1. Foods "packaged at retail" should not be exempt from mandatory nutrition
Although we agree that foods processed at retail stores may be exempt from nutrition
labelling, foods that are simply packaged at retail stores such as fresh meat, poultry, seafood,
and cheese should not be exempt. It is important that all foods provide nutrition information
so that consumers can make informed purchasing decisions especially foods such as red meat,
one of the largest sources of saturated fat in the average Canadian's diet. Diets that are high in
saturated fat increase the risk of heart disease. High-fat diets are also associated with a higher
risk of cancers of the colon, rectum, prostate, and endometrium. The Canada Food Guide to
Healthy Eating advises Canadians to "choose leaner meats, poultry, and fish" and the Nutrition
Recommendations advise us to reduce our intake of saturated fat.(2) But without nutrition
information on the labels of those products, this is difficult advice for most consumers to follow.
2. Fresh fruits, vegetables, and foods sold in bulk should not be exempt from
mandatory nutrition labelling.
Health Canada proposes that all fresh fruits and vegetables (whether packaged or not) and
bulk foods be exempt from nutrition labelling requirements. We see no reason for this arbitrary
exemption. First, the degree of processing should not determine whether nutrition information is
provided for consumers. All fruits and vegetables whether fresh, frozen, or canned should
be required to provide full nutrition information. Why should canned or frozen carrots be
required to include a nutrition label, while fresh packaged carrots are not? Nutrition information
for pre-packaged produce can simply be included on the label, as is proposed for all other
In the case of unpackaged produce and foods sold in bulk, nutrition information should
be provided at the point-of-purchase with shelf markers, bin labels, or posters. This information
should be provided in the same standardized format as is proposed for packaged food labels.
3. Added sugars should be added to the core list of required nutrients.
CSPI recommends that food labels disclose the amount of added sugars in addition to
total sugars because treating all sugars as equal fails to assist consumers in choosing a healthy
diet. While naturally occurring sugars are chemically identical to added sugars, treating them as
equal for labelling purposes provides misleading nutrition information. Added sugars are found
largely in soft drinks, baked goods, candies, and other empty-calorie, nutrient-poor foods that
most Canadians should consume in smaller quantities. In contrast, naturally occurring sugars are
found in nutrient-dense fruits and dairy products. While fruit and low-fat dairy products appear
to lower the risk of major illnesses that threaten Canadians' health,(3) foods that are high in added
sugars offer no known benefits. Instead, they increase the risk of health problems or replace
foods that appear to reduce the risk of disease.
Data from the U.S. Department of Agriculture indicate that people who consume diets
high in added sugars consume lower levels of protein, fibre, vitamins A, E, C, B-6, B-12,
riboflavin, niacin, folate, calcium, iron, zinc, and magnesium.(4) They also consume fewer
servings of grains, fruits, vegetables, meats, and dairy products than people who consume less
added sugar. For some people, diets rich in added sugars also contribute to obesity, which
increases the risk of diabetes, heart disease, high blood pressure, and other health problems.
Thus, food labels should provide information that enables consumers to distinguish added sugars
from naturally occurring sugars.
The U.S. Department of Agriculture recommends a limit of 40 g of added sugars per day.
Accordingly, we recommend that Health Canada adopt this figure as the Canadian Daily Value
(DV) so that amounts of added sugars (rather than total sugars) can also be expressed as a
"%DV" like most other nutrients.
4. Folate should be added to the core list of required nutrients.
CSPI acknowledges that dietary folate is not naturally occurring in sufficient quantities in
most foods to satisfy the 400 microgram recommended daily intake to reduce the risk of neural
tube defects such as spina bifida and fetal anencephaly. However, we believe that a mandatory
requirement for disclosure of folate content of foods would encourage consumers to choose good
sources of folate, as well as act as an effective incentive for food manufacturers to fortify their
products with folate, thereby increasing its availability in the food supply. As a result, folate
fortification of commonly consumed foods such as bread, cereals, and pasta would increase
folate intake, which is especially important for women of childbearing age who do not take folic
Taking a multivitamin with folic acid may be the most convenient and foolproof way to
ensure an adequate intake of folacin to reduce these risks. However, for the millions of
Canadians who do not take supplements, it is critical that food labels disclose folacin levels.
5. The proposed format for small packages should be revised to ensure that nutrition
information is easier to read and is provided on the label whenever possible.
Health Canada proposes that labels on packages with less than 80 cm2 of available
labelling space may either provide nutrition information in a type size no smaller than six points
or provide an address or telephone number so that consumers can obtain the nutrition
information. We recommend that manufacturers only be permitted to provide nutrition
information in one of these alternative formats when it is not physically possible to display the
information in the standard format. In the latter format, a toll-free number (not only a mailing
address) should be required so that consumers can obtain nutrition information in a simple and
timely manner. Requesting nutrition information by mail is a much more cumbersome, time-consuming method of obtaining nutrition information and it is much less likely to be used by
Health Canada also proposes that labels on packages with between 80 cm2 and 260 cm2 of
available labelling space may present nutrition information in a string design (i.e., linear format)
if there is insufficient labelling space available for a tabular format. We recommend that the
linear format be prohibited except in very limited circumstances because it is much more difficult
to read than the tabular formats. Indeed, the example provided in section 2 of the Consultation
Document on Label Format indicates that very little space is saved by using the linear format.
We recognize that the use of a standard horizontal tabular format may be impracticable
for some types of packages that have surface areas of less than 260 cm2 surface area where the
package is long and very narrow. However, manufacturers should not have the discretion to
determine how much space is sufficient to provide nutrition in a tabular format. We recommend
that labels of these types of long, narrow packages provide nutrition information in a tabular
format using a smaller type size (but no smaller than six point) to ensure maximum readability.
Manufacturers should only be permitted to use the linear format on packages where the width of
the narrower dimension of the broadest package surface is less than 4 cm.
6. Foods that use the "simplified format" should be required to include a statement
indicating which of the core list nutrients are not present in significant amounts.
Health Canada proposes that a food containing insignificant amounts of seven or more of
the core list nutrients may use a simplified nutrition information panel. Health Canada also
proposes that when nutrients other than calories, fat, carbohydrate, and protein are declared, then
the statement "Not a significant source of [list of any applicable core list nutrients]" be included
at the bottom of the nutrition information panel. However, we recommend that product labels
always disclose the fact that a food is devoid of any of the fourteen core nutrients. They must do
so by reporting a zero beside the name of the nutrient in the Nutrition Facts Box or, when eligible
to use the simplified format, they may do so by naming any of the applicable ten secondary
nutrients in a footnote beside the statement "Not a significant source of:."
7. Nutrition information for foods which require the addition of other ingredients
before consumption should be provided for foods "as prepared," in addition to "as
For products that require the addition of other ingredients before consumption (such as
beverage mixes and cake mixes), nutrition information should be provided for the food both "as
sold" by the manufacturer and "as prepared" by the consumer. The failure to provide nutrition
information "as prepared" would be very misleading and would make it difficult for consumers
to independently determine the actual nutritional composition of the finished product.
8. Strict requirements should be established to ensure the accuracy of nutrition
To ensure the accuracy and reliability of food labels, we propose that all nutrition
information provided on labels vary by no more than 10% from the actual amounts of nutrients
found in a sample of the food offered for sale. If variances greater than 10% are permitted, this
will likely undermine the public's confidence in, and effective use of, all nutrition labels.
9. The number of servings per container should be reported.
Manufacturers should be required to report the number of servings per container. This
information would assist consumers in visualizing how large a serving is and in planning meals
accordingly. For example, a 240 mL serving size of juice may be easier to visualize if a
consumer knows that there are eight such servings in a 1.89 L carton. Disclosing the number of
servings per package is also useful in comparing products whose package volume is the same,
but whose weight is significantly different.
10. Nutrition labels should disclose the basis of Daily Values.
All nutrition labels should be required to disclose the fact that the Daily Values are based
on a 2,000 calorie diet. This information is important to help consumers understand how Daily
Values are derived, and it allows each consumer to adjust the Daily Values to fit his or her own
11. Small businesses should be defined.
Health Canada sought comment on what would be a reasonable way of defining "small
business" for purposes of exemption from nutrition labelling requirements. In response, we
propose that small business be defined as a company that has less than $500,000 in gross annual
revenues, produces fewer than 10,000 average units of the relevant food product, and employs
fewer than ten employees in either of the two calendar years prior to the sale of the food.