Legibility and Location of Labelling Information

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Table of Contents

Legibility Requirements

All mandatory information required on foods sold at retail under the Consumer Packaging and Labelling Act and Regulations must be in letters of not less than 1.6 mm (1/16 inch) in height, based on the height of an upper case letter where words appear in upper case and the height of the lower case letter "o" when words appear in lower case or in a mixture of upper and lower case, other than in the declaration of net quantity [14, 15, CPLR]. For net quantity, specific size requirements exist which are based on the size of the principal display surface (definition) for the numerical portion of the net quantity declaration. Refer to the Net Quantity for more information on these requirements.

For very small packages that have a principal display surface of 10 square centimetres (1.55 square inches) or less, information required by the CPLA and CPLR, other than the information in the declaration of net quantity, may appear in letter height of at least 0.8 mm (1/32nd of an inch), provided all the information required by the CPLA and CPLR appears on the principal display panel (definition) [16, CPLR].

Mandatory information required to appear on a label (definition) of a food by the Food and Drug Regulations must be:

  1. clearly and prominently displayed on the label; and
  2. readily discernible to the purchaser or consumer under the customary conditions of purchase and use.

For the Nutrition Facts table, the Food and Drug Regulations (FDR) prescribe specific format (graphic) and technical requirements including type height. Refer to Nutrition Labelling for more information on these requirements. In addition, the FDR prescribe specific size requirements for certain other label information such as "contains [naming the sweetener(s)]" statements (see Sweeteners).

While section A.01.016 FDR does not provide specific type height requirements, the minimum type height of 1.6 mm (1/16 inch), based on the lowercase letter "o" is considered to be sufficient to meet the requirement for labelling information to be clearly and prominently displayed, when it is not otherwise specified in regulation.

In the case of some statements or claims regarding a food product, such as Nutrient Content Claims or Organic Claims, the components of these statements or claims may be required to be of the same size and prominence when applied to the label of or in any advertisement for a food. For more information on the legibility requirements for statements or claims regarding a food product, see the relevant webpage for the type of claim on the Industry Labelling Tool.

For example, if a manufacturer uses the claim "no sodium added" on the label or advertisement of a food product which meets the requirements for this claim as stated in the table following B.01.513 of the FDR, all of the words in this claim must be of the same size and prominence. It would not be acceptable if the words "no sodium" were bolded and appeared in a larger font size than the word "added". For more information on these requirements, refer to Nutrition Labelling. For all other claims, it is encouraged that all elements of a claim be of equal size and prominence.

Examples of information on a food label that may not satisfy the above mentioned legibility requirements include impressed or embossed letters on cardboard or plastic, or coloured text on a similarly coloured background.

Location Requirements

Location requirements for the core labelling requirements:

  1. Information that is required to be displayed on the principal display panel:
    1. Common name [B.01.006, FDR], and;
    2. Net quantity declaration [4, CPLA].
  2. Information that may be on any panel, except for the bottom (definition):
    1. Identity and Principal Place of Business [B.01.005, B.01.007, FDR], and;
    2. List of ingredients [B.01.005, B.01.008, FDR].
  3. Information that may appear on any panel, including the bottom if accompanied by a statement which indicates that this information is located on the bottom:
    1. Durable Life Date [B.01.007, FDR].
  4. In the case of the Nutrition Facts table, it must be displayed on the available display surface (definition) of the package [B.01.005, FDR].
  5. Specific location requirements may also exist for other labelling requirements such as alcohol by volume statements on alcoholic beverages and "contains [naming the sweetener(s)]" statements.

It is important to note that other requirements, including more commodity-specific requirements, may exist, in addition to the core labelling requirements specified above and that these may also have location requirements. For more information on these requirements, refer to the Industry Labelling Tool.

B.01.008 of the FDR states that all mandatory information required by the FDR must appear grouped together, on any part of the label, unless it is information which is required to be shown on the principal display panel or information which is specifically exempted from the grouping provisions as stated in B.01.008(1)(a) FDR (e.g., the dealer identity and principal place of business, the durable life date information, the Nutrition Facts table and regulated Nutrient Content Claims and Health Claims). If the product is required to carry a list of ingredients, the information which is required to be grouped together on that product's label must be grouped together with the list of ingredients.

As per A.01.016 of the FDR, all information required by the Regulations must be labelled in a manner which is "clearly and prominently displayed on the label" and "readily discernible to the purchaser or consumer under the customary conditions of purchase and use". Examples of types of labels which do not satisfy this requirement include:

  1. mandatory information on the reverse side or "outsert" or pull-out portion of the label (a folded or inserted panel under the label of a product), regardless of whether there is an instruction for the consumer such as "peel back here", or "lift this panel for more information" such that the consumer needs to peel the label off the container to read the reverse side. It is acceptable, however, to use the pull-out part of the label for information that is not mandatory.
  2. mandatory information which has become obscured by applying a label to an irregularly shaped package or product (e.g., a square label which has taken the shape of the spherical object to which it is applied).

In the case of ornamental containers (definition), it is acceptable for mandatory information to be located on the bottom panel, as this panel is considered to be its principal display panel [2.(2)(b), CPLR].

Other than the mandatory information that must appear on the principal display panel, for a container with no definable bottom; mandatory information may appear on any panel.

Use of Hang Tags as Labels

A tag is included in the CPLA and FDA definitions of a "label" and the CPLA definition of "apply" includes to attach to, imprint on, include in or cause to accompany in any other way a product.

Generally, mandatory information that is required to be on the principal display panel is not permitted to be located on a tag, unless the container does not have any side or surface that is displayed or visible under normal or customary conditions of sale or use (e.g., foil wrapped milk chocolate eggs in a mesh bag). In this case, the mandatory information that is required to appear on the principal display panel must be repeated on both sides of the tag, such that it is visible no matter which way the tag was displayed.

In the case of a container that is a wrapper or confining band so narrow in relation to the size of the product contained that it cannot reasonably be said to have any side or surface that is displayed or visible under normal or customary conditions of sale or use, mandatory information that is required to be on the principal display panel may be located on one of the two sides of the hang tag. Under these circumstances, the total area of one side of the tag is considered to be the principal display surface [2.(1), CPLR].

All other labelling information may be located on one of the two sides of a hang tag provided it is readily discernable.

Definitions

Label

As defined in the Consumer Packaging and Labelling Act, label means any label, mark, sign, device, imprint, stamp, brand, ticket or tag. [2, CPLA]

As defined in the Food and Drugs Act, label includes any legend, word or mark attached to, included in, belonging to or accompanying any food, drug, cosmetic, device or package. [2, FDA]

Principal Display Surface

The Consumer Packaging and Labelling Regulations define Principal Display Surface as,

  1. in the case of a container that has a side or surface that is displayed or visible under normal or customary conditions of sale or use, the total area of such side or surface excluding the top, if any,
  2. in the case of a container that has a lid that is the part of the container displayed or visible under normal or customary conditions of sale or use, the total area of the top surface of the lid,
  3. in the case of a container that does not have a particular side or surface that is displayed or visible under normal or customary conditions of sale or use, any 40 per cent of the total surface area of the container, excluding the top and bottom, if any, if such 40 per cent can be displayed or visible under normal or customary conditions of sale or use,
  4. in the case of a container that is a bag with sides of equal dimensions, the total area of one of the sides,
  5. in the case of a container that is a bag with sides of more than one size, the total area of one of the largest sides, and
  6. in the case of a container that is a wrapper or confining band that is so narrow in relation to the size of the product contained that it cannot reasonably be said to have any side or surface that is displayed or visible under normal or customary conditions of sale or use, the total area of one side of a ticket or tag attached to such container, and
  7. despite paragraphs (a) to (f) of this definition, in the case of a container of wine in which the wine is displayed for sale to consumers, any part of the surface of the container, excluding its top and bottom, that can be seen without having to turn the container. [2.(1), CPLR]

Principal Display Panel

As defined in the Consumer Packaging and Labelling Regulations, Principal Display Panel means,

  1. in the case of a container that is mounted on a display card, that part of the label applied to all or part of the principal display surface of the container or to all or part of the side of the display card that is displayed or visible under normal or customary conditions of sale or use or to both such parts of the container and the display card,
  2. in the case of an ornamental container, that part of the label applied to all or part of the bottom of the container or to all or part of the principal display surface or to all or part of a tag that is attached to the container, and
  3. in the case of all other containers, that part of the label applied to all or part of the principal display surface. [2.(2), CPLR]

As defined in the Food and Drug Regulations, Principal Display Panel means,

  1. in the case of a label applied to a prepackaged product that is subject to the Consumer Packaging and Labelling Act (CPLA) the principal display panel as defined in the Consumer Packaging and Labelling Regulations (CPLR) (see CPLR definition for Principal Display Panel above),
  2. in the case of a label applied to a prepackaged product that is not subject to the Consumer Packaging and Labelling Act, that part of the label applied to all or part of the side or surface of the container that is displayed or visible under normal or customary conditions of sale or use, and where the container does not have such a side or surface, that part of the label applied to any part of the container, except the bottom, if any, and
  3. in the case of a label applied to a food that is not a prepackaged product, that part of the label applied to all or part of the side or surface of the food that is displayed or visible under normal or customary conditions of sale or use. [B.01.001, FDR]

Bottom

The bottom is considered to be that part of a food or container which may reasonably be expected to be the surface on which the container rests when displayed for purchase. Some containers have several options as to how they can be displayed. If a food or container is labelled or printed in such a way that it may reasonably rest on any of the sides, then there is no bottom.

For example, as a frozen chicken dinner in a box may be displayed on more than one side, there is no definable bottom. In contrast, one would not reasonably expect a lemon meringue pie to be displayed on its side as it would result in damage to the product, and hence there is a definable bottom.

Available Display Surface

Available Display Surface means:

(a) the bottom of an ornamental container or the total surface area of both sides of a tag attached to the ornamental container, whichever is greater

(b) the total surface area of both sides of a tag attached to a package to which a label cannot be physically applied or on which information cannot be legibly set out and easily viewed by the purchaser or consumer under the customary conditions of purchase, and

(c) total surface area of any other package, excluding the bottom if the contents of the package leak out or are damaged when the package is turned over;

but does not include:

(d) any area of a package on which a label cannot be physically applied or on which information cannot be legibly set out and easily viewed by the purchaser or consumer under the customary conditions of purchase,

(e) any part of a package that is intended to be destroyed when it is opened, other than a package of a food that is intended to be consumed by one person at a single eating occasion, or

(f) the area occupied by the universal product code (UPC). [B.01.001, FDR]

Available display surface applies solely to the Nutrition Facts table. The appropriate size, shape and configuration of the Nutrition Facts Table depends on accurately determining the available display surface of the product's packaging. For more information please visit the Nutrition Labelling Section of the website.

Ornamental Container

An "ornamental container" means a container that, except on the bottom, does not have any promotional or advertising material thereon, other than a trade mark or common name and that, because of any design appearing on its surface or because of its shape or texture, appears to be a decorative ornament and is sold as a decorative ornament in addition to being sold as the container of the product [B.01.001, FDR].

Ornamental containers must be substantial enough to be sold on their own merit (i.e., without the food). Ornamental containers are usually made of metal (e.g., cookie tins), plastic or glass (e.g., candy filled figurines). On the other hand, fabric-covered or embossed cardboard boxes for chocolates (e.g., for Valentines Day) are normally considered decorative rather than ornamental.

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