Chapter 7 - Packaging and labelling

7.7 Non-mandatory information on labels for edible meat products in registered establishments

(a) Pictorial representation (vignette)

A pictorial representation (vignette) may be used on containers of meat products, provided such pictorial representations are neither false nor misleading as to the character and value of the contents. (See Section 5 of the Food and Drugs Act, Section 7 of the Consumer Packaging and Labelling Act and subsection 94(7) of the Meat Inspection Regulations, 1990.)

Each vignette will be evaluated on its own merit.

(b) Suggested serving

On a vignette which illustrates a food that is not part of the package and could be misleading to consumers, the words "Suggested Serving" shall be placed in proximity to the vignette. This indicates that the vignette provides a serving suggestion and does not represent the exact content of the package.

(c) Product of Canada, Made in Canada

As of December 31, 2008, a revised definition and guidelines for "Product of Canada" and "Made in Canada" came into effect.

Guidelines on the use of "Product of Canada" or "Made in Canada" statements are found in Chapter 4 of the Guide of Food labelling and Advertising. The issue of beef made from animals born in the U.S. but having resided for 60 days or more in a Canadian feedlot, was addressed, as an interim measure, in July 2011 - refer to the guideline document above.

Some importing countries make it a mandatory requirement that the wording "Product of Canada" be shown on the label used in connection with exported meat products. It is the exporter's responsibility to comply with the requirements of importing countries.

(d) Trade marks and brand names

Trade marks and brand names may be used on labels of meat products in registered establishments. The use of the usual symbols associated with trade marks (e.g. ®, T.M. [trade mark] or Reg'd T.M. [registered trademark]) are also acceptable in close proximity to a trade mark. It should be pointed out however that the mere registration of a trade mark by the Trade Marks Branch of Industry Canada does not entitle an operator to use the registered trade mark in connection with all labels of meat products. It will be the responsibility of the operator to comply with the spirit of Article 5 of the Food and Drugs Act and Article 7 of the Consumer Packaging and Labelling Act in regard to the use of trade marks and brand names. Any label registration granted does not extend to the trade mark.

(e) Claims regarding fat content in meat products

Claims such as "Contains not more than x% fat" or "Contains less than x% fat" are acceptable. The operator shall substantiate that his claim reflects the composition of the finished product and the label must comply with nutritional labelling. Labels with claims such as ABC packers lean or extra lean ham are not considered acceptable.

Ground "meat" must be identified by one of the following claims, depending on the fat content: regular, medium, lean or extra-lean (see 7.6.1(a) for details).

"Lean" or "extra-lean" claims may be made for meat cuts and prepared meat products provided they comply with the following nutrition labelling requirements for the terms "lean" and "extra-lean":

  1. "Lean" and "extra-lean" meat products shall contain 10% fat or less and 7.5% fat or less respectively;
  2. the actual content in fat shall be indicated on the principal display panel in %; and
  3. the nutrition information shall be shown on the package in one of the following manners (not necessarily on the principal display panel):
    grams (g) of fat per serving (90 g - 130 g); or

    example of a nutrition label from the Health Canada Web site that shows calories, fat, cholesterol, sodium, carbohydrates, protein, vitamin A, vitamin C, Calcium and Iron

    For example: Lean "name of the meat cut or prepared meat product"

    * contains 8% fat
    ** each portion of 100 g contains 8 g of fat
    * shall appear on the principal display panel of the label
    ** may appear elsewhere than the principal display panel

Note: It is not permitted to label the product "Lean (name of the meat cut or prepared meat product)" with the claim "92% fat free" (instead of "contains 8% fat").

For additional information on claims, please refer to the "Guide to Food Labelling and Advertising".

(f) Use of the term "air chilled" for poultry

The use of the term "air chilled" is permitted for poultry refrigerated in this way, provided the establishment has implemented a control program to show that there is no moisture gain as a result of post evisceration washing, chilling and drainage (see Chapter 19, section 19.8.4). Also claims such as "no water absorption" or "no added water" or similar phrases are not acceptable.

Claims such as "no water added during the air chilling process" are permitted if the poultry is air chilled and the Operator demonstrates through a quality control program and data that there is no more than 0.5% of water retained (to account for the scale variability) post evisceration (i.e., green weight is before inside-outside washer and final weight after chilling process for poultry and before final wash and after refrigeration but before shipping for red meat).

7.7.1 Method of production claims - evaluation procedures

In addition to registering prepared meat product labels and recipes, the Label and Recipe Registration Unit (LRRU), Operations Branch, CFIA, evaluates and registers all single ingredient meat and poultry products from federally registered establishments where animal production-related claims are made. Currently, this includes claims such as "Organic", "Raised Without Antibiotics", "Raised Without Added Hormones, Vegetable Grain Fed - No Animal By-Products" and "No Animal Meal, No Animal Fat". Claims need to be substantiated by submitting a protocol and audit report to the LRRU for verification.

The LRRU will evaluate the submission and upon acceptance will register any submitted labels bearing these claims. It is important that the requirements of the Meat Inspection Regulations, 1990, section 94 (7) and the Food and Drugs Act, section 5 (1) be respected. Failure to meet these requirements can result in legal liability on the part of the registrant.

The use of animal production claims is optional. If such claims are made, production protocols must be developed to ensure validity of the claim. The petitioner will need to develop a detailed protocol including the origin and identification of the animals in question, husbandry, and processing practices, and provide the results of a third party audit to verify the protocol, all of which is described in more detail in the subsections to follow.

Under no circumstance will any claim be accepted if the program is not effective or has not been implemented as written. All documents pertaining to the applicant's protocol must be made available to a CFIA inspector upon request.

7.7.1.1 Animal production claims

a) "Organic"

As of June 30, 2009, the Organic Products Regulations require mandatory certification to the revised National Organic Standard for agricultural products represented as organic in international and inter-provincial trade, or that bear the federal organic agricultural product legend (or federal logo).

The Label and Recipe Registration Unit will consult the Organic Office lists to determine if the applicant is on the list of certified producers prior to approving any organic label.

b) Other claims

An applicant may choose to apply for a production raising claim without being identified as Organic. A single claim or multiple claims may be applied for. Other animal raising claims include, but are not limited to, "Grain Fed - No Animal By-Products", "No Animal Meal, No Animal Fat", "Raised Without Hormones", and "Raised Without Antibiotics". In the case of the "Raised Without Antibiotics" claim for meat and poultry products, this will be acceptable provided the animals were not administered any medication that could fall in the definition of an antibiotic or have the same purpose, for example, coccidiostats or monensin.

Approved substances include vaccines registered by the Veterinary Biologics Section or direct fed viable microbial products registered by the Feed Section of the CFIA. Vitamins and minerals at nutritional levels and other nutritive and non-medicating substances commonly found in feed would also be permitted under such claims. A "Grain Fed - No Animal By-Product" claim would be accepted provided the company has procedures in place to ensure no animal by-products (such as animal fat, animal meat meal, etc.) are in the feed. Vitamins must be completely free of gelatin originating from animals.

c) Species-specific claims

If a claim is made on a label, as an effort to gain market share, that the product is originating from a certain species or sub species, the protocol and proof of origin and segregation of the animals used to create the product must be provided along with the label registration. Examples of this would include but are not limited to Angus Beef, Wagyu (Kobe Beef), Peking Duck, Muscovy Duck, North American Bison, wild boar.

7.7.1.2 Production protocol

A complete and verifiable control program must be in place to support the claim. It must be organized to be auditable and cover all the elements and steps relative to the claim. This program may be called the production protocol and must include:

  1. Steps to ensure the validity of the claim, including control programs for the cow/calf operation, hatchery/nursery, feedlot, the feed mill, the ingredient supplier (for the feed), feed transport, the producer, the slaughterhouse, the processing plant, and the live animal transport companies.
  2. Submission of a certificate by a feed mill (in the case of claims pertaining to feed contents e.g. "Grain Fed - No Animal By-Products"). The vitamin and mineral ingredients are of particular concern since traditional feeds contain vitamins and minerals encapsulated in animal by-product derived gelatine. Non-animal origin gelatine sources exist and must be included in the submitted protocol if gelatine is to be used.

7.7.1.3 Labels

Labels for all products being considered under the "claim" need to be submitted to the LRRU for evaluation using form CFIA/ACIA 1478 - PDF (71 kb). This form is available through the CFIA Web site at:
http://www.inspection.gc.ca/DAM/DAM-food-aliments/STAGING/text-texte/c1478_1330115026053_eng.pdf

The labels must be submitted using this process after the production protocol has been received and reviewed by the LRRU, including results of initial audits.

7.7.1.4 Audits

a) Audit reports

Audits by a third party are mandatory. A third party audit must ensure the protocol is implemented as written and is effective on-site.

The audits must follow the common principles found in the Meat Hygiene Manual of Procedures, the On-Farm Food Safety program, HACCP, ISO 9000, ISO Guide 62, and the CFIA documents concerning the Food Safety Enhancement Program (FSEP).

In the case of animal feed containing no animal fat or animal meal, in addition to certification of the ingredients, verification by a third party is required to ensure the suitability of the operations and that the program is effective.

The goal is to have proof that the feed mill is using the same process of manufacturing as a mill operating under the FSEP. The audit must be documented and a copy of this report must be submitted with the protocol to the LRRU.

The CFIA wants to ensure that these audits provide the same results and information as though the CFIA had conducted its own audit (refer to the standard ISO 10011 and the FSEP Manual for more details).

The choice of the auditor to be contracted with is the responsibility of the company that is making the claim.

The auditor(s) must have the necessary qualifications in order to conduct a third party audit, including knowledge of the common principles listed above.

The CFIA requires that the qualifications of the chosen auditor(s) be supplied to the LRRU as well as the report of the audit and any Corrective Action Request (CAR). The CFIA reserves the right to oppose the use of a claim on a label if it concludes that the audits were not undertaken in a suitable manner.

The CFIA retains a list of self-identified available third-party auditors for any company that wished to utilize it. This list is not meant to be exhaustive, and a company may pick any suitable person and need only show to the satisfaction of the CFIA that the auditor is qualified to do the job.

b) Frequency of audits

An initial audit must be conducted and all major CARs must be resolved before being able to use the desired claim. Should any major CAR be identified, an immediate follow-up audit is required.

A Verification Audit will take place on those CARs as soon as the CAR(s) is/are satisfied and then a maintenance audit will occur 6 months following the Verification Audit.

Provided there are no major non-conformities occurring, an audit will follow 12 months after the initial audit, and thereafter audits will be once annually.

If, during any annual audit, minor non-conformities are detected in the system, there will be no Verification Audit. However, the CAR must be satisfied prior to the next annual audit.

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