Steps for Determining the Type of Health Claim
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1. Is the product a food or a natural health product (NHP)?
Use Foods or Natural Health Products (NHP) to verify the status of the product. Depending on whether the product is a food or a NHP, it is subject to the Food and Drug Regulations or Natural Health Products Regulations respectively.
If the product is a food, continue to step two.
2. Does the claim refer to a Schedule A disease or meet the Food and Drugs Act definition of a drug?
Use Drugs vs. Foods to verify if the claim refers to a schedule A disease or is a drug claim. If yes, see Drug Representations and Premarket Approval to learn about their specific requirements such as obtaining a premarket approval in certain cases. Disease risk reduction claims (definition) or therapeutic claims (definition) must be based on sound scientific evidence that has established a relationship between certain elements of healthy diets and the reduction of risk of developing certain diseases.
Example of a disease risk reduction claim, "[Naming the food or food constituent] may reduce the risk of cardiovascular disease".
If this is not the type of claim being made, continue to step three.
3. Does the claim refer to a relationship between an ingredient and a function of the body?
Function claims (definition) relate to the specific beneficial effects that the consumption of a food or a constituent of a food (nutrient or other component) has on the normal functions of the body. For example, "[Naming the food or food constituent] promotes regularity or laxation".
If yes, see Function Claims to learn about their specific requirements.
If this is not the type of claim being made, continue to step four.
4. Does the claim refer to a relationship between a nutrient and a function of the body?
Nutrient function claims (definition) describe the well-established roles of energy or known nutrients that are essential for the maintenance of good health or for normal growth and development. For example, "Milk is an excellent source of calcium which helps build strong bones and teeth".
If yes, see Nutrient Function Claims to learn about their specific requirements.
If this is not the type of claim being made, continue to step five.
5. Does the claim refer to a relationship between probiotic microorganisms/prebiotic(s) and health benefits?
Probiotic (definition) claims are statements about the nature of the probiotic microorganism that is generally required in supporting the health effects or benefits of these microorganisms. For example, "Probiotic that contributes to healthy gut flora".
The use of the term prebiotic(s) (definition) is part of a statement that describes the specific and measurable health benefits conferred by the prebiotic substance. For example, "Prebiotic X increases calcium absorption".
If this is not the type of claim being made, continue to step six.
6. Does the claim refer to healthy eating patterns?
General health claims (definition) are broad claims that promote health through healthy eating or that provide dietary guidance. For example, "The consumption of [Naming the food] which is low in fat is part of a healthy diet".
If yes, see General Health Claims to learn more about their specific requirements.
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