Chapter 7 - Packaging and labelling

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7.6 Mandatory requirements for labels of edible meat products in registered establishments

7.6.3 The list of ingredients

(a) General requirements

All ingredients of a meat product shall be listed in descending order of their presence. This will reflect the relative proportion of the ingredients before they are combined to form the meat product. Water and smoke are considered as ingredients and shall be listed as such.

Components of ingredients such as spice mixtures, seasoning and flavouring preparations shall be shown on the label as prescribed under sections B.01.008, B.01.009 and B.01.010 of the Food and Drug Regulations (FDR) (See Annex J of this chapter for more details). In general all the components of these mixtures and preparations need not be declared in the list of ingredients. However when the mixture or preparation contains one or more of the following ingredients or components, those ingredients or components shall be shown by their common names in the list of ingredients of the meat product as if they were ingredients of that product:

1. salt;
2. glutamic acid or its salts;
3. hydrolyzed plant protein;
4. aspartame;
5. potassium chloride;
6. peanut oil; hydrogenated or partially hydrogenated peanut oil; modified peanut oil; and
7. any ingredient or component that performs a function in, or has any effect on, that meat product.

Examples: If a preservative is present in a flavouring preparation in such an amount as to have a preservative function in the meat product to which the flavouring preparation has been added, the preservative must be declared in the list of ingredients of that meat product. Similarly, soy, wheat, milk proteins, etc. are often added to seasoning or flavouring preparations to increase their dispersibility. Since these added substances also perform other functions in the final product, including solubility, gelation, emulsification, viscosity, etc., they must be declared in the list of ingredients of the final product to which the seasoning or flavouring preparations have been added, regardless of the amount present [section B.01.009 (3), FDR].

In variable formulation all meat product ingredients shall be grouped together and placed in the appropriate position in the ingredient listing and be segregated from non-meat ingredients by a semi-colon (;) or a dash (-). If meat product ingredients are fixed as to inclusion and order, segregate each meat product ingredient by a comma (,).

If the meat portion varies as to inclusion or order, then it may read: "Beef, Pork and/or Mutton". If all meat product ingredients are interchangeable, then it may read: "Beef and/or Pork and/or Mutton". Designations of species should appear, in the case of variable formulation, in either of the following formats:

1. ingredients: may contain beef, pork, mutton and their by-products; or
2. ingredients: beef and/or pork and/or mutton and/or their by-products.

A filler may be listed as an ingredient, followed by a listing of all the components between parenthesis, e.g. filler (flour, skim milk powder, etc.), or the components making up the filler may be listed individually as ingredients. Additives such as antioxidants BHA (butylated hydroxyanisole), BHT (butylated hydroxytoluene) may be abbreviated, but a flavour enhancer, such as monosodium glutamate shall be spelled out in full, in the ingredient listing.

Toasted wheat crumb may be listed as an ingredient. Toasted wheat crumb is a food made by cooking a dough prepared with flour and water, which may be unleavened, or chemically or yeast leavened, and which otherwise complies with the standard described in B13.021 and B13.022 of the Food and Drug Regulations. The components of this ingredient do not have to be declared in the ingredient listing when it is added to a meat product.

(b) Allergen labelling

Declaration of ingredients with allergenic properties or causing serious adverse reactions:

A variety of foods contain ingredients that can cause adverse reactions in certain individuals. These reactions can vary from minor to life-threatening. Most adverse food reactions are caused by the following priority food allergens:

• peanuts;
• tree nuts (almonds, Brazil nuts, cashews, hazelnuts [filberts], macadamia nuts, pecans, pine nuts, pistachios, walnuts);
• sesame seeds;
• milk;
• eggs;
• seafood (fish, crustaceans, shellfish);
• soy;
• wheat; and
• sulphites

If these allergens or their derivatives are not correctly identified on the label of a food, the results can be serious and sometimes fatal.

Undeclared allergens may occur as a result of:

1. using re-work materials containing priority allergens or their derivatives;
2. ingredient changes, substitutions or additions not reflected on the label;
3. product in wrong packages because of a mix-up in packaging materials;
4. printing error or omission from the list of ingredients;
5. unknown ingredients in raw materials;
6. use of incorrect common names to describe products/ingredients (e.g. "mandelonas" for "almond-flavoured peanuts"); and
7. carry-over of product through incomplete cleaning of food contact surfaces and utensils, sometimes because of poor equipment design.

The CFIA requires that the above allergens be included in the list of ingredients on the labels of meat products when they are present as ingredients or components of ingredients. Manufacturers must pay special attention to ingredients that are added through the use of mixtures and preparations (e.g. flavouring and seasoning preparations). Also, presence of allergens must be considered in the hazard identification and analysis done as part of the Hazard Analysis Critical Control Point (HACCP) program.

Allergen declaration may be done by using one of the three following options:

Option 1: Declare all the ingredient's components in brackets following that ingredient.

Example:

Ingredients: chicken, batter (water, modified corn starch, wheat flour, salt, soy oil, sodium bicarbonate, milk ingredients, guar gum), toasted wheat crumbs (wheat flour, palm oil shortening, salt, yeast), seasoning (herbs, spices, wheat flour, sesame seeds), lemon juice with sulphites. Fried in hydrogenated soy oil.

Option 2: Declare the name of the food allergens in plain language in brackets after the ingredients. The allergen is only required to be declared once in the list of ingredients. The other non-allergenic components are not required to be declared if the ingredient is exempted from component declaration under subsection B.01.009 (1), FDR.

Example:

Ingredients: chicken, batter (water, modified cornstarch, wheat flour, salt, sodium bicarbonate, milk ingredients, guar gum), toasted wheat crumbs, seasoning (sesame seeds), lemon juice with sulphites. Fried in hydrogenated soy oil.

Option 3: Use a "Contains" statement to list all the food allergens present in the food product. If this statement is used, it must declare all the food allergens in the food. The statement must be shown at the end of the list of ingredients.

Example:

Ingredients: chicken, batter (water, modified cornstarch, wheat flour, salt, sodium bicarbonate, milk ingredients, guar gum), toasted wheat crumbs, seasoning, lemon juice with sulphites. Fried in hydrogenated soy oil.

Contains: wheat, milk, sesame seeds, soy, sulphites

The exemptions in the FDR sections B.01.008 (10) (Components of ingredients in a sandwich not required to be shown in list of ingredients) and B.01.009 (Components of ingredients or of classes of ingredients not required to be shown on label) do not apply to food allergens. Furthermore, if an ingredient under section B.01.009, FDR, is added in another pre-packaged food, any food allergen present in that ingredient must be declared.

Foods exempt from having a label [B.01.003 (a), FDR] or a list of ingredients [B.01.008 (2), FDR] are exempt from allergen declaration. For example:

• pre-packaged foods made and sold at the same retail store;
• pre-packaged sandwiches made at a commissary and sold through automatic vending machines or mobile canteens; and
• pre-packaged meat/poultry and meat/poultry by-products that are barbecued, roasted or broiled on the retail premises

To further assist consumers in making safe food choices, the CFIA requires manufacturers, importers and distributors to identify the plant source of ingredients, such as hydrolysed plant proteins, starches, modified starches and lecithin (e.g. hydrolysed soy protein, wheat starch, modified wheat starch, soy lecithin).

It has been demonstrated that "highly refined edible oils" are virtually devoid of proteinaceous material and, hence, it is generally agreed that such highly refined oils are unlikely to cause food allergies. It is the responsibility of the manufacturer, distributor or importer to demonstrate that the highly refined oils in their products do not contain allergenic proteins.

Precautionary Statements

Where priority food allergens may inadvertently be present in a food despite Good Manufacturing Practices (GMP), a precautionary statement, such as the ones listed below, must be used following the ingredient list, in both official languages.

Examples of precautionary statements:

• "may contain X"; and
• "not suitable for consumption by persons with an allergy to X" where X is the name by which the food allergen is commonly known.

When an allergen is likely to be present in a product, the use of precautionary labelling is not acceptable and the presence of the allergenic ingredient must be accurately declared on the label. For example, it would be acceptable to use a "may contain wheat" statement on a beef burger product where the product is processed on the same manufacturing equipment as another product and where there may be a possible transfer of wheat to the final product. It would not be acceptable to have a "may contain soy" statement on a pepperoni and cheese sandwich if the pepperoni contains soy. The label would have to indicate that the product does contain soy. The "may contain" statement is not allowed on a label of a food that sometimes contains a food allergen ingredient and sometimes does not; the allergen ingredient must be declared.

The CFIA recommends that precautionary statements on ingredients be transferred to the finished product if the finished product does not already contain the food allergen mentioned in the precautionary statement.

However, the manufacturer should fully investigate the necessity of the precautionary statement of the ingredient. Precautionary statements should be used only as a last resort, and must not be used in lieu of adherence to GMP.

More information on food allergens can be found on the following Web sites:

CFIA - Food Allergens: http://www.inspection.gc.ca/english/fssa/labeti/allerg/allerge.shtml

Health Canada - Food Allergies and Intolerances: http://www.hc-sc.gc.ca/fn-an/securit/allerg/index-eng.php

(c) Requirements for cured meat products

The declaration of ingredients of cured meat products, such as ham and bacon, shall be shown as follows on the label:

1. where the list of ingredients appears on the main panel, immediately below the name of the meat product, neither naming the kind of meat product nor repeating the name is required in the ingredient listing.

   Example 1: Smoked ham
   Cured with water, salt, sodium phosphate, sodium nitrite.

   Example 2: Bacon
   Artificial maple flavour added.
   Cured with water, salt, sugar, dextrose, sodium nitrite.

2. where the ingredient listing is not immediately below the name but located elsewhere on the label, a total list of ingredients, including the kind of meat product, becomes necessary following the word "ingredients".

   Example 1: Smoked ham
   Ingredients: ham, water, salt, sodium phosphate, sodium nitrite, smoke.

   Example 2: Bacon
   Ingredients: Pork, water, salt, sugar, dextrose, sodium nitrite, smoke, artificial maple flavour.

(d) Requirements for products where mechanically separated meats have been used

The declaration of ingredients for products where mechanically separated meats have been used shall be shown as follows on the label:

1. If more than one mechanically separated species meat is used in the meat block; e.g.

   species in meat block	per cent
   Mechanically Separated Chicken:	26.85%
   Mechanically Separated Pork:	20.00%
   Mechanically Separated Beef:	10.00%
   Mechanically Separated Veal:	9.55%
   Water:	22.60%
   Spices and Filler:	11.00%

   the ingredient list should read:
   Mechanically separated meat (Chicken, Pork, Beef, Veal) water, ...

2. If only one mechanically separated species meat is used in the meat block; e.g.

   meat in meat block	per cent
   Mechanically separated chicken:	25.85%
   Pork:	20.00%
   Beef:	10.00%
   Veal:	9.55%
   Water:	22.60%
   Spices and Filler:	12.00%

   the ingredient list should read:
   Mechanically separated chicken, pork, beef, veal, water, ...

3. If more than one mechanically separated species meat is used in the meat block as well as boneless meats, e.g.

   meat used in meat block	per cent
   Mechanically separated chicken:	12.85%
   Mechanically separated turkey:	10.00%
   Mechanically separated pork:	8.00%
   Beef:	18.00%
   Pork:	9.00%
   Beef by-products (plasma,tripes):	8.00%
   Water:	22.60%
   Filler and Spices:	11.55%
   (Total of ingredients):	100.00%

   where the mechanically separated meats represent, in total, the highest percentage of the meat block, the ingredients list should read:

   Mechanically separated meat (chicken, turkey, pork), beef, pork, beef by-products; water, ...

(e) Requirements for products to which smoke or smoke flavour was added

Smoke and smoke flavour are ingredients and must be listed accordingly. The following designation shall be used depending on how these ingredients were added to the meat product:

1. "naturally smoked" - the meat product was exposed to smoke generated from the direct combustion of hardwood, hardwood sawdust or corn cobs. This can be done either in the presence of heat or not; and/or
2. "smoked" - the meat product was treated with smoke derived directly or indirectly (i.e. liquid smoke) from hardwood, hardwood sawdust or corn cobs. In the case of liquid smoke, the term "smoked" shall be used only if the meat product was subjected to heat in the presence of a vaporized liquid smoke solution or when the meat product subjected to heat has been packaged in a casing or wrapping impregnated with liquid smoke; and/or
3. "smoke flavour" - this term shall be used when liquid smoke has been added to the meat product by methods other than those mentioned above, e.g. adding liquid smoke directly into the emulsion.

(f) Requirements for meat products wrapped in collagen or carrageenan films

The use of edible wrappings (e.g. collagen or carrageenan) in the preparation of meat products other than sausages must be declared at the end of the ingredient list. For example, the declaration "wrapped in carrageenan", "coated with carrageenan" or "wrapped in collagen" shall appear at the end of the ingredient list of hams wrapped in such material.

(g) Requirements for solid meat cuts to which meat particles have been injected with the brine

When a whole muscle cut has been injected with ground or emulsified meat particles (trimmings) in a proportion that is up to 15% of the fresh weight (green weight) of the meat at formulation, the label of the product does not need to indicate the presence of the trimmings. The calculation is done according to the following formula:

For example:

When a whole muscle cut has been injected with ground or emulsified meat particles (trimmings) in a proportion that exceeds 15% of the fresh weight of the total meat content (green weight) at formulation, the ingredients list of the product's label needs to indicate the presence of the ground meat (pork, beef or poultry). For example, "A proportion of ground ham added" or "Ground and emulsified beef trimmings added" or "Ground and emulsified poultry trimmings added" or an equivalent statement shall appear in the list of ingredients.

7.6.4 The name and address of the firm

Either the complete name and address of the firm that prepares the meat product, or, preceded by the words "prepared for", the name and address of the firm for whom the meat product is produced or labelled, shall appear on the label of meat products.

Foreign firms shall include the name of the country in the address, while firms in Canada may indicate either the province or Canada. Multi-establishment firms may show the address of the head office instead of the address of the establishment preparing the meat product.

If the address shown is the address of a person for whom the meat product was prepared, then the name and address shall be preceded by the words "prepared for".

Poultry carcasses packaged in a registered establishment for another registered establishment may bear the name and address of the receiving establishment. Hence the receiving establishment may send its bags to the packaging establishment without any label change. The establishment number on the closure clip shall be the number of the establishment packaging the carcasses. The words "prepared for" are no longer required in this instance.

7.6.5 The Meat Inspection Legend

(a) General requirements

The Meat Inspection Legend is a national trade-mark. Subject to the Meat Inspection Act, it is the exclusive property of the Government of Canada and may only be used as authorized by the Meat Inspection Regulations, 1990.

All labels used in connection with edible meat products produced in a registered establishment must include the Meat Inspection Legend, with the exception of labels of bulk containers of fully marked prepackaged meat products.

The Meat Inspection Legend, when placed on a label, shall have no transverse measurement through the centre of the legend of less than 10 mm and, where stamped or branded directly on a meat product, shall have no transverse measurement through the centre of the legend of less than 25 mm.

When the Meat Inspection Legend is applied to a natural casing it shall be legible. It is not practical to stamp sausages enclosed in natural casings that have a diameter of less than 5 cm.

In the case of sausages which are enclosed in natural casings and subsequently packaged in a fully marked container for retail sale (bearing all mandatory information), the stamping of individual casings is optional.

When wieners are sold "skin-on" in artificial casings, all mandatory information must be printed on the casings. In view of the small size of the sausage, it is permitted to spread the information over three consecutive wieners.

To satisfy stamping requirements, the Meat Inspection Legend shall be applied to an edible dressed carcass or portions derived thereof and to edible organs.

The Meat Inspection Legend may be applied to the meat product by means of:

• stamping or branding;
• a sealed bag on which the meat inspection legend is printed or applied by means of a sticker or an insert;
• a breast tag in the case of a poultry or domesticated rabbit carcass; or
• a container bearing all the mandatory requirements.

The Meat Inspection Legend contains the registration number of the establishment producing the meat product. However, it may be applied without the registration number where the meat product is packaged in:

1. a hermetically sealed container that is labelled as prescribed in paragraph 60(d) of the Meat Inspection Regulations, 1990;
2. a casing or bag closed by a metal clip, if the registration number is legibly engraved on the metal clip and is visible when the clip is closed, and is preceded by the abbreviation "EST"; or
3. a cardboard container, a corrugated fibreboard container, a bulk container or a plastic container, if the registration number is clearly marked elsewhere on the principal display panel or on a panel other than the principal display panel in the case of a prepackaged product, and is preceded by the abbreviation "EST".

(b) Use of a code on hermetically sealed containers to identify the establishment

Codes may be used on hermetically sealed containers to identify the registration number, the meat product and the date of production.

The use of a code in replacement of the registration number is permitted provided the code is placed in front of the production codes (i.e. meat product, date) and is followed by either a hyphen (-), an oblique (/) or a space clearly distinguishing the establishment code from the production code. If desired, the establishment code may be placed on a separate line, above the production code. If the registration number is used, the same conditions apply.

Examples:

OR

All operators wanting to use a code instead of the establishment registration number must provide the meaning of the code to the Registrar, Meat Programs Division, Canadian Food Inspection Agency, 1400 Merivale Road, Ottawa, Ontario, K1A 0Y9 for subsequent registration and distribution to all regional offices.

7.6.6 Storage instructions

All consumer and bulk containers used in connection with edible meat products in a registered establishment shall be labelled with storage instructions unless the meat contained therein is one of the following shelf-stable types:

1. commercially sterile meat products in cans, jars, or pouches (excluding pasteurised products);
2. dried meat products with a water activity (a_w) value of 0.85 or less;
3. meat products which have a pH value of 4.6 or lower;
4. meat products packed in a 100% brine solution;
5. fermented meat products that have a pH level of 5.3 or less and an a_w of 0.90 or less. It is understood that the pH of 5.3 or less is achieved at the end of the fermentation period; or
6. meat products for which the operator submitted to the Director, Meat Programs Division, a quality control program and supporting data demonstrating that the process is validated to produce safe products and to ensure shelf stability.

All edible meat products, not considered as shelf stable, prepared in a registered establishment shall be labelled with storage instructions which consist of one of the following statements: "Keep refrigerated" or "Keep frozen", whichever is applicable. Storage instructions may be in the check-off form on labels of all containers (prepackaged products) or shipping containers, with the appropriate instruction checked off. The storage instructions shall be shown on the principal display panel.

For certain types of institutional products, the following will also be acceptable: "Keep refrigerated if used before (date) or freeze immediately".

7.6.6.1 Durable life date statement

The words "Best Before" and "Meilleur avant" followed by the durable life date must appear on the label of a prepackaged meat product where the durable life of the meat product is 90 days or less, as prescribed in B.01.007 of the Food and Drug Regulations and in Section 94 of the Meat Inspection Regulations, 1990.

7.6.6.2 Production date and identification code of production lot

All meat products shall be labelled with the production date or with a code identifying the production lot. This code or date of production must appear on the immediate container of prepackaged meat products or on a tag attached to it. For a rapid identification of the product in the case of a recall procedure, it is recommended to add this code/date of production on the shipping containers of the prepackaged meat products. This information must also appear on the bulk containers of meat products. It is possible to use the durable life date statement (see 7.6.6.1) as an identification code of production.

7.6.6.3 Retained water declaration for raw single-ingredient meat products

The amount of water added and retained in raw-single ingredient meat products due to post-evisceration contact with water, in excess of naturally occurring moisture (refer to Chapter 19, sub-section 19.8.3 of this manual), must be declared as part of the product name on the principal display panel of prepackaged products or on shipping containers for non prepackaged product. Raw single-ingredient meat products include e.g. dressed carcasses, parts of dressed carcasses, offal and giblets.

Retained water may be rounded off to the nearest whole number. Retained water below 0.5% need not be declared. The permitted labelling variation is a maximum of 20 percent above the declared amount within the retained water statement.

Operators may include a "no retained water" statement on the label (optional) when no water added due to post-evisceration processing has been retained by the raw single-ingredient meat product.

Amended labels to add the moisture declaration statement may be approved locally by the Veterinarian or Inspector-in-Charge in consultation with area meat hygiene program officers. The following four phrases are permitted:

• "up to X % water retained";
• "less than X % water retained";
• "up to X % retained water added due to processing"; and
• "no retained water".

A submission to support a similar claim must be submitted by the operator to the Veterinarian or Inspector in Charge for evaluation by the area meat hygiene program labelling specialist before it is used.

A claim such as "no water added" is not permitted since it is misleading under section 5 of the Food and Drugs Act.

The moisture declaration must be part of the product description, shall be conspicuous and shall be not less than half of the product's common name or half of any additional mandatory information (e.g.: "with giblets").

Packages containing a variety of raw single-ingredient meat products (e.g. giblets) may be labelled by either:

1. listing a separate declaration for each component; or
2. a single declaration which indicates the maximum water retained by the components.

Dressed poultry carcasses and parts from dressed poultry carcasses, including detached necks and salvaged portions, are exempt from the requirements of this sub section pending amendments to section 25 (which sets standards for water retention in poultry carcasses) of the Meat Inspection Regulations. However, poultry carcases containing giblets (e.g. frozen turkeys) do require a retained water declaration as part of the product name for the giblets.

Ground meat including finely textured meat (FTM) and mechanically separated meat (MSM)

Ingredients used in the preparation of red meat species ground meat, FTM, or MSM, (e.g., as applicable, bone-in cuts, trimmings, head meat, hearts, tongues) which absorb and retain any water are nor permitted to be used in the preparation of red meat species ground meat, FTM or MSM. At this time, according to Canadian regulations, water cannot be added to these red meat species products.

Meat products treated with salt and water in accordance with Judaic law

Only water absorbed and retained as part of the Kosher process may be excluded from the retained water declaration provided that the product description contains the phrase "soaked and salted" or a similar phrase. The operator shall supply the Veterinarian in Charge with a letter, signed by a Rabbi serving the establishment, which clearly indicates which processing steps are part of the Kosher process.

Prepared Meat Products

Any retained water in raw single-ingredient meat products, used as ingredients, need not be declared on the labelling of prepared, including multi-ingredient meat products (e.g. raw or cooked sausage, pre-basted turkeys, or deli meats). However, such meat products must comply with applicable standards of identity or composition requirements for the specific prepared meat product as contained in Meat Inspection Regulations, the Food and Drug Regulations or this manual.

7.6.6.4 Nutrition labelling

The Nutrition Facts table (NFT) is mandatory for most prepackaged meat products. Some exemptions and exceptions exist.

The following products are exempt from displaying a Nutrition Facts table:

• raw, single ingredient meat, meat by-product, poultry meat and poultry by-products;

  Note: Prepackaged ground meat, ground meat by-product, ground poultry meat and ground poultry meat by-product must always carry a Nutrition Facts table [B.01.401 (3) (d), FDR];

• foods sold only in the retail establishment where the product is prepared and processed, including products made from a pre-mix when an ingredient other than water is added to the pre-mix; and
• individual servings of foods that are sold for immediate consumption (e.g., sandwiches or ready-made salads), when these have not been subjected to a process or special packaging, such as modified atmosphere packaging, to extend their durable life;

The exemption is lost when: [B.01.401 (3), FDR]

• a vitamin or mineral nutrient is added to the product or when it is declared as a component of an ingredient (other than flour); or
• the label contains one or more of the following:
  • a nutritional reference or nutrient content claim; and/or
  • a biological role claim; and/or
  • a health claim; and/or
  • a health-related name, statement, logo, symbol, seal of approval or other proprietary mark of a third party.

The nutrition facts table is voluntary on a label of a prepackaged meat product intended solely for use as an ingredient in the manufacture of other prepackaged products, or intended solely to be served in a commercial or industrial enterprise or institution. However, the nutrition information shall accompany the product when it is delivered to the purchaser in the manner described in B.01.404 and B.01.405, FDR.

More information on topics such as format and serving size can be found in the Nutrition Labelling Toolkit.

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