September 20, 1999

The Hon. Allan Rock, P.C., M.P., Minister of Health
Room 441-S, Centre Block
House of Commons
Health Canada
Ottawa, Ontario Canada K1A 0A6

Dear Minister Rock:

We are writing to draw your attention to the results of the public consultation on nutrition labelling conducted by Health Canada. In brief, there was near-unanimous support for mandatory nutrition labelling from individual Canadians as well as the health, consumer and educational organizations that filed comments. In addition, submission from the provincial governments of Ontario, British Columbia, Saskatchewan and Prince Edward Island, and municipal health authorities in Toronto and Ottawa-Carleton strongly favoured a mandatory nutrition labelling system (though the N.S. government preferred a voluntary system). We hope you will agree that the overwhelming support for mandatory labelling sets a clear direction for Health Canada's regulatory reform on this important public health issue.

We were delighted to see considerable support for mandatory nutrition labelling in nearly half of the food industry submissions filed before the August 6^th deadline. 40% of the 46 food industry submissions to express and opinion on the subject either supported or accepted mandatory nutrition labelling. This signals that the claims by food industry representatives that mandatory labelling is prohibitively expensive or otherwise not workable should be regarded with some circumspection.

We have attached a chart showing an overview of key respondents' views on the issue of whether labelling should be mandatory or remain voluntary. As you can see, the table shows that Health Canada has a clear mandate to proceed with nutrition labelling despite the objections of and viewpoints of outspoken food industry associations, such as the Food and Consumer Product Manufacturers of Canada. It seems clear that public opinion would enthusiastically support an effort to amend the Food and Drugs Act to require nutrition labelling on all foods. Requiring this information by legislative amendment to the Food and Drugs Act would give this important public health measure the stature it deserves and it would help insulate the principles of it from being eroded by food industry-initiated amendments to regulations or internal Health Canada policy directives.

Improving the public's health, not aiding the marketing objectives of certain food companies, must remain Health Canada's only concern. We thank Health Canada for this opportunity to comment and would like to offer our assistance to work toward a final resolution of this matter.

Respectfully submitted,
Bill Jeffery, L.LB.
Public Policy Analyst

CSPI is an independent consumer health organization, specializing in nutrition and food safety, that is funded in Canada by more than 135,000 subscribers to its Nutrition Action Healthletter.