This article originally appeared on the G.S. Jameson & Company blog.
By @Glenford Jameson
Health Canada has released the details of its long-awaited framework for Front-of-Package Nutrition Symbol labelling on any prepackaged food that meets or exceeds 15 per cent sodium, sugar, or saturated fat (30 per cent for prepackaged meals). The new regulations come into force on July 20, 2022 but manufacturers have until January 1, 2026 to implement changes. All of this is part of Health Canada’s Healthy Eating Strategy, which strives to encourage consumers to make healthier and more informed food choices in an effort to attack diabetes, heart disease, obesity, and other detrimental diseases.
Certain exemptions apply to the labelling requirements, though, which manufacturers should note prior to production of their prepackaged foods and/or their labels. If you manufacture single-serving food products, for example, or single ingredient foods (such as granulated sugar, maple syrup, salt, butter, plain milk, plain yogurt, cheese, ground beef, or whole cuts of poultry or fish), you are exempt from declaring a Nutrition Symbol on the front of your prepackaged food.
However, if you manufacture any prepackaged food that meets the definition found in either the Food and Drug Regulations or the Safe Food for Canadians Regulations chances are you will need to update your packaging or review your recipe within the next few years.
While updating a package to include a new symbol is always tedious and expensive, we view the changes that Health Canada has implemented as encouraging a level playing field amongst affected manufacturers, some of whom have been portrayed negatively for producing foods with equivalent sugar, sodium, or saturated fat values to their more frequently praised counterparts. High fructose juices, for example, will now bear the same Nutrition Symbol as carbonated soda; most granola bars, including those chocolate-covered ones, will display the same symbol as chocolate bars; prepackaged popcorn, often touted as the diet-friendly alternative to potato chips, will now display a symbol suggesting its sodium content. We should not be surprised to also see high levels of sugar in most gluten-free baked goods, or high levels of sodium in most meat alternatives. Unlike Canada’s rules surrounding sugars-based ingredients, which can be applied in unintentional ways, for example, these rules seem clear and enforceable on a consistent basis.
Yet, what happens if you are a manufacturer of guacamole? Assuming there are no fillers or additives, guacamole – at its core – is a combination of single ingredient vegetables and fruits. Maybe a bit of salt, and a splash of oil to help emulsify. And yet, its saturated fat content is high enough to warrant a Front-of-Package Nutrition Symbol. We could make a similar argument with apple sauce, which is ultimately puréed apples. And yet, its sugar content is high enough to warrant a Nutrition Symbol. Consumers are faced with tough choices: is apple sauce a better choice than pudding? Is guacamole a better choice than queso fundido? Either way, it appears that the effect of this new regulatory scheme is that Health Canada will attempt to curb the public’s consumption of sugar, sodium, and saturated fat by requiring all of these products to bear the same front-of-package warnings.
This particular labelling requirement is clearly not perfect, but its intention is clear and similar mandates have been received as just and effective in a number of other comparable jurisdictions. More importantly, it cannot be viewed in isolation: the Front-of-Package Nutrition Symbol must be viewed in combination with any other labelling or packaging update that Health Canada has made recently, or provided a consultation for, in an effort to encourage healthy eating practices. Health Canada and the Public Health Agency of Canada continually review different tools to improve the dietary and nutritional choices that Canadians make. For example, the Nutrition Symbol must be read side-by-side with the updated Nutrition Facts table and the grouping of sugars now found in ingredient lists, all of which become enforceable by the Canadian Food Inspection Agency as of December 2022.
As always, the Nutrition Symbol must be implemented in the required format, including correct size and placement, and therefore it serves manufacturers to have their labels reviewed prior to production.
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