Foods for Use in Manufacturing Other Foods
This section deals with the requirements of prepackaged foods for use in manufacturing other foods and it identifies the major differences in the presentation of nutrition information for this class of foods as compared to prepackaged foods for the consumer.
Foods for use in manufacturing other foods are prepackaged products that are intended for use as an ingredient [B.01.404 (1),FDR]:
- in the manufacture of other prepackaged products intended for sale to a consumer at the retail level, or
- in the preparation of foods by a commercial or industrial enterprise or institution.
This category of foods:
- requires cooking before consumption; or
- Note: while these may not strictly be ingredients in the preparation of other foods, their nutrition information may change after cooking or they may be combined with other ingredients (e.g. oil) during the cooking process.
- is to be combined with another ingredient to prepare a food.
Examples of foods in this category include: unbaked lasagna, raw seasoned fillets, dry noodles, frozen fries, unbaked pies, canned pie filling, instant potatoes, dried soup mix, corn starch and sugar.
Not all bulk containers of food are considered to be "solely" for use in the manufacturing of other foods. This is determined by the intended use of the ingredients. For example, if the contents are intended to be repacked from bulk at the retail premises or sold directly to consumers from bulk bins, these products require a standardized Nutrition Facts Table Format.
Nutrition Labelling Requirements
The nutrition labelling requirements for Foods for Use in Manufacturing Other Foods are similar to those of prepackaged foods sold to the consumer, with some differences. The following rules apply:
- Nutrition information for energy and the same core nutrients as required for prepackaged foods for the consumer in B.01.401 must be included [B.01.404(3)(a), FDR];
- Additional information for the same nutrients as required for prepackaged foods for the consumer in section B.01.402 of the FDR must also be provided when triggered [B.01.404(3)(a), FDR];
- Additional information permitted in section B.01.402 of the FDR may also be included [B.01.404(3)(b), FDR].
- The information does not have to appear in a Nutrition Facts table format as prescribed by B.01.401(1) of the FDR. Information is not required to be in a box, nor must it obey the formatting requirements [B.01.401(7)(b), FDR];
- The information may simply list the nutrients and their values.
No Exemption from Providing Nutrition Information
Nutrition labelling exemptions found in B.01.401 do not apply to these products [B.01.404(2), FDR]. For example, while prepackaged fresh apples sold in a retail store are generally exempt from carrying a Nutrition Facts table [B.01.401(2)(b)(ii), FDR], prepackaged apples intended solely as:
- an ingredient for use in the manufacture of other prepackaged consumer foods (e.g., apple sauce), or
- an ingredient (e.g., sliced apples) for use in the preparation of food (e.g., an apple pie) by a commercial or industrial enterprise or institution
must be accompanied by written nutrition information upon delivery [B.01.404 (2), FDR].
Nutrients must be declared:
- per gram (g) or 100 grams (100 g) if the net quantity is declared by weight or count [B.01.404(3)(c)(i)(a) and (ii)(a), FDR]; and
- per millilitre (ml) or 100 millilitres (100 ml) if the net quantity of the food is declared by volume [B.01.404(3)(c)(i)(b) and (ii)(b), FDR].
Units of Measure
- Vitamins must be declared in the units set out in Table I of Division 1 of Part D of the FDR (e.g., RE, µg, mg, NE) [B.01.404(3)(c)(i), FDR].
- Minerals must be declared in the units set out in Table I of Division 2 of Part D of the FDR (e.g., mg, µg) [B.01.404(3)(c)(i), FDR].
- The information for the other nutrients and energy must be declared in absolute units as set out in column 3 to the tables to B.01.401 and B.01.402 of the FDR (e.g. Calories, g, mg, µg).
- The declaration of % Daily Values and information on "serving of stated size" may be omitted [B.01.404(3)(c)(iii), FDR].
The table in Annex 1: Vitamin and Mineral Declarations summarizes the units of measure to be used when providing nutrition information for vitamins and minerals for foods for use in manufacturing other foods.
Precision of Nutrient Declarations and Rounding
- All information must be stated with a degree of precision (i.e., same number of significant figures) corresponding to the accuracy of the analytical methodology used to produce the nutrition information [B.01.404(3)(c)(iv), FDR];
- Since the nutrient information provided to the manufacturer may be used to create a Nutrition Facts table for another food, it must not be rounded;
- It is also acceptable to declare < (the limit of detection) as opposed to declaring 0, where the declaration is to be to the "degree of precision that corresponds to the accuracy of the analytical methodology used". For example, < 10 mg is acceptable if the nutrient is not detected but the limit of detection is 10 mg.
Voluntary Claims and Statements
Nutrient Content Claims
The provisions set out in the Food and Drug Regulations for making a nutrient content claim is intended to apply specifically to products sold to consumers at the retail level and where a Nutrition Facts table is required as per B.01.401. However, there is no prohibition from making a nutrient content claim, such as "trans fat free", on foods intended for further manufacture. These types of claims may be made at the manufacturer level provided that the amount of the nutrient subject to the claim, per a reasonable serving of stated size, is given and the product meets the criteria set out for the claim. Refer to Nutrient Content Claims for specific requirements regarding these types of claims.
Note: The final product must be assessed independently for compliance with any given claim. Variation in the amount of the ingredient used or the effect of other ingredients used may have an impact on the final product meeting the criteria for the claim.
Documentation for Purchaser
In the case of foods that are shipped to a purchaser on a continual basis, with no change to the formulation, documentation may be provided to the purchaser on the basis of the first shipment, without having to provide the information on an ongoing basis provided the purchaser agrees in writing to this arrangement (see Accompanying Documentation for Nutrition Labelling, Letter to Industry).
Any change to the nutrition information as a result of formulation changes or other influences would have to accompany the modified product with its first delivery after the change has occurred. It is recommended that a reference system be set up to ensure a match between the nutrition information and the incoming material for document control purposes. The purchaser should retain relevant hard copies of the information on file for ingredients that have been used in existing production lots still on the market.
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