Legibility and Location of Labelling Information
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Location requirements for the core labelling requirements:
- Information that is required to be displayed on the principal display panel:
- Information that may be on any panel, except for the bottom (definition):
- 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:
- Durable Life Date [B.01.007, FDR].
- 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].
- 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:
- 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.
- 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.
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