Archived - What we heard report:
Food Labelling Modernization Initiative Phase II -
Engagement on options to modernize the food labelling system
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The Canadian Food Inspection Agency (CFIA) launched the Food Labelling Modernization (FLM) initiative in June 2013. The overall objective of this initiative is to develop recommendations that will lead to a more modern and innovative food labelling system within CFIA responsibility, which responds to current and future challenges. It focuses on the four key areas: regulations; service delivery; policy and program development; and roles, responsibilities and partnerships.
A multi-phased engagement approach is used in this initiative. Feedback from Phase I engagement (2013-2014) helped to identify the key issues on the food labelling system. In the Phase II engagement (2015), we presented proposed options to modernize the system.
This report is a summary of the stakeholder feedback to the Phase II FLM consultations held in the winter and spring of 2015. Consultations used a combination of face-to-face discussions in five cities across Canada, webinars, and an online questionnaire. Nearly 1600 stakeholders participated in these activities: 38% consumer, 34% industry, 17% government and 11% others (e.g. health professionals, academia, etc.).
Although this report only captures the most common themes we heard, all comments were considered by the CFIA to inform the development of key recommendations. The CFIA also received feedback that was out of the scope of CFIA's mandate or the FLM initiative. These comments were shared with other government departments responsible for the issue, where appropriate.
The views expressed herein are those raised by the stakeholders who participated in FLM Phase II engagement activities and do not necessarily reflect those of the Canadian Food Inspection Agency (CFIA, the Agency) or the Government of Canada.
What we heard
The opportunity to provide feedback was well received by stakeholders and there was overall stakeholder support for options to modernize:
- Strong support to modernize the regulatory framework.
- Strong support to use more innovative approaches and tools, improvements to training, and guidance to enhance the complaints process.
- Consumers and industry support more balanced participation by all stakeholders, and strong government oversight.
- Strong support for a risk based framework that allows greater role for industry, consumers, health professionals and other stakeholders.
- Stakeholders also strongly indicated that CFIA and HC must work closely together to align and coordinate food labelling initiatives.
Key area: Regulations
Stakeholders told us that clear, simple, concise and easy to understand language and format is needed in regulation, particularly for best before date labelling, class names and food standards.
Enhancing "best before date" labelling
Stakeholders told us there are too many exemptions for best before dating, and there is need for clarity on when to use"packaged on dating" vs. "best before date". There was strong support for adding the four digit year to the current date marking format. Some stakeholders support a flexible best before date format, while others indicated a preference for characters rather than numbers for months. There were also specific recommendations to include expiration dates.
The engagement also highlighted that there is a need for more consumer education to improve understanding of best before dates and other date markings.
Improving legibility and placement of information
Consumers indicated that the type size for list of ingredients and common name should be increased. It is difficult to read information off shiny surfaces. Some recommended white backgrounds and that mandatory information should have a consistent location on the label.
Some industry members expressed concern over the level of detail provided within the proposed approaches and how this would impact label space and branding. They noted that the design of packaging needs to be as flexible as possible, and that outcome based requirements may be the best approach.
Enhancing dealer name and address
Stakeholders told us that:
- The contact information for the dealer name and address should reflect modern ways for consumers to directly contact companies.
- Terms such as "packaged by", "manufactured by", "imported by" are not meaningful to consumers who want to know where their food comes from.
- The "prepared for" labelling requirement should be removed as it is seen as having no relevance.
- The dealer name and address on wholly imported foods should be the name of the importer as opposed to the manufacturer or distributor in the exporting country to ensure consistency and accountability.
There were also specific recommendations to include origin of food on all products.
Improving information on key ingredients emphasized through claims or pictures
Stakeholders indicated that:
- The list of ingredients does not let consumers know how much of a specific ingredient is in the product when a claim is made such as "made with fruit."
- Consumers cannot easily compare products with similar ingredient lists when ingredients are highlighted.
While there was strong support from consumers to have more information to assist in their purchasing decision, some industry members expressed concern over the protection of proprietary information in a highly competitive environment. They noted that flexibility is needed for product innovation and variability in formula.
Improving ingredient list class names
Consumers want more ingredients listed and the ingredients list to be clear and understandable. We heard that class names should provide clear information to consumers and be revised so that ingredients are not hidden. Industry identified trade consistency issues with specific class names. Stakeholders had differing views on the approach for certain class names, for example on milk ingredients and modified milk ingredients, sugar and seasonings.
Modernizing food standards
CFIA heard from industry that standards are outdated, are a barrier to trade, stifle innovation, limit consumer offerings and contribute to administrative burden. It is also difficult to update or amend food standards in a timely manner. In Phase II engagement, there was strong support to modernize the standards and use new tools such as Incorporation by Reference (IbR).
We heard specific recommendations to amend existing standards and include new ones.
FLM key area: Service delivery
Stakeholders indicated that the Online Labeling Tool (OLT) is "a step in the right direction", and that information is clearer than it used to be.
A number of suggestions were made on additional information on the website that could contribute to better awareness of food labelling, including:
- A repository of FAQs and a database of past decisions;
- More visuals and clear examples (e.g. tables, sample labels);
- Improving website navigation through search optimization, a site map, and numbering of sections, and;
- Clear contact information for inquiries (email and phone number).
A number of suggestions were also made on how to proactively work together to track issues, distribute information and promote compliance in priority areas.
FLM key area: Policy development
Stakeholders generally were supportive of the proposed approach to explore a different model that would increase the role of industry, associations and consumers in the maintenance of existing, and development of new policies related consumer value claims. A number of suggestions were also made on how this can be achieved.
FLM key area: Roles, responsibilities, and partnerships
Some stakeholder suggestions on enhancements to the CFIA website to better inform about stakeholder roles and responsibilities include:
- Clarifying CFIA and Health Canada's roles in food labelling by using comparison tables, flow charts and/or decision trees.
- Providing clear information, tools and guidance to support stakeholders in their respective roles in the food labelling system.
The following key themes to implement the modernization changes in the labelling system emerged:
- There is a need for more consumer education to help them understand various label elements.
- Complete, accurate, consistent and truthful information on ingredients lists, nutrition, health and consumer values claims are needed.
- The overall impact of the proposed changes on small business in particular needs to be considered.
- The need for feasible transition periods (e.g. to phase out old equipment) was highlighted. In some cases, new labelling equipment and total package redesign (not just label redesign) will be required.
- Alignment with Health Canada's modernization initiative will be critical to minimize the implementation burden (cost, time) on industry that would result from multiple changes to government regulations.
- Alignment and harmonization of regulations with the US and other international trading partners will help to facilitate trade and commerce and ensure equivalent requirements for domestic food and imports and exports.
The feedback received from various engagement activities, combined with our research into international standards and best practices in other jurisdictions informed the development of the FLM key proposals to modernize the food labelling system. The CFIA will be consulting stakeholders on these proposals through the FLM Online Discussion Paper and Questionnaire and through webinars, face to face sessions and other meetings. For more information on this phase of consultation, please visit Food Labelling Modernization initiative.
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