September 6, 2001

Mr. Ronald Burke, Director
Bureau of Food Regulatory, International and Interagency Affairs
Health Canada
Room 2395, Address Locator 0702C1
Health Protection Building, Tunney’s Pasture
Ottawa, ON K1A 0L2
Fax: (613) 941-3537

Re: Nutrition Labelling, Nutrition Claims, and Health Claims; Canada Gazette, Part I, (pub. June 16, 2001)

Dear Mr. Burke:

I would like to commend Health Canada for moving ahead with plans to introduce comprehensive food labelling reforms. I am especially impressed with the proposal to mandate comprehensive, easy-to-read nutrition labelling in a standardized format on most packaged foods.

The potential public health benefits of these reforms are enormous. I know my patients will benefit from the new nutrition labels. That said, the proposals leave some room for improvement. I urge Health Canada to take the following measures before making its final recommendations for regulatory reforms to the Cabinet’s Special Committee of Council:

• Close the loophole for labelling fresh meat: All fresh meat should be required to carry nutrition labels. If necessary, the grace period for complying with mandatory nutrition labelling rules could be extended from two to three years for pre-packed single-ingredient fresh meat, poultry, and marine and freshwater animal products, but such foods should not be exempted outright. My patients need nutrition information on all meat, poultry and seafood packages to better follow the Canada Food Guide and my advice to choose foods low in saturated fat.
• Do not exempt in-store baked goods: Do not exempt in-store baked goods (including desserts high in trans and saturated fatty acids, low-fibre breads, high calorie muffins, etc.) from the general requirement to provide nutrition information. The place of production is not relevant to the importance of the nutrition information. Grocery stores and bakeries should have little difficulty supplying this information.
• Require that the amounts of added sugars be reported on labels in addition to total sugars: Set a recommended maximum daily intake for “added sugars” and require that the amount of added sugars per serving be listed separately on nutrition labels as a percent of the recommended maximum. This information will help consumers distinguish high total-sugar foods (such as nutrient-dense fruit juice) from high added-sugar foods (such as the so-called “fruit drinks”).
• Require that the amount of folic acid be reported on labels: Reporting the amount of folic acid will encourage manufacturers to fortify foods with this important safeguard against neural tube birth defects. Disclosure will also assist women of child bearing age to select foods rich in folic acid.
• Tighten rules for making health claims: Tighten the eligibility rules for the use of health claims so that only foods low in total fat, saturated and trans fatty acids, cholesterol, sodium, and added sugars would be eligible. Potent marketing messages, such as the “calcium/vitamin D—osteoporosis” claim, should not appear on foods like ice-cream snacks, milk shakes, and cheeses that are high in saturated fat. Similarly, messages such at the “fruits/vegetables—cancer” claim should not appear on ketchup, pickles, relish, fruit jams and jellies which are not nutritious. Allowing disease risk reduction claims on foods known to increase the risk of other diseases is misleading and counter-productive.
• Tighten rules for making nutrition claims: The regulations should require that concise explanatory notes (where necessary) appear beside nutrition claims. For example, “low fat” claims should be accompanied, if appropriate, by the statement: “Not a low calorie food.”

In sum, I urge you to promptly finalize Health Canada’s proposed food labelling reforms and make the improvements described above.

Sincerely,