artificial casing
B Printed bag
BL Pressure-sensitive label for bag
C Individual carton and mono-cup lid
CB Combo bins
D Stencilled product description, (pail, barrel head, barrel and drum)
DC Display carton
EC Edible casing
F Bacon folder or wallet
G Paper label for glass jar
HB Hessian bag
HL Header label (hanging)
I Insert label
K Kemex label
L Paper label
M Breast tag; clip for bag or casing
P Pouch, film, foil or paper
PB Poultry bag
PL Placard label for freight car, tank car or truck
PS Pressure-sensitive label for consumer sized products
RS Stamp, stencil or pressure-sensitive label for use with shipping container
S Shipping container
SB Sleeve printed band
SL Label for shipping container
SV Sealed vehicle
T Lithographed can
W Wrap, cello, foil or paper
X Shipping tag
Y Stockinette
Z Tag for sausage in natural casing

Please note that in fully marked containers closed by a pressure sensitive tamper evident label that doubles as a seal, the label sticker shall display either the meat inspection legend or a complete label.

All other pressure-sensitive labels need not be tamper evident, but must stick securely to the shipping cartons or immediate containers.

7.3.3 Package design guidelines for Vexar netting, coloured casings and bags

  1. General
    • Opaque bags, casings or wrappings of any colour, including for poultry carcasses, are acceptable.
    • Tinted transparent and semi-transparent bags, wrappings or films are permitted under certain conditions (see item (b)).
    • Netting must be of significantly contrasting colour to the product it is covering.

    The wrappings shall not be of such colour, design or kind as to be misleading with respect to colour, quality or kind of product to which they are applied. Transparent or semi-transparent wrappings for articles such as sliced bacon or fresh (uncooked) meat products shall not include lines or other designs of red or other colour which give a false impression of leanness of the product. Transparent or semi-transparent wrappings, casings or bags for use in packaging cured, cured and smoked, or cured and cooked sausage products, and sliced ready-to-eat meat products may not include red designs which would enhance the appearance of the product.

    In the case of packages of bacon slices (belly or side), the window area on the package must be large enough to expose at least 2/3 (66%) of the bacon strip length, as well as the complete width of the bacon strip.

  2. Use of coloured transparent or semi-transparent containers
    1. Prepackaged meat products

      This category of meat products refers to those meat products intended to be sold directly to the consumer. These products shall not be packaged in coloured transparent or semi-transparent containers unless:

      1. a declaration attesting that the container is coloured appears:
        1. on the label in close proximity to the product name (e.g. "Beef sausage in coloured casing"); or
        2. on the container printed in a repeated manner.

        and

      2. a cross-section of the meat product is visible through a clear colourless film.

        Note: the size of the lettering for the declaration will be a minimum of one-half the size of type of the product name.

    2. Non-prepackaged meat products

      This category of meat products refers to meat products that are not intended to be sold directly to the consumer in their original container, but require slicing and cutting by the retailer before being offered for sale. Such products are not required to bear special markings/declaration or to show a clear cut surface. This would include meat products sold to deli outlets, hotels and restaurants. There is no weight restriction for these products.

7.4 Request for registration of labels and recipes

Label as defined in the Meat Inspection Act, includes any legend, word, mark, symbol, design, imprint, stamp, brand, ticket or tag or any combination thereof that is or is to be applied or attached to or included in, or that accompanies or is to accompany, any meat product, package or animal.

Recipe as defined in the Meat Inspection Regulations, 1990 Section 2, in respect of a meat product:

  1. the ingredients of the meat product and the components of the ingredients thereof, including food additives;
  2. the proportions of those ingredients and components; and
  3. the method of manufacture and the results of any test conducted on the meat product.

7.4.1 Labels and recipes requiring registration by the Label and Recipe Registration Unit

  1. From Canadian registered establishments:
    1. all labels intended for immediate containers (pre-packaged) and recipes of prepared edible meat products for domestic sale, except:
      • meat products exempted under paragraph 3(1)(i) of the Meat Inspection Regulations, 1990;
      • salted Kosher meat*;
      • salted casings; and
    2. all labels for meat products with a claim in regard to the term "organic", "natural", "no animal by- products", "raised without antibiotics", or any other animal production or feed related claims. See section 7.7.1 for more information.
  2. From foreign establishments authorized to export meat products to Canada:
    1. Same as from Canadian registered establishments.
    2. All labels intended for immediate containers (pre-packaged) of single ingredient edible meat products intended to be sold directly to consumers at the retail level in Canada.

* Meat products treated with salt and water in accordance with Judaic law. The ingredient listing is not required on the label of these products when the identity of the product reflects the fact that the product has been salted.

7.4.2 Submission of labels and recipes for registration

It is highly recommended that before a label or a printer's proof of a label is submitted to the LRRU, the operator presents the proposed label and recipe, together with a completed application form CFIA/ACIA 1478 (Annex A), to the Inspector in Charge of the registered establishment for review. The preliminary review by the Inspector in Charge is intended as a screening process to ensure all regulatory requirements have been met and also serves to keep the Inspector in Charge informed of the operator's intentions to develop a new product or of a forthcoming label change.

The operator shall inform the inspector of all label and recipe applications made to the LRRU. Ensuring that the label reflects the product recipe is the responsibility of the operator and will be verified by the inspector as part of their inspection activities.

Upon receipt of registration documents for a label and /or recipe from the LRRU, the Inspector in Charge should forward any objection or comment that they have concerning that label and/or recipe to their Area Office contact with a copy of the correspondence to their immediate supervisor.

7.4.2.1 Detailed label application process for Canadian processors

The following documents are required by the LRRU:

  • 1 copy of the application form CFIA/ACIA 1478 (Annex A);
  • 2 copies of the recipe (refer to section 7.4.6);
  • 3 copies of the label (printer's proof, i.e. label design prior to printing); and
  • payment, if applicable (refer to section 7.5).

A copy of form CFIA/ACIA 1478 is provided in Annex A or can also be found on the CFIA Web site at www.inspection.gc.ca under Forms/Publications –> CFIA Forms –> 1478. The form can be completed on the web page but must be printed and mailed.

The registration of a new label is usually done in 2 steps:

  1. Proof review

    The LRRU may issue a registration number at the time of the proof review. The application, including the label and stamped recipe, will be returned to the operator with comments (if any). The LRRU will also send the reviewed application form and proof label to the Inspector in Charge. The recipe is not distributed back to the inspector. Only upon receiving a registration number may the operator then proceed to have the labels printed provided the corrections have been made.

  2. Final approval

    As a final step, the operator shall submit two photocopies of the CFIA/ACIA 1478 containing LRRU response and comments (if any) together with two final printed labels to the LRRU. Full size colour printer's proof may be sent as final if the label is excessively large or bulky. One copy of the CFIA/ACIA 1478 with the label and recipe will be kept by the LRRU while the second stamped copy (see Figure 1, Annex E) will be returned to the operator.

    The operator shall provide the Inspector in Charge with a final label for their files. This completes the label registration process.

    If the final printed label is not submitted to the LRRU within a period of 120 days following proof registration, then the label registration lapses automatically and will be deemed "cancelled".

    Please note that a final approval may be given to a label at the first step if the final label is provided and no corrections are required by the LRRU.

7.4.2.2 Application process for foreign processors

The label application process for foreign processors is the same as for Canadian processors, except for the following points:

  1. three copies of the recipe is required for foreign products;
  2. the Meat Inspection Authority of a foreign country is responsible to see that labels used for export of meat products to Canada are registered by the LRRU and are produced in accordance with the registered recipe; and
  3. label registration of imported products are valid for 10 years; after that time, a new label registration request must be made.

7.4.2.3 Electronic application process

Proof registration for some types of labels and recipes may be done electronically. It is expected that this option be expanded to all labels in the future. For further details on electronic submissions please contact Label-Etiquette@inspection.gc.ca

7.4.3 Generic labelling

More than one label may be grouped under the same registration number when the same product is packaged into various formats (weights, volumes, counts). A new registration fee will apply to the first label and an update fee ($45.00) will apply to all subsequent generic labels (if fees apply, see section 7.5).

When submitting a generic label for update, the company is to send in all formats, where possible, related to that recipe (registration number) at the same time. Where it is not possible to do so, the operator shall make an appropriate comment on the registration form.

All other variations of a label of the same product cannot be grouped under the same registration number. For example, if a product is packaged under multiple brands, or if the same product is manufactured in various establishments, each label with a different brand or establishment number is given a different registration number.

Only one type of label per application is allowed (Cryovac bag, combo bins, pails, shipping cartons, bacon folders, casing, etc.).

7.4.4 Submitting label updates

Depending on what is being updated, a new registration number may be assigned.

  1. A new registration number will be assigned for each submission where a change in any of the following parameters occurs (unless changes are made within 120 days of registration):
    • brand name;
    • establishment number;
    • storage instructions;
    • common name;
    • company names or first dealers;
    • claims;
    • change in nutrition facts data or format; and
    • recipe.
  2. The registration number remains the same when there is a change to the following:
    • artwork;
    • positioning;
    • medals, ribbons; and
    • other non-mandatory information.

In both cases, a new CFIA/ACIA 1478 form or a copy of the most recent final registration, clearly explaining the update and showing the previous registration number, must be submitted along with the label and any pertinent information. When an update is made to the recipe, the updated recipe must be submitted as per section 7.4.6.

7.4.4.1 Label updates required as a result of mandatory regulatory change

When labelling changes are made to a previously registered final label in order to comply with new regulations, such as mandatory nutritional labelling, the amended label must be re-registered. When the only changes made are with respect to the regulatory change (i.e. no other label or recipe modifications are made), the company is to submit 2 copies of the new printer's proof label and 2 copies of the most recent final registration form for that label to the LRRU. The new label will be reviewed to determine if the requirements of the new regulations have been met.

7.4.5 Submission for temporary registration of promotional labels

Temporary registration numbers are assigned to certain promotional labels, and to labels bearing animal or feed production claims.

We distinguish two types of promotional labels:

  1. A promotional label for a meat product on which a change in the mandatory information has been made, bearing a statement such as "new", "improved", must be submitted to the LRRU for registration, as outlined under section 7.4.2, and will receive a 1 year temporary registration.
  2. A promotional label which highlights a "contest", "give-away", "coupon inside", etc. does not have to be submitted for registration. This only applies to a label that has received a final registration number and that had no change made to the mandatory information. A sample of such a label, together with a reference to the original registration number, shall be submitted to the LRRU and to the Inspector in Charge for record purposes only.

Flashes are permitted provided they do not obliterate any of the mandatory information. Depending upon the statement that is highlighted, the same procedures as for (a) and (b) apply.

Temporary registration numbers valid for 1 year are also assigned to products bearing animal or feed production claims such as "organic" and "raised without antibiotics". The label must be re-registered each subsequent time as per section 7.4.4 with an updated production claim certificate.

7.4.6 Submission of product recipe

In the case of a prepared meat product, the product recipe shall accompany the label and be submitted in duplicate on company letterhead, signed and dated by a company official. In the case of a foreign establishment, the recipe shall be submitted in triplicate.

The recipe must include the formulation and the method of preparation and shall be outlined in detail. This would include but is not limited to:

  • total protein and meat product protein percentages for standardized meat products for which minimum percentages are prescribed;
  • processing steps including cooking and cooling parameters (time, temperature);
  • whether the product is "ready to eat" or requires cooking prior to consumption;
  • data to substantiate shelf stability (aw, pH, etc.) if applicable;
  • calculations for determination of added nitrite (ppm) and added phosphate salts (%);
  • validation processes for hermetically sealed commercially sterile products (Fo, pH, time, temperature, atmospheric pressure, etc.); and
  • available display surface calculations in cm2 to determine nutrition facts format.

If found acceptable, one copy will be kept on file in Ottawa and the other will be stamped with an official stamp (See Figure 2, Annex E) and returned to the applicant. The list of ingredients and the method of preparation on that copy are considered as official. When an inspector wishes to examine a formulation, management must produce the officially stamped copy.

Any future modifications to the recipe will have to be clearly identified and submitted to the LRRU. Any changes must be authorized by the operator by initialling the modifications and signing the document (print name, title and date).

7.5 Label registration fees

Taken from the Canadian Food Inspection Agency Act
CFIA Fees Notice
Part 10 - Meat Products Inspection Fees
3. (4) Table 1 # 7. (labels and recipes)

Labels and Recipes

  1. Subject to subitems (3) to (5), for the registration of a label or recipe submitted pursuant to paragraph 110(1)(a) of the Regulations
    $100
  2. Subject to subitems (3) to (5), to change a label that is already registered, to register a new label with a recipe that is already registered or to review a label for a meat product that is not a prepared meat product
    $45
  3. If a change made to a registered label does not affect the information required by the Regulations to be on the label, no fee is payable for the registration of the changed label.
  4. If a change is made to a registered label or recipe as a result of an amendment to the Regulations, no fee is payable for the registration of the changed label or recipe.
  5. No fee is payable for the registration of a label or recipe for the following meat products:
    1. casings;
    2. lard, leaf lard, suet, tallow, shortening and other rendered animal fat; and
    3. prepared meat products that have not been dehydrated, fermented, smoked or submitted to any heat treatment.

Payments can be made by any one of the following methods:

  1. CFIA Account Number (Obtained from the CFIA Accounts Receivable Service Centre)
  2. Cheque (payable to the "Receiver General of Canada")
  3. Credit Card
    • VISA
    • MasterCard
    • American Express

Payments made via Credit Card require that a letter of authorization be provided on company letterhead including the Credit Card type, number and expiration date.

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