Comparative nutrient content claims
On December 14, 2016, amendments to nutrition labelling, list of ingredients and food colour requirements of the Food and Drug Regulations came into force. Regulated parties have a five (5) year transition period to meet the new labelling requirements.
Consult the Former – Comparative Nutrient Content Claims for information on the former requirements.
Comparative nutrient content claims are those that compare the nutritional properties of two or more foods. The major categories of comparative nutrient content claims are:
- Light in energy or fat
Examples of comparative claims include:
- "3 grams more fibre than 1 slice of Brand X bread"
- "33% less sodium per x serving than our regular potato chips"
Table of Contents
- Conditions for use of comparative nutrient content claims
- Comparative claims for vitamin and mineral nutrients
- Reformulated products and similar reference foods
- Example: steps for evaluating "reduced in fat"
Conditions for use of comparative nutrient content claims
The comparative nutrient content claims listed in the table following B.01.513 of the FDR (see Specific Nutrient Content Claim Requirements) may be used on food labels or in advertising. The claims must meet both the food conditions which must be met (column 2) and the labelling and advertising conditions (column 3). In general, comparative claims must:
- involve similar reference foods (definition) (e.g. skim milk and whole milk), or reference foods of the same food group (definition) (e.g. tofu sausage and regular meat sausage) depending on the type of claim;
- clearly identify the foods being compared and the differences between them; and
- be based on differences which are both nutritionally and analytically significant.
Comparative claims for vitamin and mineral nutrients
Comparative claims relating to the content of vitamins and mineral nutrients in foods are not mentioned in the table following Section B.01.513 but similar rules for use as those discussed above apply. See Vitamin and Mineral Nutrient Claims for further information.
Reformulated products and similar reference foods
A reformulated product may temporarily use the pre-reformulated product as a similar reference food if the pre-formulated product will be phased out. For example, a product that has been reformulated to reduce the trans-fat content may use the claim "reduced in trans fatty acids" as compared to the pre-reformulated product as the similar reference food, if the food, label and advertisement meet all of the conditions set out for the nutrient content claim. This claim would be acceptable on a food for a one-year period (from the production date) after the similar reference food has been phased out. This claim can be made in advertising (e.g. television, radio, print, etc.) only for one year as well. After the one year period, the claim would not be acceptable given that the similar reference food is no longer available. Other more appropriate claims such as "Lower in trans fatty acids" or "Free of trans fatty acids" could be used at that time, provided the food meets the conditions set out for those claims.
The "reduced in trans" comparative claim should normally be against the manufacturer's regular product since in order to decrease the trans content, the food would have to be reformulated with a different source of fat and/or oil. However, a competitor's product that meets the definition of a similar reference food could also be used.
Note: The food carrying the claim "reduced in trans fatty acids" must be processed, formulated, reformulated or otherwise modified, without increasing the content of saturated fatty acids, so that it contains at least 25% less trans fatty acids, based on the reference amount of the food and similar reference food (or based on 100 g for prepackaged meals). The similar reference food cannot meet the conditions for the "low in saturated fatty acids" claim (see Summary Table of Saturated Fatty Acid Claims).
Example: steps for evaluating "reduced in fat"
See item c) of the Summary Table for Fat Claims (item 13 of the table following B.01.513), "Reduced in fat", to evaluate the claim: "30% lower in fat than our regular granola bar"
- the "lower in fat" granola bar must have a minimum of 25% less fat than the similar reference food (i.e., the regular granola bar); and
- the similar reference food (i.e., the regular granola bar), must not qualify as "low in fat".
- the "similar reference food" (e.g., the regular granola bar) must be identified;
- the amounts of the food being compared must be stated, unless they are the same; and
- the difference must be expressed per serving of stated size (as a percentage, a fraction or in grams).
For more examples on identifying the validity of a claim, please refer to Nutrient Content Claim Examples.
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