Health Claims
Nutrient Function Claims

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Nutrient function claims (definition), a subset of function claims, describe the well-established roles of energy or nutrients that are essential for the maintenance of good health or for normal growth and development.

Nutrients include carbohydrate, protein, fat, fatty acids, sugars and the vitamins and minerals listed in Division D, Food and Drug Regulations. Additionally, substances recognized as nutrients by the Institute of Medicine of the National Academies of Science, Washington, D.C. are considered nutrients. Other food components, such as lycopene, lutein, anthocyanins and other compounds found in foods are not considered nutrients for labelling purposes.

Conditions of Use for Nutrient Function Claims

Provisions for nutrient function claims are made in B.01.311, D.01.006 and D.02.004 of the FDR.

No Drug Representations for Nutrient Function Claims

Nutrient function claims may not refer to the treatment, prevention or cure of a Schedule A disease; or claim to treat, mitigate, or prevent a disease, disorder or physical state; or claim to correct, restore or modify an organic function [3(1) and 3(2), FDA]. Such claims are considered to be drug claims (see Drugs vs. Foods).

Language Requirements for Nutrient Function Claims

Nutrient function claims must be present in both English and French unless a bilingual labelling exemption applies to the product [B.01.311(5) and B.01.012(3) or (7), FDR].

Declaration of the Amount of the Nutrient

Whenever a nutrient function claim is made, the consumer must be informed as to the amount of energy or nutrient present in a serving of the food. This may be achieved through a declaration in the Nutrition Facts table (NFT) or in a quantitative statement outside the NFT; the manner in which the information is provided depends upon a number of factors described below [B.01.311(4), B.01.401(3)(e), D.01.004(1)(c) and D.02.002(1)(c), FDR].

1. Nutrition Facts Table

When a nutrient function claim appears on the label of a prepackaged food or in advertisements placed by or on the direction of the manufacturer of the food, the label of the food must declare a Nutrition Facts table (NFT) [B.01.401, FDR]. Foods that are normally exempt from declaring a NFT lose their exemption and are required to declare a NFT containing the energy value or nutrient value that is the subject of the claim. See Reasons for losing the exemption [B.01.401(3)(e)(ii), FDR].

2. Quantitative Statement for Nutrient Function Claims

Information for Prepackaged Products and Advertisements Placed by the Manufacturer

The Regulations also permit nutrient function claims to be made for nutrients other than those permitted in the NFT, e.g. essential fatty acids such as DHA. In these cases, a quantitative declaration of the amount of the nutrient(s), in grams per serving of stated size, must appear on the label of the food [B.01.311(4), FDR].

Information for Non-Prepackaged Products or Advertisements Placed by Someone Other than the Manufacturer

When a nutrient function claim appears on the label or in an advertisement for a non-prepackaged product or in an advertisement for a prepackaged product not made or placed by or on the direction of the manufacturer or importer, the quantitative amount of energy or nutrient present, shall be declared per serving of stated size and shall appear on the label or in the advertisement, where the claim is made.

The quantitative value shall be expressed in calories in the case of energy; in percent Daily Value for vitamins and minerals nutrients; in milligrams for potassium, sodium, and cholesterol; and in grams for any other case. [B.01.300, B.01.311(3), B.01.312, D.01.004(1)(c), D.02.002(1)(c), FDR]

See Advertisements for Nutrient Function Claims below for more information regarding quantitative statements in television and radio advertisements.

See Nutrient Content Claims for more information on quantitative statements.

Food vs. Nutrient

Nutrient function claims are not made for a food per se; they may only be made respecting the energy value or nutrients in a food. For example, the nutrient function claim "Milk helps build strong bones and teeth" is unacceptable, because a nutrient function claim refers to the nutritional function of energy or a nutrient (e.g., calcium) in a food, not a particular food (e.g., milk). An acceptable claim is "Milk is an excellent source of calcium which helps build strong bones and teeth".

Specific Requirements

Additional requirements must be met for the following nutrients function claims.

Protein [B.01.305(1), FDR]

When nutrient function claims are made for protein, the food must meet the requirements for the "source of protein" claim, which includes having a minimum Protein Rating (PR) of 20 (See Item b of Summary Table of Protein Claims).

Vitamin and Mineral Nutrients [D.01.004, D.02.002, FDR]

When nutrient function claims are made for vitamin and mineral nutrients, the vitamin or mineral nutrient must have an established Recommended Daily Intake (RDI). The food must contain a minimum of 5% of the RDI for the vitamin or mineral stated in the claim (i.e. being at least a dietary source of the nutrient). Recommended Daily Intakes for vitamins and mineral nutrients are found under Recommended Daily Intake (RDI). The percent Daily Value (% DV) of the vitamin or mineral nutrient that is the subject of the claim must appear in the Nutrition Facts table, if not already required.

Acceptable Nutrient Function Claims Table

Note that when a nutrient function claim is made for a nutrient, the food is not required to be a source of that nutrient unless it has an established "source" claim criteria, as listed above for protein and vitamin and mineral nutrients.

Nutrient function claims can also be made about a nutrient that is not a core nutrient (listed in B.01.401, FDR) nor an "additional" nutrient (listed in B.01.402, FDR), e.g., essential fatty acids such as linoleic acid and DHA (docosapentaenoic acid).

General Nutrient Function Claims

The following statements are two general nutrient function claims that are permissible for all nutrients. [B.01.311, B.01.312, D.01.006 and D.02.004, FDR]:

"Energy (or Name of the nutrient) is a factor in the maintenance of good health."

"Energy (or Name of the nutrient) is a factor in normal growth and development."

Specific Nutrient Function Claims

In addition to the two general nutrient function claims listed above, the Table of Acceptable Nutrient Function Claims below lists specific nutrient function claims associated with nutrients. The claims in the table refer to the scientifically recognized specific role each nutrient has in maintaining good health or in supporting normal growth and development. Other nutrient function claims may also be acceptable and will be evaluated on a case by case basis. The table will be updated as new nutrient function claims are reviewed and found to be acceptable by Health Canada. See Acceptability of New Nutrient Function Claims for more information on approval of a new nutrient function claim.

Table of Acceptable Nutrient Function Claims
Nutrient Acceptable Nutrient Function Claims Table Note 6
Protein
  • helps build and repair body tissues
  • helps build antibodies
  • helps build strong muscles
Fat
  • supplies energy
  • aids in the absorption of fat-soluble vitamins
DHA
  • DHA, an omega-3 fatty acid, supports the normal physical development of the brain, eyes and nerves primarily in children under two year of age Table Note 7
ARA
  • ARA, an omega-6 fatty acid, supports the normal physical development of the brain, eyes and nerves primarily in children under two year of age Table Note 7
Carbohydrate
  • supplies energy
  • assists in the utilization of fats
Vitamin A
  • aids normal bone and tooth development
  • aids in the development and maintenance of night vision
  • aids in maintaining the health of the skin and membranes
  • helps build strong bones and teeth
  • supports night vision
  • supports healthy skin
Vitamin D
  • factor in the formation and maintenance of bones and teeth
  • enhances calcium and phosphorus absorption and utilization
  • helps build strong bones and teeth
  • builds and maintains strong bones and teeth
  • improves calcium absorption
  • improves calcium and phosphorus absorption
Vitamin E
  • a dietary antioxidant
  • a dietary antioxidant that protects the fat in body tissues from oxidation
Vitamin C
  • a factor in the development and maintenance of bones, cartilage, teeth and gums
  • a dietary antioxidant
  • a dietary antioxidant that significantly decreases the adverse effects of free radicals on normal physiological functions
  • a dietary antioxidant that helps to reduce free radicals and lipid oxidation in body tissues
  • helps build teeth, bones, cartilage and gums
  • protects against free radicals
  • protects against the damage of free radicals
  • protects against the oxidative effects of free radicals
Thiamine (Vitamin B1)
  • releases energy from carbohydrate
  • aids normal growth
Riboflavin (Vitamin B2)
  • factor in energy metabolism and tissue formation
Niacin
  • aids in normal growth and development
  • factor in energy metabolism and tissue formation
Vitamin B6
  • factor in energy metabolism and tissue formation
Folate
  • aids in red blood cell formation
  • a factor in normal early fetal development Table Note 8
  • a factor in the normal early development of the fetal brain and spinal cord Table Note 8
Vitamin B12
  • aids in red blood cell formation
Pantothenic Acid
  • factor in energy metabolism and tissue formation
Calcium
  • aids in the formation and maintenance of bones and teeth
Phosphorus
  • factor in the formation and maintenance of bones and teeth
Magnesium
  • factor in energy metabolism, tissue formation and bone development
Iron
  • factor in red blood cell formation
  • helps build red blood cells
Zinc
  • factor in energy metabolism and tissue formation
Iodine
  • factor in the normal function of the thyroid gland
Selenium
  • a dietary antioxidant involved in the formation of a protein that defends against oxidative stress
  • dietary antioxidant
  • helps protect against oxidative stress

Table Notes

Table Note 6

The following two general nutrient function claims are permissible for all nutrients [B.01.311, B.01.312, D.01.006, D.02.004, FDR]:

  • "Energy (or Name of the nutrient) is a factor in the maintenance of good health."
  • "Energy (or Name of the nutrient) is a factor in normal growth and development."

Return to table note 6  referrer

Table Note 7

Note that this claim is based on available scientific evidence indicating that the development of the brain, eyes, and nerves in the human infant takes places very early starting in late pregnancy and up to 2 years of age. The Institute of Medicine in their 2005 report* stated that "The developing brain accumulates large amounts of DHA during the pre- and postnatal development and this accumulation continues throughout the first 2 years after birth". *Dietary Reference Intakes for Energy, Carbohydrate, Fiber, Fat, Fatty Acids, Cholesterol, Protein, and Amino Acids. Washington, (DC): National Academies Press; 2005. P. 444-5.

Return to table note 7  referrer

Table Note 8

In order to make these two claims for folate, the food must contain at least 40 micrograms of folate (20% Daily Value) per reference amount and per serving of stated size. This is a higher minimum amount than usual for a nutrient function claim for a vitamin because the function referred to in these two claims is associated with an intake that is higher than the Daily Value. These claims should not be used on foods intended solely for children under 2 years of age.

Return to table note 8  referrer

Advertisements for Nutrient Function Claims

The information below applies to non-prepackaged products or advertisements placed by someone other than the manufacturer or importer.

Radio Advertisements

When these claims are made in a radio advertisement, the quantitative statement shall be communicated immediately preceding or following the claim [B.01.312(3), FDR].

Television Advertisements

In the case of a television advertisement, the manner in which the quantitative statement is communicated depends upon the manner in which the nutrient function claim is delivered, i.e., audio mode, visual mode, or both audio and visual modes.

  • When the claim is delivered in the audio portion of the advertisement only then the quantitative statement must be communicated immediately preceding or following the claim in the audio mode or in both the audio and visual modes [B.01.312(4)(a), FDR].
  • When the claim is delivered in the visual portion of the advertisement only the quantitative statement must be communicated immediately preceding or following the claim in the audio mode or in the visual mode [B.01.312(4)(b), FDR].
  • In the case where the claim is made in both the audio and visual portions of a television advertisement the quantitative statement must be in the audio mode or in both the audio and visual modes.
  • In the case where the quantitative statement appears in the visual mode, it must appear at the same time and for the same length of time as the claim; must be adjacent to (without intervening material) the most prominent (or only) claim; and must be in letters of at least the same size and prominence as the claim [B.01.312(5), FDR].

Acceptability of New Nutrient Function Claims

This section applies to nutrients that meet the following criteria:

  1. the nutrient has an established Recommended Dietary Allowance (RDA), Adequate Intake (AI), or Acceptable Macronutrient Distribution Range (AMDR) by the Institute of Medicine of the US National Academies
    and
  2. the function reflects consensus among the broad scientific community and has been published by an authoritative scientific body Footnote 9 as its current position with regard to the function(s) within the past 15 years.

To seek advice on the acceptability of a new function claim for a nutrient that meets the above criteria, manufacturers are encouraged to contact the Food Directorate of Health Canada with the following information:

  1. the name of the authoritative body;
  2. the exact wording of the statement;
  3. a copy of the source document in which the statement is published;
  4. a description of the review process undertaken by the authoritative body to develop the statement; and
  5. an indication that there is no conflicting authoritative statement.

See Science Research for information on how function claims are assessed for nutrients for which no Recommended Dietary Allowance (RDA), Adequate Intake (AI), or Acceptable Macronutrient Distribution Ranges (AMDR) have been established by the Institute of Medicine of the US National Academies (e.g. DHA).

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