List of ingredients and allergens
Manner of declaring

Ingredients

Order of ingredients

Ingredients must be declared by their common name in descending order of their proportion by weight of a prepackaged product. The order must be the order or percentage of the ingredients before they are combined to form the prepackaged product. In other words, based on what was added to the mixing bowl [B.01.008.2(3)(a), FDR].

The following ingredients, however, can be listed at the end of the ingredients list in any order [B.01.008.2(4), FDR]:

Sugars

Sugars-based ingredients (definition) are required to be grouped within the list of ingredients following the term "Sugars" [B.01.008.3(1), FDR]. For more information, refer to Grouping Sugars-based Ingredients.

Ingredients that generally do not have to be declared

When present in a prepackaged product, the following ingredients and their components are not required to be declared in the list of ingredients, unless they contain known allergens, gluten, or added sulphites at quantities greater than or equal to 10 parts per million. Refer to Food allergen, gluten and added sulphite declaration for exceptions.

  • Wax coating compounds and their components are not required to be shown on the labels of prepackaged fresh fruits or fresh vegetables as an ingredient or a component [B.01.008(3)(a), FDR]. Apples, turnips and cucumbers are examples of fruits and vegetables that have wax coatings.
  • Sausage casings are not required to be shown on the labels of prepackaged sausages as an ingredient or as a component [B.01.008(3)(b), FDR]. However, the declaration of a natural casing is required if it is of a different species than the meat ingredients used in the sausage. For more information, refer to Meat Products Wrapped in Natural Casings under the Meat and Poultry Products page.
  • Hydrogen, when used for hydrogenation purposes, is not required to be shown on the labels of any prepackaged products as an ingredient or component [B.01.008(3)(c), FDR].

Components

Order of components

Components (definition) (ingredients of ingredients) must be declared by their common name as part of the list of ingredients. They can be declared in one of two ways:

  • 1) in parentheses following the ingredient common name in descending order of proportion by weight in the ingredient [B.01.008.2(5)(b), FDR]

For example:

Ingredients: Tomato paste (tomatoes, salt, benzoic acid) • Sugar • Modified corn starch • Lemon juice from concentrate (water, concentrated lemon juice, sugar, benzoic acid) • Water • Spices • Salt • Allura red

or,

  • 2) in descending order of proportion by weight in the finished food as if they were ingredients [B.01.008.2(6), FDR]

This option saves space in the list of ingredients since all ingredients and components are only listed once in descending order based on their total weight in the final food.

For example:

The following ingredient list illustrates how components of tomato paste and lemon juice from concentrate in the above example could be listed along with the other ingredients in the list of ingredients. In order for this option to be plausible, a company must know the exact proportions of all components used by their ingredient suppliers.

Ingredients: Tomatoes • Sugar • Modified corn starch • Water • Concentrated lemon juice • Salt • Spices • Benzoic acid • Allura red.

Generations

Except in the case of allergens (noted below in the second example), ingredients of the third generation and so on are generally not required to be included in the ingredients list.

For example:

Consider the ingredients and components of an ice cream containing vanilla cookie pieces. In the ice cream, the vanilla cookies are an ingredient (first generation) that is flavoured with vanilla extract. The vanilla extract is a component of the cookies (second generation) and contains alcohol. The alcohol is a component of the vanilla extract, which can also be referred to as an ingredient of a component within the ice cream (third generation), therefore does not need to be declared in the list of ingredients.

However, some exceptions exist when allergens are present in the third generation or further.

For example:

Exceptions will exist if we consider the ingredients of an ice cream containing coconut cookie pieces. In the ice cream, the coconut cookies are an ingredient (first generation) that are made from ground dried coconut that contains sulphites. The dried coconut is a component of the cookies (second generation). Sulphites are a component of the dried coconut, which can also be referred to as a component within the ice cream (third generation). In this case, the ice cream with coconut pieces contains 15 ppm of sulphites. Although the sulphites are a "third generation" ingredient in the ice cream, as the final product contains more than 10 ppm of sulphites, they must still be declared.

For details, refer to the Food allergens, gluten & added sulphites.

Ingredients that generally do not have to declare their components

The following table lists foods which, when used as ingredients in other foods are exempt from declaring a component (ingredients of ingredients) [B.01.009(1), FDR]. Refer to Food allergens, gluten and added sulphites declaration for exceptions.

Table A: Ingredients exempt from component declaration
Item Ingredient
1. butter
2. margarine
3. shortening
4. lard
5. leaf lard
6. monoglycerides
7. diglycerides
8. rice
9. starches or modified starches
10. breads subject to compositional standards in Sections B.13.021 to B.13.029
11. flour
12. soy flour
13. graham flour
14. whole wheat flour
15. baking powder
16. milks subject to compositional standards in Sections B.08.003 to B.08.027
17. chewing gum base
18. sweetening agents subject to compositional standards in Sections B.18.001 to B.18.018
19. cocoa, low-fat cocoa
20. salt
21. vinegars subject to compositional standards in Sections B.19.003 to B.19.007
22. alcoholic beverages subject to compositional standards in Sections B.02.001 to B.02.134
23. cheese for which a standard is prescribed in Division 8 of the FDR, if the total amount of cheese in a prepackaged product is less 10% of the packaged product
24. jams, marmalades and jellies subject to compositional standards in Sections B.11.201 to B.11.241 of the FDR when the total amount of those ingredients is less than 5% of a prepackaged product
25. olives, pickles, relish and horseradish when the total amount of those ingredients is less than 10% of the prepackaged product
26. one or more vegetable or animal fats or oils for which a standard is prescribed in Division 9 of the FDR, and hydrogenated, modified or interesterified vegetable or animal fats or oils, if the total of those fats and oils contained in a prepackaged product is less than 15% of that prepackaged product
27. prepared or preserved meat, fish, poultry meat, meat by-product or poultry by-product when the total amount of those ingredients is less than 10% of the prepackaged product that consists of an unstandardized food
28. alimentary paste that does not contain egg in any form or any flour other than wheat flour
29. bacterial culture
30. hydrolyzed plant protein
31. carbonated water
32. whey, whey powder, concentrated whey, whey butter and whey butter oil
33. mould culture
34. chlorinated water and fluorinated water
35. gelatin
36. toasted wheat crumbs used in or as a binder, filler or breading in or on a food product

Additional notes about ingredients that generally do not have to declare their components:

  • partial declaration of some components for an ingredient exempt from component declaration is considered misleading as per subsection 5(1) of the FDA, as this gives the erroneous impression that those components are the only ones present in the final product
  • if the component of an ingredient set out in the table above [B.01.009(1), FDR], (i.e. ingredients exempt from declaring a component), is a vitamin or mineral, when a vitamin and mineral nutrient claim or statement is made on the food label, all components must be shown in brackets following the ingredient [D.01.007, D.02.005, FDR]
  • the ingredients of a sandwich made with bread are exempt from declaring components [B.01.008(3)(d), FDR]. Although a list of ingredients is required on the label of a sandwich, the components of those ingredients are not required to be declared. Some common ingredients (e.g., salami or mayonnaise) are not exempt from component declarations as per B.01.009(1) of the FDR, but when those ingredients are used to make a sandwich they are granted an exemption from declaring their components. Sandwiches are generally understood to be a filling between two pieces of bread, but as there is no legal definition, it was determined that the exemption should include foods commonly considered to be sandwiches, even if they are made with bread-like products. This exemption would apply to a sandwich made with pita or other bread-like products such as tortillas, chapatis, croissants, etc. provided the pita or other bread-like product surrounds the filling or the filling is contained between portions of the bread-like product. This exemption does not apply to open-faced "sandwiches", e.g. pizza, tuna melt, etc., or foods not commonly thought of as sandwiches such as dessert and confectionery-type products, e.g. ice cream or cookie "sandwiches", donuts with fillings, etc. There are no conditions to this exemption except for the fact that priority food allergens (definition), such as milk, must be declared when present

For example:

The label of a sandwich may have the following list of ingredients:

Ingredients: Whole wheat bread • Salami • Cheddar cheese (milk) • Mayonnaise (egg) • Lettuce • Salt • Pepper

Food preparations that generally do not have to declare their components

The following table lists food preparations and mixtures which, when used as ingredients in other foods, are exempt from declaring their components (except for the components listed in tables C and D below) [B.01.009(2), FDR]. Refer to Food allergen, gluten and added sulphites declarations for additional exceptions.

Table B: Preparations exempt from a component declaration
Item Preparation/Mixture
1. food colour preparations
2. flavouring preparations
3. artificial flavouring preparations
4. spice (definition) mixtures
5. seasoning or herb (definition) mixtures
6. vitamin preparations
7. mineral preparations
8. food additive (definition) preparations
9. rennet preparations
10. food flavour-enhancer preparations
11. compressed, dry, active or instant yeast preparations

Regardless of their quantities in the final product, spice and herb mixtures are permitted to be declared at the end of the list of ingredients as "spices" or "herbs" without declaring their ingredients or components.

Seasonings in a "seasoning preparation" should be less than 2% of the weight of the finished food to be exempt from declaring their ingredients or components, and simply referred to as "seasoning". This exemption does not apply to the ingredients listed in B.01.009(3) of the FDR (i.e. components of preparations which must always be declared) or to food allergens (definition) (i.e. mustard).

Seasoning preparations greater than 2% of the final weight of the finished food are in quantities greater than those required to flavour a food, and therefore the term "seasoning" will be accepted in these situations if all ingredients and components are declared in parenthesis immediately after the term.

The 2% rule is intended to clarify that the term "seasoning" cannot be used to shorten the list of ingredients or to hide certain components.

For example:

If a product contains peanut butter seasoning with the list of ingredients: "peanut butter seasoning and salt" this declaration is not acceptable if the "peanut butter seasoning" makes up 30% of the finished product. In this situation, all of the ingredients and components that make up the peanut butter seasoning (i.e. "peanuts, corn syrup solids, dextrose, sugar, salt, vegetable oil, shortening, imitation flavour and seasonings") must be declared in the list of ingredients. Even though the term "peanut butter seasoning" is acceptable as a common name for the ingredient the correct list of ingredients is:

Ingredients: Peanut butter seasoning (peanuts, corn syrup solids, dextrose, sugar, salt, vegetable oil, shortening, imitation flavour and seasonings) • Salt... plus the remaining 70% of ingredients

Components of preparations which must always be declared

The following substances, when present in the preparations and mixtures listed in table B above, must always be shown by their common names in the list of ingredients of the food to which the preparation or mixture is added, as if they were ingredients of that food [B.01.009(3), FDR].

Table C: Components of preparations which must always be declared
Item Ingredient
1. salt
2. glutamic acid or its salts, includes monosodium glutamate (MSG)
3. hydrolyzed plant protein
4. aspartame
5. potassium chloride
6. any ingredient or component that performs a function in, or has any effect on, that food

The components listed in the table above must be declared as if they were ingredients, as they perform a function in, or have an effect on, the final food, e.g., flavour enhancers. As the function of such ingredients (i.e., flavour enhancer), is to make other flavours more effective, flavour enhancers are considered to have an effect on the final food and, therefore, need to be declared by their common names in the list of ingredients of the final food, e.g., ethyl maltol, disodium guanylate, calcium inosinate, sodium ribonucleotides, etc.

Note: Maltol and ethyl maltol can be added to any food product where a flavour preparation or seasoning, etc. is permitted.

The components of the flavour-enhancer preparation that simply perform a function on the flavour enhancer preparation (i.e., they make the preparation easier to handle, measure, etc.), and are not considered to have an effect on the final food do not have to be declared.

For example:

  • If a lemon flavour preparation has a yellow colour added to it which will also turn the cake yellow, when the flavour is added to the cake, then the colour will be considered to have an effect on the food and must be declared in the list of ingredients.

    Or

  • If a preservative is added to a flavour enhancer preparation to preserve the stability of the preparation, but will not have the same preservative functions on the final product, then it will not have to be declared in the list of ingredients.

Components of foods which must always be declared

The following foods must always be listed by name in the list of ingredients when they are present in the foods listed in the Table A: Ingredients exempt from component declaration and the preparations and mixtures listed in Table B: Preparations exempt from a component declaration [B.01.009(4), FDR].

Table D: Components of foods which must always be declared
Item Ingredient
1. peanut oil
2. hydrogenated peanut oil, including partially hydrogenated peanut oil, as per B.01.010(3)(a) of the FDR
3. modified peanut oil

Grouping sugars-based ingredients

Purpose

The requirement to group sugars-based ingredients is intended to help consumers understand their relative proportion in the food compared to other ingredients as well as identify unfamiliar sources of sugars in their foods.

Ingredients with common names such as agave syrup, malted barley, isomaltose and pear juice concentrate may not be recognized by most Canadians as sugars-based ingredients.

In cases where a product contains a large proportion of these ingredients, grouping would move the sugars-based ingredients closer to the beginning of the ingredient list. This way, the relative proportion of sugars-based ingredients in the product is indicated more clearly.

Grouping required

In a prepackaged product, each sugars-based ingredient must be grouped after the term "Sugars" [B.01.008.3(1), FDR]. It is the manufacturer's responsibility to determine if the ingredients they use fall within the definition of a sugars-based ingredient (definition). Manufacturers must be able to provide evidence of their approach taken to identify sugars-based ingredients for CFIA to verify.

Sugars- based ingredients can be one of the following:

Ingredient that is a monosaccharide or disaccharide or a combination of these

Monosaccharides are basic units of sugar and there are only three monosaccharides: glucose, fructose and galactose. Disaccharides are sugars made up of two monosaccharide units. Common examples of disaccharides include sucrose, lactose and maltose. Therefore, a sugars-based ingredient that is a monosaccharide, disaccharide or a combination of these refers to sugars that have their common name ending in "-ose" or contains the word "sugar". This includes glucose-fructose, cane sugar, sucrose, beet sugar, and lactose. Refer to Annex 1A: Examples of sugars-based ingredients that are monosaccharide, disaccharide or a combination of these for a list of additional examples.

Ingredient that is a sweetening agent

This refers to sweetening agents as defined in, but not limited to, Division 18 of the FDR. Some sweetening agents are not in Division 18 but may have prescribed standards by other regulations or other applicable legislation, for example, maple syrup.

Examples of sweetening agents include fancy molasses, maple syrup, brown sugar, agave syrup, refined sugar syrup, honey, and other syrup. Refer to Annex 1B: Examples of sugars-based ingredients that are sweetening agents for a list of additional examples.

Ingredient that is a functional substitute for a sweetening agent

With reference to any prepackaged products, a functional substitute for a sweetening agent (definition) means a food,

  • that is not a sweetener or sweetening agent including any sugars, but
  • replaces a sweetening agent and has one or more functions of the sweetening agent including, sweetening, thickening, texturing or caramelizing [B.01.001(1), FDR].

Sweetening agents may also have other functions including, flavouring, preservation, browning/caramelization, and colouring.

A "functional substitute for a sweetening agent" is generally not an obvious source of sugars in the food. For example, fruit juice concentrate may not be familiar to some as a source of sugars. Grouping of sugars-based ingredients may help consumers identify these hidden sources of sugars in their foods.

For example:

Below are the ingredients in a fruit-berry salad dressing in descending order.

Ingredients: Water, Concentrated white grape juice, White wine vinegar, Canola oil, Strawberry puree, Dijon mustard (water, mustard seeds, vinegar, salt, turmeric), Concentrated raspberry juice, Concentrated blackberry juice, Salt, Concentrated lemon juice, Poppy seeds, Spices and Xanthan gum

The ingredients, "concentrated white grape juice, strawberry puree, concentrated raspberry juice, and concentrated blackberry juice" are replacing a sweetening agent (e.g., sugar) and have one or more functions of the sweetening agent such as texturing (strawberry puree) and colour (concentrated juices). Therefore these ingredients are functional substitutes for a sweetening agent and must be grouped together in brackets following the term "Sugars", as follows:

Ingredients: Water • Sugars (concentrated white grape juice, strawberry puree, concentrated raspberry juice, concentrated blackberry juice) • White wine vinegar • Canola oil • Dijon mustard (water, mustard seeds, vinegar, salt, turmeric) • Salt • Concentrated lemon juice • Poppy seeds • Spices • Xanthan gum
Contains: Mustard

As such, the sugars-based ingredients listed below in Annex 1C: List of sugars-based ingredients that are functional substitutes for sweetening agents must always be grouped after the term "Sugars" in the list of ingredients. Apart from this list, there are other ingredients containing sugars, which may have a function in the food in addition to sweetening. It is the responsibility of the manufacturer to be able to demonstrate that such an ingredient performs a function other than sweetening the food, otherwise it should be grouped. It is also permitted to include in the sugars grouping, any other ingredient containing sugars regardless of its purpose in the food.

Refer to Annex 1C: List of sugars-based ingredients that are functional substitutes for sweetening agents for a list of substitutes that must be grouped.

No grouping required

Sugar alcohols (e.g., maltitol) and sweeteners such as steviol glycosides or aspartame cannot be grouped as "Sugars" in the list of ingredients.

Since the aim is to group hidden sources of sugars, there is no need to group ingredients such as chocolate that are well-known as sources of sugar. In addition, no grouping is required for ingredients that are visible in intact pieces or layers such as yogurt coating or pieces of frozen fruits.

For example:

Consider a cookie manufacturer who produces raisin and cranberry cookies. The manufacturer adds dried raisins and cranberries to the cookie dough at the final stage of production just before baking the cookies. The dried fruits appear as distinct and intact pieces within the cookie dough and therefore are considered as obvious sources of sugars.

Some ingredients do not meet the definition of sugars-based ingredients. However, the total sugars content of the prepackaged product they are in will still be captured by the "Sugars" declaration in the NFt.

Refer to Annex 2: Examples of ingredients for which grouping with sugars is not required for additional examples that do not meet the definition of sugars-based ingredients.

Some ingredients fall within the definition of sugars-based ingredients but are not required to be grouped when they are in the following prepackaged products [B.01.008.3(4), FDR]:

1. Sweetening agents packaged and sold as such [B.01.008.3(4)(a), FDR].

Sweetening agents (definition) include icing sugar, maple syrup, lactose, agave syrup, sugar, golden corn syrup, molasses, glucose syrup, and dextrose.

For example:

Consider the ingredient list on prepackaged golden corn syrup. The list of ingredients will show:

Ingredients: Glucose • Water • Refiner's syrup • Salt • Vanillin

2. Fruit or vegetable juice or vegetable drink that does not contain any sweetening agent, including any blend of these juices and drinks [B.01.008.3(4)(b), FDR]

These prepackaged products are fruit or vegetable juices or blends that do not contain any added sweetening agents.

For example:

The prepackaged product "100% orange and tangerine juice" will have the following list of ingredients.

Ingredients: Orange juice • Tangerine juice

3. (a) Fruit or vegetable juice or vegetable drink that does not contain any sweetening agent, including any blend of those juices and drinks to which fruit or vegetable purée or any blend of these purées has been added [B.01.008.3(4)(b)(i), FDR]

These prepackaged products are fruit or vegetable juices or vegetable drinks and purées or a blend of these, with no added sweetening agents.

For example:

The prepackaged product "ABC fruit and vegetable juice" is made from a blend of fruit and vegetable juices to which fruit and vegetable purées have been added. The ingredient list is as follows:

Ingredients: Apple juice • Carrot juice • Mango purée • Sweet potato purée • Natural flavour • Vitamin C

(b) Fruit or vegetable juice or vegetable drink that does not contain any sweetening agent, including any blend of those juices and drinks that are reconstituted [B.01.008.3(4)(b)(ii), FDR]

These prepackaged products are fruit or vegetable juices or vegetable drinks or a blend of these, with no added sweetening agents, provided they have been reconstituted to regular strength.

For example:

"Reconstituted orange and apple juice" will have the following list of ingredients.

Ingredients: Water • Concentrated orange juice • Concentrated apple juice

This exemption also applies to a prepackaged product that is a blend of reconstituted fruit or vegetable juices. The ingredient list is shown as follows:

Ingredients: Reconstituted apple juice (water, concentrated apple juice) • Reconstituted grape juice (water, concentrated grape juice) • Natural flavour • Vitamin C

(c) Fruit or vegetable juice or vegetable drink that does not contain any sweetening agent, including any blend of those juices and drinks that are a concentrate intended for dilution and consumption as juice or drink [B.01.008.3(4)(b)(iii), FDR]

An example of this type of prepackaged product is a frozen concentrated fruit juice that only requires dilution with water before consumption.

For example:

The list of ingredients of a frozen concentrated orange juice will be shown as follows:

Ingredients: Concentrated orange juice

4. Fruit or vegetable purée, including any blend of these purées, that does not contain any sweetening agent [B.01.008.3(4)(c), FDR]

These prepackaged products are fruit or vegetable purées or blends made without added sweetening agents.

For example:

A jar of unsweetened apple sauce is made of reconstituted apple purée without any added sweetening agent. The ingredient list on the jar would be declared as follows:

Ingredients: Apples • Water • Ascorbic acid

Consider also a jar of unsweetened strawberry-kiwi apple sauce is made of concentrated apple puree and a blend of fruit purees, without any sweetening agent. Water is added to reconstitute it to regular strength.

Ingredients: Apples • Water • Concentrated apple puree • Concentrated black carrot juice (for colour) • Concentrated blackcurrant juice (for colour) • Strawberry puree • Kiwi puree • Ascorbic acid • Natural flavour

5. Prepackaged products that contain only one sugars-based ingredient and the sugars-based ingredient contains the word "sugar" in its common name [B.01.008.3(4)(d), FDR]

For example:

The prepackaged product "lemon cookies" is made with cane sugar, the only sugars-based ingredient in the product, and "cane sugar" contains the word "sugar" in its common name. Therefore, this product is exempt from grouping cane sugar in brackets following the term "Sugars", as shown in the list of ingredients below:

Ingredients: Enriched flour • Buttermilk (cultured milk, salt, sodium citrate) • Butter • Cane sugar • Lemon zest • Sea salt • Sodium bicarbonate.
Contains: Wheat • Milk.

6. Formulated liquid diets and human milk substitutes (Infant formula) [B.01.008.3(4)(e), FDR]

Prepackaged products such as human milk substitutes (commonly known as infant formula) and formulated liquid diets are exempted from grouping their sugars-based ingredients because; these products are already strictly regulated and should not be discouraged for consumption because of added sugars-based ingredients.

Order of sugars-based ingredients

When a prepackaged product contains one or more sugars-based ingredients, these ingredients must be declared in parentheses immediately following the term "Sugars" in the list of ingredients [B.01.008.3(1), FDR].

The order must be in descending order of proportion by weight or percentage of the sugars-based ingredients added to the mixing bowl [B.01.008.3(2), FDR].

For example:

A prepackaged product of molasses cookies has the following ingredients:

Flour • Fancy molasses • Vegetable oil shortening • Brown sugar • Liquid whole egg • Sugar • Salt • Sodium bicarbonate • Spices • Allura red

In this example, the sugars-based ingredients "fancy molasses", "brown sugar" and "sugar" must be grouped together in brackets after the term "Sugars", in descending order of proportion by weight, as follows:

Ingredients: Sugars (fancy molasses, brown sugar, sugar) • Flour • Vegetable oil shortening • Liquid whole egg • Salt • Sodium bicarbonate • Spices • Allura Red
Contains: Wheat • Egg

Sugars-based ingredients in components

It is not required to group sugars-based ingredients in components (definition). This means when components such as sugar or dextrose appear in parentheses after an ingredient, they will stay ungrouped in those parentheses along with other components. None of the components need to be part of the overall "Sugars" grouping in the list of ingredients.

However, when suppliers sell certain foods in Canada, the sugars-based ingredients would already be grouped. In such cases, manufacturers are allowed to keep the sugars-based ingredients grouped when declaring components.

For example:

Consider the ingredient list of prepackaged chocolate chip cookie, made with chocolate chips that contain two sugars-based ingredients (sugar and dextrose). The ingredient list declared on the chocolate chips by the supplier is as follows:

Ingredients: Unsweetened chocolate • Sugars (sugar, dextrose) • Soy lecithin • Artificial flavour

In this example, chocolate chips are not required to be grouped after the term "Sugars". The manufacturer of the chocolate chip cookie could transfer the components just as they are to the cookie's list of ingredients:

Ingredients: Sugars (brown sugar, sugar) • Flour • Chocolate chips [unsweetened chocolate, Sugars (sugar, dextrose) • soy lecithin • artificial flavour] • Butter • Dried whole egg • Sodium bicarbonate • Vanilla extract • Salt

In the above example, there is no need to "pull out" its components that are already grouped (i.e. sugar and dextrose), unless a simplified version of the ingredient list is used.

In a simplified version, sugar and dextrose would need to be grouped with the other sugars-based ingredients in the list of ingredients. For an example of a simplified version with all components listed as if they were ingredients, refer to order of components.

Component declaration for sugars-based ingredients within sugar grouping

If a sugars-based ingredient has components, the requirements related to the order of components must be respected when declaring these components.

For example:

In a salad dressing's list of ingredients, there might be sugars-based ingredients, such as "concentrated white grape juice", with components of their own. While the sugars-based ingredient must be included within the sugar grouping, its components may be declared in 2 ways.

Option 1:
After the sugars-based ingredient's common name in the sugar grouping.

Ingredients: Water • Sugars [concentrated white grape juice (white grape juice concentrate, water, preservative, color)] • Dijon mustard (water, mustard, vinegar, salt)

Or,

Option 2:
In the list of ingredients (if the amounts of each component are known) in descending order of proportion.

Ingredients: Water • Sugars (white grape juice concentrate) • Mustard • Vinegar • Salt • Preservative • Color

You must use one or the other option above.

Common names

Ingredients (definition) and their components (definition) must be declared in the list of ingredients by their common names [B.01.010, FDR].

Mandatory common names for ingredients and components

To assist consumers in making their food choices, specific mandatory common names are required to be used as to identify food ingredients or components. For example, the plant source of certain ingredients, such as hydrolyzed plant proteins, starches, modified starches and lecithin must be named (e.g., hydrolyzed soy protein, wheat starch, modified wheat starch, soy lecithin).

For example:

Shortening that contains vegetable oil or partially hydrogenated vegetable oil must be listed in the list of ingredients of a food as "vegetable oil shortening" (unless it contains one of those fats and oils that must be mentioned by name e.g. coconut oil, palm oil, palm kernel oil, cocoa butter, peanut oil). Shortening containing lard should be called "lard shortening". Shortening does not have to be qualified in a list of ingredients as "hydrogenated" or "partially hydrogenated".

The following table lists all the mandatory common names for foods used as ingredients or components (ingredients of ingredients) in other foods [B.01.010(3)(a), FDR]:

Mandatory common names of ingredients and components
Item Ingredient or component Mandatory common name
1. any oil, fat or tallow described in Section B.09.002 of Division 9, except lard, leaf lard or suet the name of the meat from which the oil, fat or tallow is obtained plus "oil", "fat" or "tallow"
2. shortening or margarine containing fats or oils, except shortening or margarine containing coconut oil, palm oil, palm kernel oil, peanut oil or cocoa butter "shortening" or "margarine" modified by "vegetable oil" or "marine oil" or by the common name of the vegetable, animal or marine oil or fat used
3. shortening or margarine containing coconut oil, palm oil, palm kernel oil, peanut oil or cocoa butter "shortening" or "margarine" modified by the common name of the vegetable oil or fat used
4. meat the name of the meat
5. poultry meat the name of the poultry
6. fish the name of the fish
7. plant protein product the name of the plant plus "protein product"
8. hydrolysed plant protein "hydrolyzed" plus the name of the plant plus "protein" or "hydrolysed" plus the name of the plant plus "protein"
9. any protein isolate the name of the source of the protein plus "protein" or the common name of the protein isolate
10. any meat by-product described in Section B.14.003, other than gelatin the name of the meat plus "by-product" or the name of the meat plus the name of the meat by-product
11. any poultry meat by-product described in Section B.22.003 the name of the poultry plus "by-product" or the name of the poultry plus the name of poultry meat by-product
12. any oil or fat referred to in Section B.09.002 that has been hydrogenated or partially hydrogenated, including tallow, but not including lard "hydrogenated" plus the name of the meat from which the oil, fat or tallow is obtained, plus "oil", "fat" or "tallow"
13. any oil or fat referred to in Section B.09.002 of Division 9, including tallow, that has been modified by the complete or partial removal of a fatty acid "modified" plus the name of the meat from which the oil, fat or tallow is obtained, plus "oil", "fat" or "tallow"
14. one or more vegetable fats or oils that have been hydrogenated or partially hydrogenated except coconut oil, palm oil, palm kernel oil, peanut oil or cocoa butter "hydrogenated vegetable oil" or "hydrogenated vegetable fat" or "hydrogenated" plus the specific name of the oil or fat
15. coconut oil, palm oil, palm kernel oil, peanut oil or cocoa butter that has been hydrogenated or partially hydrogenated "hydrogenated" plus the specific name of the oil or fat
16. one or more marine fats or oils that have been hydrogenated or partially hydrogenated "hydrogenated marine oil" or "hydrogenated marine fat" or "hydrogenated" plus the specific name of the oil or fat
17. one or more vegetable fats or oils that have been modified by the complete or partial removal of a fatty acid, except coconut oil, palm oil, palm kernel oil, peanut oil or cocoa butter "modified vegetable oil" or "modified vegetable fat" or "modified" plus the specific name of the oil or fat
18. coconut oil, palm oil, palm kernel oil, peanut oil or cocoa butter that has been modified by the complete or partial removal of a fatty acid "modified" plus the specific name of the oil or fat
19. one or more marine fats or oils that have been modified by the complete or partial removal of a fatty acid "modified marine oil" or "modified" plus the specific name of the oil or fat
20. starch the name of the plant plus starch
21. the name of the plant plus starch modified plus the name of the plant plus starch
22. lecithin the name of the source of the lecithin plus lecithin
23. crustacean the name of the crustacean
24. shellfish the name of the shellfish

Class/Collective names for ingredients and components

Certain foods and classes of foods, may be listed by collective or class names. These collective names may only be used if the individual ingredients/components of that class are not shown separately in the list of ingredients by their individual common name.

The following table provides optional common names for foods or classes of foods used as ingredients or components in other foods [B.01.010.10(3)(b), FDR].

Class names for ingredients
Item Ingredient or component Class/Collective name
1. one or more vegetable fats or oils, except coconut oil, palm oil, palm kernel oil, peanut oil or cocoa butter "vegetable oil" or "vegetable fat"
2. one or more marine fats or oils marine oil
3. Repealed
4. one or more substances prepared for their flavouring properties and produced from animal or vegetable raw materials or from food constituents derived solely from animal or vegetable raw materials flavour
5. one or more substances prepared for their flavouring properties and derived in whole or in part from components obtained by chemical synthesis "artificial flavour", "imitation flavour" or "simulated flavour"
6. one or more spices, seasonings or herbs except salt "spices", "seasonings" or "herbs" (definition)
7. any of the following in liquid, concentrated, dry, frozen or reconstituted form, namely, butter, buttermilk, butter oil, milk fat, cream, milk, partly skimmed milk, skim milk and any other component of milk the chemical composition of which has not been altered and that exists in the food in the same chemical state in which it is found in milk milk ingredients
7.1 any of the following in liquid, concentrated, dry, frozen or reconstituted form, namely, calcium-reduced skim milk (obtained by the ion-exchange process), casein, caseinates, cultured milk products, milk serum proteins, ultrafiltered milk, whey, whey butter, whey cream and any other component of milk the chemical state of which has been altered from that in which it is found in milk modified milk ingredients
7.2 one or more ingredients or components set out in item 7 combined with any one or more ingredients or components set out in item 7.1 modified milk ingredients
8. any combination of disodium phosphate, monosodium phosphate, sodium hexametaphosphate, sodium tripolyphosphate, tetrasodium pyrophosphate and sodium acid pyrophosphate "sodium phosphate" or "sodium phosphates"
9. one or more species of bacteria bacterial culture
10. one or more species of mould "mold culture" or "mould culture"
11. preparation containing rennin rennet
12. milk coagulating enzymes from Aspergillus oryzae RET-1 (pBoel777), Endothia parasitica, Mucor miehei or Mucor pusillus Lindt microbial enzyme
13. one or more substances that function to impart flavour and that are obtained solely from the plant or animal source after which the flavour is named the name of the plant or animal source plus the word "flavour"
14. toasted wheat crumbs made by cooking a dough prepared with flour and water, which may be unleavened, or chemically or yeast leavened, and which otherwise complies with the standard prescribed by Section B.13.021 or B.13.022 toasted wheat crumbs
15. that portion of chewing gum, other than the coating, that does not impart sweetness, flavour or colour gum base
16. sugar, liquid sugar, invert sugar or liquid invert sugar, singly or in combination sugar
17. glucose syrups and isomerized glucose syrups, singly or in combination, where the fructose fraction does not exceed 60% of the sweetener on a dry basis glucose-fructose
18. glucose syrups and isomerized glucose syrups, singly or in combination, where the fructose fraction exceeds 60% of the sweetener on a dry basis fructose syrup
19. sugar or glucose-fructose, singly or in combination sugar/glucose-fructose
20. water to which carbon dioxide is added carbonated water
21. one or more of the following food additives, namely, potassium bisulphite, potassium metabisulphite, sodium bisulphite, sodium dithionite, sodium metabisulphite, sodium sulphite, sulphur dioxide and sulphurous acid sulfites, sulfiting agents, sulphites or sulphiting agents
22. demineralized water or water otherwise treated to remove hardness or impurities, or fluoridated or chlorinated water water
23. wine vinegar, spirit vinegar, alcohol vinegar, white vinegar, grain vinegar, malt vinegar, cider vinegar or apple vinegar, singly or in combination vinegar

Common name and ingredient function

When vitamins, mineral nutrients and amino acids are added to food, the purpose of the addition must be determined (e.g., as food additives for fortification) in order to determine the appropriate common name.

For example:

When ascorbic acid is added to a food as a vitamin for enrichment purposes, it may be declared as either "vitamin C" or "ascorbic acid" in the list of ingredients. However, when ascorbic acid is used as a food additive for purposes such as bleaching, maturing, dough conditioning, preservation etc., the name "ascorbic acid" must be used in the list of ingredients, and not "vitamin C". If other forms of ascorbic acid are used, e.g. sodium ascorbate, ascorbyl palmitate, etc., the correct name must be used in the list of ingredients.

Additionally, when preparations of vitamins, mineral nutrients, food additives and flavour enhancers are added to food, they must be shown in the list of ingredients by the common name of their active ingredient(s) present, e.g., vitamin A palmitate. Yeast preparations may be declared as "yeast".

Additional information in the list of ingredients

In general, the common name of an ingredient is the only information that should appear in the list of ingredients, unless a particular adjective or descriptive phrase is prescribed by regulation. Although there is no specific prohibition against additional descriptive information from appearing in the list of ingredients, the general prohibition from declaring any information that is misleading or likely to create an erroneous impression applies [6(1), SFCA; 5(1), FDA]. Declarations about nutrient or other characteristics of ingredients that imply characteristics about the final food therefore may be considered misleading. Refer to General principles for labelling and advertising for more information about misleading.

For example:

The term "iron" on its own is sufficient to represent iron in the list of ingredients as a food regardless of whether or not the iron is in reduced carbonyl or electrolytic form. The terms "reduced", "carbonyl" and "electric" represent processes only and are not considered part of the common name of the mineral nutrient. It is unadvisable to use the term "reduced iron" in the list of ingredients as some consumers can be confused by this terminology and it may lead consumers to believe that the food is reduced in iron which can have serious consequences for those who suffer from hemochromatosis and must avoid excess iron.

As ingredients must be declared by their common names, it is generally not appropriate for brand names to appear in the list of ingredients. There will however be no objection to factual descriptions appearing separately and distinctly from the list of ingredients on any other part of the label.

Acceptable additional information appearing in the list of ingredients can include examples such as:

  • a statement of an additive's function, in brackets, e.g., "soy lecithin (an emulsifier)"
  • a description naming the type of vitamin, in brackets, following the form of the vitamin added, e.g., "thiamine mononitrate (vitamin B1)"
  • a description of a significant alteration of an ingredient, e.g., "deflavoured apple juice"
  • adjectives and descriptions that help to differentiate different versions of the same ingredient, e.g., "organic", "fresh tomatoes", "sun dried tomatoes", "pure milk chocolate", "natural spring water", etc.

Other acceptable descriptions for use in the list of ingredients will be considered on a case-by-case basis. For further details, refer to common name.

Multiple ingredient lists

There should be one list of ingredients for each different kind of food in a multi-pack product in both official languages. These declarations must all use the appropriate Canadian ingredient and component common names in accordance with the Food and Drug Regulations or the Safe Food for Canadians Regulations. For further details, refer to common name.

Food allergens, gluten & added sulphites

Food allergens and gluten must be declared in the list of ingredients in which they are present, or in a "food allergen source, gluten source and added sulphites statement" (definition), by their prescribed source names [B.01.010.1(2), FDR]. Note: The words "contains statement" and "food allergen source, gluten source and added sulphites statement" have the same meaning and are used interchangeably in this section for ease of reference.

Added sulphites at levels of 10 ppm or more, and that are not already required to be shown in the list of ingredients, must be declared in the list of ingredients by their prescribed source names. If a contains statement is used, the declaration must use one of these common names: "sulfites", "sulfiting agents", "sulphites" or "sulphiting agents" [B.01.010.2(3), B.01.010.2(6), FDR].

If a contains statement is used on the label, all allergen, gluten and added sulphite information must appear in the statement at least once, even if that information is already shown in the list of ingredients for the product [B.01.010.3(1)(b), B.01.010.3(2), FDR].

For example:

Ingredients: Wheat flour • Water • Vegetable oil margarine • Sugar • Yeast • Canola oil shortening • Potato starch • Garlic • Salt • Parsley • Seasoning • Diacetyl acid esters of mono & diglycerides • Whey powder • Calcium propionate • Potassium bisulphite
Contains: Wheat • Milk • Sesame • Sulphites

In this example, all food allergens, gluten sources and added sulpthites are declared at least once in the contains statement, even though wheat and potassium bisulphite (sulphites) already appear in the ingredient list. Since a contains statement is being used to declare other known allergen sources (milk and sesame), wheat and sulphites must appear in both places.

Order of food allergen and gluten source declaration

The requirement for food allergens and gluten declarations apply to all generations (definition) of ingredients. Therefore, food allergens and gluten must be declared regardless of which generation they are present in. For example, if they are present in the third or fourth generation of ingredients they will still have to be declared in the list of ingredients on the product label or in a contains statement. Refer to Generations for more information on the generations of ingredients.

The source of food allergens and gluten must be declared in one of two ways:

  1. in the list of ingredients [B.01.010.1(2)(a), FDR], or
  2. in a "food allergen source, gluten source and added sulphites statement" [B.01.010.1(2)(b), FDR]

Option 1: The prescribed source name of the food allergen or gluten may be shown in parentheses in the list of the ingredients, as follows:

  • (a) Immediately after the ingredient that is shown in the list, if the food allergen or gluten [B.01.010.1(8)(a)(i)-(iii), FDR]:
    • (i) is that ingredient
    • (ii) is present in that ingredient but is neither a component of that ingredient nor present in a component of that ingredient, or
    • (iii) is a component of that ingredient or is present in a component of that ingredient, and the component is not shown in the list of ingredients. Note that if the source of a food allergen or gluten is shown immediately following the ingredient, the components of the ingredient must be shown immediately after the allergen source [B.01.008.2(5)(a), FDR]

For example:

Ingredients: Flour (wheat) • Liquid albumin (egg) • Vegetable oil • Sugar • Chocolate chips (milk) (sugar, chocolate liquor, cocoa butter, milk ingredients, soy lecithin, salt, natural flavour).

In this example:

  • wheat protein is an inherent part of flour but is not a component. Since wheat is both a food allergen and gluten source, it must be declared
  • liquid albumin is an egg protein. As eggs are a food allergen, egg must be declared
  • the components of the ingredient "Chocolate" are shown in parentheses immediately after the allergen source milk.

or

  • (b) Immediately after the component that is shown in the list of ingredients, if the food allergen or gluten is the component or is present in the component [B.01.010.1(8)(b), FDR]

For example:

Ingredients: Pastry pieces [flour (wheat), butter (milk), liquid albumin (egg), canola oil] • Sugar • Natural flavour.

In this example, as "pastry pieces" are not exempt from component declaration, its components must be declared. The required food allergen and gluten prescribed source names are declared in parentheses after the component in which they are present:

  • wheat is a part of flour
  • butter is made from milk
  • liquid albumin is an egg protein

Option 2: The prescribed source name of a food allergen or gluten may be shown on the label of a product in a contains statement that complies with the naming and location restrictions outlined in B.01.010.3(1) of the FDR if the food allergen or gluten:

  • (a) is an ingredient, or present in an ingredient that is not shown in the list of ingredients, but is not a component of that ingredient or present in a component of that ingredient [B.01.010.1(9)(a), FDR]

    or

  • (b) is a component or present in any generation (definition) of a component and neither the component nor the ingredient in which it is present is shown in the list of ingredients [B.01.010.1(9)(b), FDR]

For example:

Protective edible waxes are part of the post-harvest and handling technologies routinely used by the fresh produce industry to minimize moisture loss, prolong the shelf life and to improve the appearance of fresh produce. Edible wax coatings on fresh fruits and vegetables can potentially contain soy, chitosan (derived from crustaceans) and caseinate components (derived from milk).

Wax coating compounds and their components are not required to be shown on the label of any prepackaged fresh fruits or vegetables. Therefore, if any food allergens, gluten or added sulphites are present in these wax coatings, they must be declared on the labels of prepackaged fruits and vegetables. As wax coatings are exempt from being declared as ingredients and components as per B.01.008(3)(a) of the FDR, the other components of the wax coatings are still exempt from declaration and do not need to appear in a list of ingredients.

For instance, if a bag of prepackaged apples has a wax coating containing caseinate compounds, as casein contains milk, the food allergen source "milk" must be declared on the label of the apples. The food allergen source "milk" can be declared in a contains statement on the label: "Contains: Milk".

Order of added sulphites declaration

Sulphites, like any other food additive, are required to be declared in the list of ingredients of food labels when they are added directly to a prepackaged product as an ingredient or a component of an ingredient that is not exempt from component declaration. If added sulphites are present in a prepackaged product in the first generation (i.e. ingredient) or second generation (i.e. component), and are not exempt from declaration, they must be declared in the list of ingredients regardless of their quantity. Refer to Generations for more information on the generations of ingredients.

In the following examples, sulphites are a component of the dried apricots. Dried apricots are not exempt from component declaration, therefore sulphites must be declared along with all the other components of the dried apricots, regardless of their quantities.

  • Sulphites added as a food additive ingredient

For example: Consider an example of dried apricots where sulphites added at a level of 5 ppm

Ingredients: Apricots • Sugar • Sulphites

  • Sulphites added as a component of an ingredient that is not exempt from component declaration

For example:

Ingredients: Rolled oats • Flour (wheat) • Dried apricots (apricots, sugar, sulphites) • Liquid whole egg (liquid whole egg, beta-carotene) • Salt • Sodium bicarbonate • Soy lecithin

In this example, allergen sources such as wheat in flour may instead be shown in the contains statement.

Added sulphites declaration

If added sulphites are present in a prepackaged product in a total amount of 10 parts per million or more, and are not already required to be shown in the list of ingredients under section B.01.008 or B.01.009 of the FDR, the sulphites must be shown on the label of the product in:

  • the list of ingredients, or
  • in a "food allergen source, gluten source and added sulphites statement" that complies with the requirements under section B.01.010.3(1) of the FDR [B.01.010.2(3), FDR]

Sulphites that are declared in the list of ingredients must be shown as follows:

(a) sulphites that are a component of an ingredient that is shown in the list of ingredients must be shown either in parentheses immediately after the ingredient or at the end of that list, where they may be shown in any order with the other ingredients that are shown at the end of that list under B.01.008.2(4) of the FDR [B.01.010.2(7)(a), FDR]; and

(b) in all other cases, the sulphites must be shown at the end of the list of ingredients where they may be shown in any order with the other ingredients that are shown at the end of that list under subsection B.01.008.2(4) of the FDR [B.01.010.2(7)(b), FDR]

For example:

In a box of cookies that are made with apricot jam, sulphites are a component of the apricot jam with pectin. Assuming that the jam is only 5% or less of the cookie, it is exempt from component declaration [B.01.009(1), item 24, FDR], and that the sulphites are at a level of 13 ppm (therefore greater than 10 ppm), the sulphites must be declared as per subsection B.01.010.2(3) of the FDR. Both of the examples below are acceptable ways to declare sulphites (at levels of 10 ppm or more) in the list of ingredients.

In the list of ingredients, sulphites can be declared in parentheses after apricot jam with pectin:

Ingredients: Rolled oats • Flour (wheat) • Liquid whole egg • Apricot jam with pectin (sulphites) • Salt • Sodium bicarbonate • Soy lecithin

Or at the end of the list of ingredients in any order:

Ingredients: Rolled oats • Flour (wheat) • Liquid whole egg • Apricot jam with pectin • Salt • Sodium bicarbonate • Soy lecithin • Sulphites

Note: In situations where added sulphites are a component that must be declared in the list of ingredients as per B.01.008(1)(b) of the FDR, but the total amount is less than 10 parts per million, then the sulphites will not have to be declared in the contains statement. In both examples, allergen sources such as wheat in flour may instead be shown in the contains statement.

Cross contamination statements

A cross contamination (or precautionary) statement is a declaration on the label of a prepackaged product that alerts consumers of the possible presence of an allergen in the food. For more details, refer to Food allergen cross contamination (or precautionary) statements.

Prescribed source names

Food allergens and gluten prescribed source names

The prescribed source of a food allergen present in a prepackaged product must be declared as follows [B.01.010.1(6), FDR]:

Food allergen prescribed source names
Food allergens Prescribed source name
Almonds Almond, Almonds
Brazil nuts Brazil nut, Brazil nuts
Cashews Cashew, Cashews
Hazelnuts Hazelnut, Hazelnuts
Macadamia nuts Macadamia nut, Macadamia nuts
Pecans Pecan, Pecans
Pine nuts Pine nut, Pine nuts
Pistachios Pistachio, Pistachios
Walnuts Walnut, Walnuts
Peanuts Peanut, Peanuts
Sesame seeds Sesame, Sesame seed, Sesame seeds
Wheat or triticale Wheat or Triticale
Eggs Egg, Eggs
Milk Milk
Soybeans Soy, Soya, Soybean or Soybeans
Powdered mustard Mustard, Mustard flour, Ground mustard
Fish, crustaceans, shellfish Common name of the fish, crustacean or shellfish
Mustard seeds Mustard, Mustard seed or Mustard seeds

The prescribed source of gluten from the grain of a cereal referred to in the definition of "gluten", derived from that grain, or from the grain of a hybridized strain cereal from one or more of the cereals referred to in the "gluten" definition, must be declared as follows [B.01.010.1(7), FDR]:

Gluten prescribed source names
Gluten Prescribed source names
Barley Barley
Oats Oats
Rye Rye
Triticale Triticale
Wheat Wheat

Food allergens and gluten only have to be declared once in the list of ingredients on the label of all prepackaged products. Further declaration is not required when the prescribed source names for allergens and gluten are already part of the common name of the ingredient or component which they are in, or are already declared in the parenthesis immediately after an ingredient or component [B.01.010.1(10), FDR]. There is however no prohibition from declaring food allergens or gluten more than once unless it would result in a non-compliance with other regulations or legislation.

For example:

Ingredients: Enriched flour (wheat) • Buttermilk (cultured milk, salt, sodium citrate) • Butter • Cane sugar • Lemon zest • Sea salt • Sodium bicarbonate.

In the above example, all food allergen and gluten sources are declared appropriately in the list of ingredients, either in the parentheses or as part of the common name of the ingredient. Although butter is a milk source, as the FDR states, food allergens, gluten and added sulphites only have to be declared once on the label. As milk is identified in the common name of cultured milk, it does not have to be declared as a source for butter.

Sulphites prescribed source names

If sulphites are declared in the list of ingredients, they must be declared as follows [B.01.010.2(6), B.01.010.2(8), FDR]:

Sulphites prescribed source names
Sulphites Prescribed source names
potassium bisulphite sulfites, sulfiting agents, sulphites or sulphiting agents
or
Potassium bisulphite
potassium metabisulphite sulfites, sulfiting agents, sulphites or sulphiting agents
or
Potassium metabisulphite
sodium bisulphite sulfites, sulfiting agents, sulphites or sulphiting agents
or
Sodium bisulphite
sodium metabisulphite sulfites, sulfiting agents, sulphites or sulphiting agents
or
Sodium metabisulphite
sodium sulphite sulfites, sulfiting agents, sulphites or sulphiting agents
or
Sodium sulphite
sodium dithionite sulfites, sulfiting agents, sulphites or sulphiting agents
sulphur dioxide sulfites, sulfiting agents, sulphites or sulphiting agents
sulphurous acid sulfites, sulfiting agents, sulphites or sulphiting agents

As long as one of the prescribed source names for sulphites listed above are present, or are already declared in the parenthesis immediately after another ingredient or component, further declaration is not required in the list of ingredients [B.01.010.2(10), FDR]. However, note that there is no prohibition from declaring sulphites more than once unless it would result in a non-compliance with other regulations or legislation.

Bilingualism

The list of ingredients must be shown in both English and French unless the product is exempt from bilingual labelling [B.01.012, FDR]. For further details, refer to Bilingual labelling.

The English and French versions of the list of ingredients must begin on a separate line, except, for small packages with an available display surface (ADS) of less than 100 cm2, where the second language version of the list of ingredients may start after the end of the first language list [B.01.008.2(9), FDR].

Flexibility in the declaration of a list of ingredients

Sometimes there is variation in the supply of certain ingredients for natural or economic reasons, which results in manufacturers substituting, varying or omitting certain ingredients that are normally used. Section B.01.011 of the FDR and section 284 of the SFCR provide an orderly procedure to outline how manufacturers can substitute, vary or omit ingredients while maintaining a correct list of ingredients for consumers.

Omissions and substitutions

When ingredients or components are omitted or substituted during a 12-month period, all of the foods that may be used as ingredients or components throughout the 12-month period must be shown in the list of ingredients. It must be clearly stated as part of the list of ingredients that the ingredient or component might be omitted/substituted. The ingredients that may be omitted or substituted are grouped with the same class of foods that are otherwise used as ingredients or components and the foods within each group must be listed in descending order of the proportion in which they will be needed during the 12-month period [B.01.011(1), FDR; 284(1), SFCR].

Variations

When proportions of ingredients or components are varied, the list of ingredients may show the ingredients or components on the label in the same proportions throughout the 12-month period if it is clearly stated as part of the list of ingredients that the proportions indicated are subject to change, and the ingredients or components are listed in descending order of the proportion in which they are likely to be used for the majority of the 12-month period [B.01.011(2), FDR; 284(2), SFCR].

Therefore, there are different ways that a manufacturer can indicate in the list of ingredients if an ingredient or component has been omitted, substituted or varied. In all circumstances, the ingredients must appear at the proper place in the list of ingredients of the finished product. The class group should then appear at the proper place in the list of ingredients of the finished product.

No objection will be taken if an asterisk appears next to an ingredient to indicate that an explanation regarding an omission, substitution or variation will appear at the end of the list of ingredients.

For example:

Flexibility in the declaration of ingredients lists can appear in the marketplace as:

  • "Ingredients: Pork and/or Beef…" This statement means that the amounts of pork and/or beef will be varying in the prepackaged product over a 12-month period. A given product may contain only pork, beef, or a mixture of both pork and beef. However, as pork has been listed first, it is expected that over the 12-month calendar year, pork is present in higher quantities.
  • "Ingredients: Milk solids, Bacterial culture, Salt, *may contain Carotene." This ingredients list represents commercial butter which uses colour at some points during the year. The colour of butter varies seasonally, based on the cattle's diet. To ensure consistency, colour may be added or omitted. "May contain" is considered an appropriate way to indicate that an ingredient is sometimes omitted from the recipe.
  • "Ingredients: Baby romaine lettuce, Baby Swiss chard, Baby spinach, Baby kale, Arugula, Radicchio. The proportion of ingredients in each package may vary." Mixed green salads are usually produced in varying quantities of lettuces depending on the availability of ingredients. All of the ingredients are the same over a 12-month period, but the proportions vary. It must be clearly stated that the proportions indicated are subject to change, and they must be listed in descending order of the proportion in which they will be in for the majority of the 12-month period.
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