Composition and Quality Claims
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Pure, 100% Pure, 100%, All
The term "pure" should not be used on the labels of, or in connection with, an article of food that is a compound, mixture, imitation or substitute. Consumers expect a food described as "pure" or "100% pure" to be uncontaminated and unadulterated, and to contain only substances or ingredients that are understood to be part of the food so described.
For example, consumers do not expect a product described as "100% pure corn oil" to contain any substance other than corn oil. Therefore, the claim is not appropriate on a food that contains any preservatives, antifoaming agents or colour even though the standards may permit them. In some cases, this claim is considered to be synonymous with the claim "contains no preservatives". Guidance on the use of such claims is outlined under Negative Claims Pertaining to the Absence or Non-Addition of a Substance.
The term "pure" or "100% pure" can be used to modify an ingredient name appearing in the common name of a food such as "pure vegetable oil" or "pure vegetable oil margarine". The claim can also be worded so that it refers specifically to a named ingredient in the food. The claim "made with pure corn oil with added preservative" implies that the corn oil used was pure, before the preservative was added to the final product.
Similarly, consumers expect that a product described as "100% pure pork sausage" would contain only meat originating from hogs and that the pork portion would contain no additives or contaminants (i.e., that the pork in the sausage is pure). However, although it would acceptable to describe single-ingredient foods or specific ingredients in a food as "pure" or "100% pure", products like the sausage that are not single-ingredient foods should not be described as "100%", "pure" or "100% pure". For example, the claim "100% pure sausage" is unacceptable.
In a few cases, however, it may be possible to describe a standardized multi-ingredient food as "pure" on condition that:
- none of the optional ingredients permitted by that standard are added to the food, and;
- the common name allowed and used to describe the food includes the names of all the ingredients of the food.
For example, "pure sweet milk chocolate" would be expected to be made only with pure sugar, pure fluid whole milk and pure chocolate.
For reconstituted orange juice, "pure" or "100% pure" can be used on the label of the reconstituted product to describe the product if only water has been added to the concentrate. "Pure" or "100% pure" cannot be used on the label of a reconstituted product if any optional ingredient such as sodium benzoate, sugar, colour, vitamin C, etc., is incorporated into the concentrate.
In all cases, the terms "all", "pure" or "100% pure" must be used with care. If these terms are used in such a way as to imply that other similar products are adulterated or not up to standard, then the use of these terms could be construed as being misleading.
Entirely, Completely, Absolutely
Although these terms are often redundant in normal usage, they may nevertheless alter the meaning of statements and claims. Generally, claims may be made when the food meets the criteria for that claim. However, in some cases, the criteria for a claim provide some tolerance. When claims are modified by a term such as "entirely", the tolerance, in effect, ceases to exist.
For example, the claim "Canadian" is synonymous to a "Product of Canada" claim, in which case all or virtually all major ingredients, processing, and labour used to make the food product must be Canadian. Ingredients that are present in the food at very low levels and that are not generally produced in Canada would be permitted provided that these ingredients amount to generally less than a total of 2 per cent of the food. For a food with the claim "Entirely Canadian", this allowance would no longer apply; all ingredients, processing and labour would be expected to be Canadian.
For additional information on the use of claims such as "Canadian" or "Product of Canada", see the Guidelines for Product of Canada and Made in Canada Claims.
True, Real, Genuine
Terms such as "true", "real", "genuine" are composition claims about a product or its ingredients. It is not acceptable to use such terms to describe foods or ingredients that are imitations or substitutes.
Claims that describe an ingredient within a food as "true", "real", "genuine" or any similar term such as "Made with Real [naming the ingredient]" are acceptable if the named ingredient is present in the food, regardless of what form (e.g., frozen powdered, ground, concentrated, etc.) For example, a box of frozen waffles that claims "contains real blueberries" must actually contain real frozen blueberries.
Concentrated, Concentrate, Condensed, Strength, Reconstituted
In general, it is not acceptable to use the above terms in a way that implies nutritional superiority.
The terms "concentrated", "concentrate" or "condensed" may be used to describe products still in the liquid state after a substantial amount of water has been removed, for example, "condensed milk".
The terms "dehydrated", "dried" or "powdered" are more appropriate when the removal of the water results in a product that is no longer in a liquid state, for example, "powdered whole milk". Dehydrated fruits and vegetables and products such as soup mixes or bases are not regarded as "concentrates" or as being concentrated.
A claim that a food is "concentrated" or "condensed" or a statement pertaining to "strength" is considered acceptable when there is a recognized standard with which to compare the product. "Concentrated orange juice" or "double strength vinegar for manufacturing purposes" are examples of correct usage.
Foods restored to their original moisture content must be described as "reconstituted" or as "made from concentrate" as part of the common name of these products.
A manufactured product requiring dilution as directed on the label before it is in a form ready to be consumed may be described, under special circumstances, as "concentrated", "concentrate" or "condensed", even though no water has been removed during processing. For example, concentrated liquid infant formula and condensed soup fall within this category.
Some common names, by definition, connote "concentration" or "strength", and should not be further modified by words such as "concentrated" or "condensed". For example, the word "instant" in the common names "instant coffee" and "instant tea" implies that these products require water to be added prior to consumption. Therefore, it not appropriate to further describe these products as "concentrated". Similarly, syrups should be described by a declaration of the actual amount of sugar present, rather than by the less informative term "strong".
A product is not necessarily "strong" or "concentrated" because it contains a relatively large amount of one constituent. A pudding, for example, is not "concentrated" merely because a new formula calls for 15 percent milk solids instead of 5 percent, nor is cheese a "concentrated milk".
A powdered product is not a concentrate solely because it has been made to occupy less volume than the similar product it replaces. There can be no effect of concentration when, based on mass, the same amount of each product is needed to reconstitute or prepare for normal use. Agglomerated instant coffee, for example, is not "concentrated instant coffee".
The term "vegetarianism" generally refers to the practice or theory of living on a diet made up of plant foods such as fruits, vegetables, grains and nuts, and may sometimes include animal products not derived from slaughter such as eggs, milk and cheese. Animal products resulting from slaughter, such as animal/fish flesh, bone, stock, fats, gelatin, etc. are not, by definition, included in a vegetarian diet.
While strictly speaking, a vegetarian food is one made from only plant-based ingredients, it is recognized that several types of vegetarian diets exist. Therefore, the CFIA will not object to the general term "vegetarian" to describe foods that are suitable for any one of the following types of diets:
- Lacto-ovo (or Ovo-lacto)-vegetarian - permits plant foods plus dairy and egg
- Lacto-vegetarian - permits plant foods plus dairy, no eggs
- Ovo-vegetarian - permits plant foods plus eggs, no dairy
- Vegan - permits plant foods only
If any of the specific vegetarian claims above are being made on a food, the food is expected to contain only ingredients derived from the sources included in that type of vegetarianism.
Highlighted Ingredients Claims
Under Section 7 of the Consumer Packaging and Labelling Act (CPLA), it is considered false or misleading to use any expression, word, figure, depiction, symbol or other device that implies that an ingredient is present when it is not, or that implies an ingredient is not present when it is present.
Ingredients that are not present in a food may not be illustrated on the label of the food or in an advertisement unless it is made clear that the ingredient is not a part of the food.
It is misleading to over-emphasize the importance, presence or absence of an ingredient or substance in a food because of its desirable or undesirable qualities, or for any other reason.
For example, it is misleading to over-emphasize the presence of wheat germ in breakfast cereal when the amount present is the amount normally found in the grain used in making the cereal. Also, it is misleading to over-emphasize the presence of butter in a cake when butter is actually the minor shortening ingredient.
In principle, any emphasis regarding the presence of an ingredient, component or substance should be accompanied by a statement regarding the amount of that ingredient, component or substance present in the food.
Minute or Trace Ingredients
To avoid creating an erroneous impression, food labels and advertisements must not stress (by analytical tables or otherwise), the presence of elements or substances found in minute or trace quantities. Other than as required or permitted in the Nutrition Facts table, mineral nutrients in trace quantities in foods should not be declared except in the case of mineral water, where the amount of each "mineral" present may be stated, providing this declaration is not over-emphasized. For more information, refer to Mineral Water, Spring Water and Bottled Water.
Descriptions with Characterizing Ingredients
Care must be exercised in the use of the words "butter" and "cream" in the name of a food or in descriptions relating to that food. These words should not be used to describe a food that is or has been made, in part, of cream or butter, unless the food contains an amount of cream or butter sufficient to characterize the product.
- If butter is the sole shortening agent, the term "all butter" may be used as part of the common name (e.g., "all butter cake").
- If butter is the major shortening agent employed, the term "butter" may be used as part of the common name. However, the impression should not be created that the product contains solely "butter" as the shortening agent (e.g., "butter cake" is acceptable).
- If butter is a minor shortening agent but is still present, the term "butter" alone should not be used as part of the common name. However, "butter flavour(ed)" may be used (e.g., "butter flavoured cake") or the amount of butter present may be stated.
When it is clear that the terms "butter", "cream" or "creamy" refer to texture, form, colour, etc. and not to the butter or cream content of a food, their use may be acceptable, e.g. peanut butter, cream eggs, Bavarian cream pie, apple butter, chocolate creams.
Similarly, "malted" must be used with care. A food is not "malted" simply because malt extract has been added. "Malted" means that the carbohydrate has been modified by suitable treatment with the diastase of malt. Unless such treatment has been given, "malt flavoured" is the appropriate term to use.
Negative Claims Pertaining to the Absence or Non-Addition of a Substance
A negative claim is a statement about:
- the absence of a particular ingredient, substance or class of substances in a food because the substance is not inherent to the food;
- a substance that is not present in the food either through direct addition or through carry-over; or
- a substance that has been removed from the final food.
Conditions for making a Negative Claim
Claims to the effect that a food does not contain an ingredient or substance must be factual and not misleading. Generally, a negative statement pertaining to the absence or non-addition of a substance to a food is acceptable under the following conditions.
Absence or insignificant level
The ingredient, substance or class of substances claimed to be absent, must be totally absent and must not have been added directly or indirectly to the food or to any of its ingredients or components. Where industry wishes to make a negative claim based on a physiologically insignificant level, the claim must be justified: appropriate research and analytical data should demonstrate both that the level is appropriate, and that any residual amount of the substance claimed to be absent is below this threshold and is declared on the label.
The maximum acceptable level is defined as:
- zero for allergens and gluten sources that are intentionally added (and less than 20 ppm for gluten sources that are the result of cross contamination; see CFIA's Compliance and Enforcement of Gluten-Free Claims.
- the level of physiological insignificance such as those levels which act as the basis of nutrient free claims as described in the table following section B.01.513 of the Food and Drug Regulations (e.g., sodium free); and
- the non-detectable limit using an acceptable methodology, in cases where no physiological thresholds have been established.
Since physiologically insignificant levels for many substances are not well documented, case-by-case assessment will be required. Submissions should be made by industry, with the appropriate literature review and supporting scientific data, to Health Canada and CFIA.
Factual statements must not give an erroneous impression about the product's composition and quality.
For example, a "no added water" claim for a pasta sauce where water has been added indirectly as inherent water in another ingredient gives an erroneous impression about the product's water content as compared to other pasta sauces. To avoid misrepresentations of this kind, it is recommended that positive (rather than negative) claims must be made, such as "made from fresh tomatoes".
A negative statement should not create a false impression that the product is uniquely different from other similar products. For example, when a class of foods is inherently free of a substance or where it is not permitted by Regulation to contain the substance, this must be made clear. A claim that the substance is absent will be considered misleading unless it is appropriately qualified by a statement to the effect that the claim is not unique to the food but is common to all foods of the same class [5(1), FDA].
However, the information that a substance is absent in a food may be beneficial information to individuals who wish to avoid certain substances. Therefore, negative claims are accepted, but only under circumstances that reduce the potential for misrepresentation.
For example, a "no colour added" claim for wieners suggests that other wieners may contain colour when, in fact, colour is not permitted to be added to wieners. However, it is acceptable to state: "No wieners sold in Canada contain added colour."
Similarly, beverages that are not permitted by Regulation to contain added caffeine, such as juice, could not be labelled or advertised as "caffeine-free", unless the claim is accompanied by a statement to the effect that "all juices are caffeine-free", or that a juice is "a caffeine-free food".
Conversely, as there is nothing in Regulation that prohibits the addition of colour to cookies, it would be acceptable for such an unstandardized product to carry a "no colour added" claim without the claim being accompanied by a statement such as "all cookies have no colour added", provided that no colour was added, directly or indirectly, to the product. When placed on a package of cookies, this claim does not suggest a false uniqueness to the cookies, as some cookies do contain added colour.
Compliance with this policy will be assessed on a case-by-case basis.
Examples of Negative Claims
No Preservatives Claims
Claims pertaining to the absence or non-addition of a food class such as "contains no preservatives" and "no preservatives added" are permitted where none of the preservatives found in Health Canada's Lists of Permitted Food Additives have been directly added or none are present due to carry-over.
For example, it would be misleading to make a "no preservative" or "no preservative added" claim in bakery products if sodium propionate were added indirectly through a dough-conditioning premix.
There is no objection to claims for the absence of preservatives when the food contains naturally-occurring constituents that can provide a preservative function (e.g., naturally-occurring benzoates in cranberry juice, acetic acid in vinegar and citric acid in lemon juice, etc.).
Ingredients such as cultured whey, cultured dextrose, cultured skim milk, etc., can be specifically manipulated to contain high levels of peptides and propionic, butyric and lactic acids. These ingredients can act as preservatives. If foods contain these ingredients, claims pertaining to the absence of preservatives are not appropriate. Traditional preservatives such as salt and sugar are exempt from this policy.
For example, ascorbic acid is added to apple juice to preserve the colour of the juice during processing. It degrades to very low or insignificant levels, but despite this degradation, this additive has already performed its preservation function. Therefore, a "no preservative" claim is not considered appropriate for the final product.
No Preservative Claims for Multi-Functional Additives
Certain food additives such as ascorbic acid, acetic acid, citric acid, lecithin and tartaric acid are capable of performing a number of functions. Acetic and tartaric acids may be used as acidulants or anti-microbial agents to preserve a food. Where they are added for reasons other than preservation, and their function is clearly stated in the list of ingredients, a "no preservatives" claim is acceptable.
If a non-preserving additive is carried-over into the final food by way of an undeclared component, the claim can still be made and an explanation of its function need not be stated.
For example, ascorbic acid is a multi-functional additive that is often used in bakery products for its dough-conditioning property at levels of less than 100 ppm. In these cases, ascorbic acid is not added for its preservative function, so the claim "contains no preservatives" is acceptable, provided the function of the ascorbic acid is clearly stated, e.g., "ascorbic acid (dough conditioner)". Other examples include "lecithin (an emulsifier)" and "citric acid (acidulant)".
Note: For labelling purposes, liquid smoke is not considered to be a preservative.
No Monosodium Glutamate (M.S.G.) Claims
Consumers may believe that monosodium glutamate (M.S.G.) is the sole source of concern in food sensitivity reactions to glutamates. This is misleading. Foods that are inherently high sources of free glutamates may also be of concern. The Federation of American Societies for Experimental Biology (FASEB)Footnote 1, in its report on adverse reactions to monosodium glutamate, concluded that there is no difference in the physiological response to man-made and natural glutamates.
Claims pertaining to the absence or non-addition of monosodium glutamate such as "contains no M.S.G.", "no M.S.G. added" and "no added M.S.G." are considered misleading and deceptive when other sources of free glutamates are present. These include hydrolysed vegetable protein, soya sauce or autolysed yeast extracts. In addition, a number of common food ingredients contain high levels of naturally-occurring free glutamates, including tomatoes and tomato juice, grapes and grape juice, other fruit juices, cheeses such as Parmesan and Roquefort, and mushrooms.
For example, a claim for the absence of M.S.G. is not acceptable on a tomato-based pasta sauce unless the responsible party can prove, using an acceptable methodology, that there are no detectable glutamates in the product.
Lactose-Free and Lactose Reduced Claims
Claims relating to the presence or absence of lactose in a product are not prohibited under the Food and Drug Regulations (FDR) [Section B.01.502(2)(d), FDA]. However, there are no criteria set out in the regulations for these statements. The CFIA uses the following guidelines for lactose claims:
- Lactose- free means that there is no detectable lactose in the food using an acceptable analytical method.
- Lactose reduced may be used to describe a product that has been reduced significantly in lactose. A significant reduction is considered to be a 25% reduction or more.
For more information on common names for lactose-free products please see: Common names for lactose-free dairy products.
Non-Dairy or Dairy-Free claims
The claim "non dairy" or "dairy-free" cannot be used for products containing milk derivatives such as caseins, or sodium caseinate.
The word "dairy" when used as an adjective generally means "made from milk". Caseins and sodium caseinate are milk derivatives. It is misleading to claim a product is "non dairy" or "dairy-free" when it contains a milk ingredient or derivative or made from these ingredients. The following are some examples of milk ingredients and derivatives:
- butter, butter oil, milk fat
- caseinate (ammonium/calcium/magnesium/potassium/sodium)
- casein/rennet casein
- hydrolyzed casein, hydrolyzed milk protein
- cheese, cheese curds
- lactalbumin/lactalbumin phosphate
- lactate (when made from milk ingredients)
- milk, skimmed milk, partially skimmed milk, cream, buttermilk
- sour cream, sour milk solids
- whey, whey butter, whey cream , whey protein concentrate
- delactosed/demineralized whey
- Simplesse® (whey protein concentrate-microparticulated fat replacers)
Claims Referring to the absence of a Nutrient
Claims like "energy-free", fat free or "no sugar added" can be made if they meet certain criteria. Refer to Nutrient Content Claims for more information about these negative claims.
A health claim about a non-cariogenic substance is possible under some circumstances. See the Disease Risk Reduction Claims Table for more information.
Other Negative Claims
Other negative claims may be acceptable. Follow the links below for more information:
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