Identity and Principal Place of Business
Manner of Declaring
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The "identity" declared on the label of prepackaged products represents the regulated party that has manufactured or produced the food, or for whom the food has been manufactured or produced. The declared identity must be complete and accurate enough to enable someone to get in touch with the person (definition) who operates the company.
For example, the identity may be:
- The legal name under which the company operates and has been registered federally, provincially or territorially.
E.g. I Love Candy Inc.
Principal Place of Business
As indicated, the principal place of business must lead to a physical location where the "principal", or main, "business" can be found. Although a physical location is required to be declared on labels, the legislation does not prescribe the level of detail necessary, nor does it state that a "complete mailing address" is required. The CFIA encourages industry to provide a mailing address that is complete enough so that consumers, who wish to communicate with the "person" in writing, can do so in a timely manner. The best practice is to include the civic address, city, province, postal code and country.
Websites, telephone numbers, and virtual addresses are not acceptable "principal place of business" declarations, as they are not physical locations. Websites are instead examples of Additional Information that May be Added on a Label.
In addition, a numerical code is not an acceptable means of expressing the principal place of business of the dealer (definition) taking responsibility for the product. For example, a French postal code in the example "P. Bureaux & Fils, Négociants à 12345 (France)" does not meet the requirements for the "dealer identity and principal place of business".
Declarations on Domestic Products
Prepackaged products wholly manufactured or produced in Canada are subject to domestic requirements for identity and principal place of business declaration.
Imported products that are not considered to have been "wholly manufactured outside of Canada" (i.e. processing steps are carried out in Canada to modify the nature of the product) are also subject to these domestic requirements. The addition, removal or combination of one or more ingredients, physical or chemical processing including grinding and blending, are examples of processes that modify the nature of a product. For example, macadamia nuts that have been imported in bulk and are then roasted, salted and canned in Canada are not "wholly manufactured outside of Canada". The identity and principal place of business is therefore declared as it would be for domestic products, as opposed to according to the section that follows on imported products.
The following are examples of acceptable declarations for the identity and principal place of business of the responsible party for domestic products:
Example 1: The name of the Canadian city accompanied by CanadaFootnote 1 or the province.
ABC Foods Inc.
ABC Foods Inc.
ABC Foods Inc.
DEF Foods Inc.
GHI Foods Inc.
Example 2: A full civic address of the Canadian company.
ABC Foods Inc.
123 Streetsville Rd
M5M 5M5, Canada
Example 3: If a company has multiple branches across Canada, the company may list multiple branches.
Yellow Banana Ltd.
Vancouver, Calgary, Winnipeg, Toronto
Declarations on Imported Products
Prepackaged products wholly manufactured or produced outside of Canada and subject to the CPLA must indicate "imported by/for" (importé par/pour) or the country of origin as part of the identity and principal place of business declaration whether they are labelled or relabelled in Canada or elsewhere [31(2), CPLR].
The requirement to indicate "imported by/for" (importé par/pour) or the country of origin also applies to imported products that are imported in bulk and repackaged at a level of trade other than retail [31(3), CPLR]. An example includes nuts that have been imported in bulk (already roasted and salted) and are only canned in Canada.
If the imported product is repackaged at retail, it is not required to indicate "imported by/for" (importé par/pour) or the country of origin as part of the identity and principal place of business declaration, unless prescribed by commodity specific regulations (e.g. fresh fruits and vegetables or dairy products). For more information on food-specific labelling requirements, visit the Industry Labelling Tool.
For further details on placement and type height, refer to Legibility and Location below [31(4), CPLR].
The following options satisfy the above requirements for the identity and principal place of business of the responsible party for imported products:
- declare the identity and principal place of business of the foreign manufacturer (definition);
- declare the identity and principal place of business of the Canadian company adjacent to the country of origin of the product; or
- declare "imported for" or "imported by" followed by the identity and principal place of business of the Canadian company
Examples of the above options:
Yummy Nut Ltd. Hilo,
Fate Foods Inc.
Drink ABC Rio de
Janeiro, Brazil Ltd.
A foreign company may also list multiple branches.
In this example Oaxaca, Acapulco and Tula are all cities in Mexico where products from Tamale Inc. are manufactured. As the headquarters for Tamale Inc. are in Tula, which is in the state of Hidalgo, this method of declaration is acceptable.
Imported by / Importé par
The Crunchie Nut Distributions Ltd.
Winnipeg, Manitoba R1G 2N2
The Crunchie Nut Distributions Ltd.
Product of USA
Declarations on Retail Specific Products
For retail foods, the identity and principal place of business of the legal entity may vary depending on ownership of the store.
Where multiple stores are owned or franchised by a banner (e.g. retail food chain), the legal name of the individual store or franchisee store must appear on the label. The banner may also appear, but not on its own
Example: Blue Herring Distribution Inc., store #1234.
- Blue Herring Distribution Inc. is the name of the banner or retail food chain, and Store #1234 is the name of the legal entity the store operates under.
For an independent store that is not part of a banner, the name that must appear is again that of the legal entity.
Example: John Doe's Fish Market.
Location of Label or Container Manufacturers
Where any direct or indirect reference is made on a label to a manufacturing place that refers to the place where the label or container was manufactured, and not the product itself, that reference must be accompanied by an additional statement. This statement must indicate that the place written on the label is referring to where the label or container was manufactured [31(1), CPLR].
- E.g. Label printed in Canada by …
- E.g. Label lithographically printed in Canada by …
- E.g. Container manufactured in Canada by …
Additional Information that May be Included on a Label
Information such as websites and 1-800 telephone numbers may be provided in addition to a company's identity and principal place of business.
Additional terms such as "prepared for", "packaged for", or "distributed by", that further explain information about the identity and principal place of business may be voluntarily added on the label of prepackaged products. In general this is not mandatory. In some cases, however, the terms "manufactured by" or "produced for" are required by commodity specific regulations. For more information on food-specific labelling requirements, visit the Industry Labelling Tool.
Legibility and Location
The identity and principal place of business must be declared on any part of the product label except for the bottom [B.01.005, B.01.007(1), FDR, 10, 13, CPLR], and in letters with a minimum type height of 1.6 millimetres (1/16 inch) based on the lowercase "o" [14(1),15, CPLR].
When the area of the principal display surface of a container is 10 square centimetres (1.55 square inches) or less, then the identity and principal place of business declarations may be shown in letters with a minimum type height of 0.8 millimetres (1/32 inch) [16, CPLR].
The statement of geographic location for products that are wholly manufactured or produced in a country other than Canada must be located immediately adjacent to the declaration of identity and principal place of business, and shown in letters at least as large as those used in the declaration of the Canadian principal place of business [31(2),(3),(4), CPLR].
For more information on this subject, refer to Legibility and Location.
Unlike other mandatory information that is required to be declared on prepackaged product labels, identity and principal place of business do not have to be declared in both official languages [6(2), CPLR; B.01.012(9), FDR]. It is acceptable for identity and principal place of business to be declared in either English or French, or an alphabet that is common to English and French such as Spanish, Italian, Portuguese, German, Swedish, etc. Languages with other alphabets such as Arabic, Japanese, Chinese, Russian and Greek, however, are not accepted.
The words "imported by" or "imported for", when required, must be declared in both official languages.
For more information on this subject, refer to Bilingual Labelling.
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