CSPI REPORTS


Canadian Nutrition Labelling:

A Call for Reform


Centre for Science in the Public Interest


Supported by:

The Council of Canadians
FoodShare Metro Toronto
Ontario Society of Nutrition Professionals in Public Health
National Federation of Consumers' Associations of Quebec
Toronto Food Policy Council





About the Centre for Science in the Public Interest

The Centre for Science in the Public Interest (CSPI), a non-profit consumer organization, was founded in 1971. CSPI's twin missions are to conduct innovative research and advocacy programs in health and nutrition, and to provide consumers with current, useful information about their own health and well-being. CSPI is headquartered in Washington, D.C., with additional staff in Toronto, Ontario.

CSPI lead the drive in the U.S. for enactment of the Nutrition Labeling and Education Act of 1990, which requires standardized nutrition information on practically all food labels and sets standards for all nutrition and health claims for food products.

CSPI is supported almost entirely by the 1,000,000 subscribers to its Nutrition Action Healthletter, including more than 75,000 in Canada.

Center for Science in the Public Interest
P.O. Box 4252 Postal Station A
Toronto, Ontario M5W 2X5


1875 Connecticut Ave. N.W. Suite 300
Washington, DC 20009
202/332-9110


© Copywrite 1997 by Centre for Science in the Public Interest

This report was prepared by Leila Farzan, senior staff attorney, with the assistance of Michael Jacobson, executive director, and Bruce Silverglade, director of legal affairs. We'd like to acknowledge Bill Jeffery, consumer policy consultant in Ottawa, Ontario, for his extensive review and valuable comments.


Executive Summary

Canada's current nutrition labelling regulations and guidelines are inadequate and should be improved. Since nutrition labelling is not mandatory, many food labels do not provide any nutrition information. As a result, the nutrient content of many foods cannot be determined. The lack of information makes it difficult for Canadians to select foods in accordance with the dietary advice of health authorities. Interestingly, many products that do not provide any nutrition information when sold in Canada are simultaneously sold in the U.S. in packages that provide extensive nutrition information.

Although some foods do provide nutrition information, that information is often limited, difficult to read, or based on serving sizes that vary significantly within food categories, making brand comparisons difficult. Moreover, nutrition information is not expressed in ways that enable consumers to determine how the quantities of nutrients listed on a label fit into a healthful daily diet.

To address those problems, the following general reforms are proposed:

I. Introduction

Diet plays an essential role in promoting good health and preventing disease. Accordingly, health authorities recommend that Canadians eat a healthful diet to reduce their risks of serious health conditions. They advise consumers to limit their intake of certain nutrients, such as fat, saturated fat, cholesterol, sugar, and sodium, while consuming adequate complex carbohydrates (starch and fibre).

Unfortunately, it is difficult for Canadians to follow that dietary advice. Since nutrition labelling is not mandatory, many food labels do not provide any nutrition information whatsoever. As a result, consumers cannot determine the nutrient content of many foods.

Although some foods do provide a modicum of nutrition information on the label, that information is usually limited in scope, difficult to read, or based on serving sizes that vary significantly within food categories. Moreover, nutrition information is not expressed in ways that are most meaningful or useful to the average consumer. Without additional information, consumers cannot determine how the quantities of nutrients listed on a label fit into a healthful daily diet.

Surveys show that the majority of Canadian consumers believe that nutrition is an important factor in selecting food.

Although the majority of Canadians believe that nutrition information is important, only 34% of Canadian consumers believe that the nutrition information on product labels is satisfactory. The National Institute of Nutrition's 1992 report concluded that consumers want labels with increased size, colour, and contrast; standardized formats; and easier-to-read terms. Legibility is a concern for many consumers, especially for those over 65. Forty-four percent of grocery shoppers (including 70% of seniors) find the writing on packages too small to read.

Moreover, a national plan, Nutrition for Health: An Agenda for Action, was developed in 1996 to improve the nutritional health of Canadians. One of the key actions outlined in the plan is to "[i]mprove usefulness of nutrition labelling, increase its availability, and broaden public education on its use."

In the U.S., virtually all packaged foods are required to bear a "Nutrition Facts" label that provides American consumers with extensive information on important nutrients in a standardized, easy-to-read format. The "Nutrition Facts" label is very useful in helping Americans to select more healthful foods. For example, a 1996 survey found that 58% of American consumers said they almost always read the nutrition label when buying a food for the first time. One-third of those reading the nutrition label said they stopped buying a food product because of something they read on the label, and about one-quarter started buying and using a certain item after examining the label.

The requirement for nutrition labelling has helped spur competition in the U.S. on the basis of nutrition, and that helps even people who are not avid label readers. For instance, companies are marketing many more lower-fat and other nutrition-modified foods. Moreover, many companies, forced for the first time to analyze and disclose the nutrient content of their products, may be motivated to improve the nutritional quality of their foods.

Health Canada, under authority of the Food and Drugs Act and Regulations, is the federal agency responsible for the development of the food labelling regulations and policies dealing with health and safety matters. As such, it is the agency responsible for establishing the standards and guidelines for nutrition labelling.

Health Canada has stated its intention to revise nutrition labelling requirements and release a discussion document detailing its proposals. However, what action -- if any -- will be taken remains uncertain since Health Canada has neither released the document nor apparently set a target date for its release. Instead, Health Canada has been focusing on the requirements regarding nutrient content claims on food labels for the purpose of partial harmonization with the United States. Interestingly, the impetus for the proposed changes was fueled by the food industry and international trade concerns.

II. The Relationship Between Diet and Disease

It is well-established that the Canadian diet contributes heavily to obesity, heart disease, cancer, diabetes, and other serious diseases and health-related conditions. Cardiovascular disease accounts for more than one-third of all deaths; cancer accounts for more than one-fourth.

To help Canadians improve their diet, Health Canada's Nutrition Recommendations for Canadians and Canada's Food Guide to Healthy Eating provide guidance to consumers in making food choices that will supply recommended levels of essential nutrients while reducing the risk of chronic disease.

For example, studies have demonstrated that diets high in saturated fat and trans fat tend to increase the risk of heart disease. High-fat diets have also been associated with an increase in the risk of cancers of the colon, rectum, prostate, and endometrium.

To reduce health risks, Canada's Food Guide advises consumers to choose lower-fat dairy products, leaner meats, and foods prepared with little or no fat. Similarly, the Nutrition Recommendations states that the amount of fat in the Canadian diet should be restricted to no more than 30% of energy; saturated fat should provide no more than 10% of energy. The Nutrition Recommendations explains:

Diets high in fat have been associated with a high incidence of heart disease and certain types of cancer and a reduction in total fat intake is an important way to reduce the intake of saturated fat. The evidence linking saturated fat intake with elevated blood cholesterol and the risk of heart disease is among the most persuasive of all diet/disease relationships and was an important factor in establishing the recommended dietary pattern.
Sodium is another nutrient that is associated with the risk of serious disease. The connection between high-sodium diets and hypertension is well-supported. Hence, Canada's Food Guide and the Nutrition Recommendations advise consumers to limit their consumption of sodium. The Nutrition Recommendations explains:

The present food supply provides sodium in an amount greatly exceeding requirements....Consumers are encouraged to reduce the use of salt (sodium chloride) in cooking and at the table, but individual efforts will be relatively ineffective unless the food industry makes a determined effort to reduce the sodium content of processed and prepared food.
A diet high in dietary fibre has been associated with a reduction in the risk of several serious diseases. High-fibre diets appear to decrease the risk of colon cancer and help prevent heart disease and the onset of diabetes. Hence, the Nutrition Recommendations encourages its consumption.

Sugary foods have been associated with dental caries (tooth decay). Thus, Health Canada acknowledges that frequent intake of sugars, long exposure of teeth to sugars, and sticky forms of sugars can all influence dental caries. Also, to reduce the risk of obesity, Health Canada advises people with lower energy needs to limit their intake of foods that are high in sugar.

However, if consumers are to make those and other dietary adjustments recommended by health authorities, they must be able to make informed judgments when selecting foods. Unfortunately, most food labels (as well as unlabelled foods at grocery stores or foods eaten at restaurants) fail to provide the nutrition information that consumers need to apply current dietary recommendations to everyday purchase and consumption decisions. Thus, inadequate nutrition labelling is a significant deterrent to making food choices that are consistent with a healthy diet.

III. Current Regulations

Current nutrition labelling regulations -- or lack thereof -- make it difficult for Canadians to follow the dietary advice of health authorities and select foods in accordance with Health Canada's Nutrition Recommendations and Canada's Food Guide. The fundamental problem with current nutrition labelling is that it is not mandatory. A food label is only required to divulge nutrition information when a nutrition claim is made on the label -- and even then the information required to be disclosed is limited to only a few nutrients.

When labels do provide nutrition information, additional problems are presented. Labels may selectively list certain nutrients, but exclude other important nutrients, which may mislead consumers about the food's overall nutritional value. For example, a low-fat food that is high in vitamins may tout those facts on the label, but fail to disclose that it is also high in sodium.

Nutrition information is also sometimes difficult to read -- and even harder to find. Some nutrition information is printed in very fine, small print or is located in an inconspicuous place on the label. Moreover, nutrition information is based on serving sizes that may vary significantly among brands within a given food category, making comparisons difficult. For example, one brand of corn oil lists nutrition information per two-teaspoon serving; one brand of sunflower oil lists this information per one-tablespoon serving (there are three teaspoons in one tablespoon).

Furthermore, nutrition information is not expressed in ways that are most meaningful and useful to the average consumer. Without additional information, consumers cannot easily determine how the quantities fit into a healthful diet. For example, a consumer may not know that the 1,000 milligrams of sodium in one serving of soup represents a sizable portion of an ideal daily intake.

A. Nutrition labelling is not mandatory
Currently, food labels are not required to disclose nutrition information unless the label bears a nutrient content claim, that is, a statement that directly or indirectly describes the level of a nutrient (e.g., "low sodium"). As a result, many Canadian food labels that do not make nutrient content claims do not disclose the nutrient content of the food. Examples of the variety of foods that do not provide any nutrition information on their labels include:

Interestingly, those products that are sold in the U.S. under the same brand name have complete nutrition labelling.

Nutrition information is vital for consumers who wish to avoid or select foods based on their nutrient content. When that information is not provided on the label, it is extremely difficult, if not impossible, for consumers to determine the nutrient content of a food.

Nutrition information is particularly important when a food is high in fat, saturated fat, cholesterol, or sodium. Unfortunately, many foods high in those nutrients do not disclose nutrition information on the label. For example, Skippy Peanut Butter, Hellmann's Mayonnaise, and Hormel Spam are all high in fat, but fat content is not disclosed on their labels. Similarly, many processed foods, such as Campbell's canned Chicken Gumbo soup, are high in sodium, but do not provide nutrition information.

B. When nutrition information is provided, not all important nutrients are listed.
Nutrition information is required only when a product label makes a nutrition claim. When a nutrition claim is made, only the amount of the nutrient for which the claim is made must be disclosed. However, companies may also voluntarily list other nutrients as desired. Because manufacturers may list selected nutrients and are not required to list the amount of other important nutrients, consumers may be misled about a food's overall nutritional value.

Moreover, labels may list the content of nutrients that make the food appear healthful, but are not required to disclose the fact that the food may be high in undesirable nutrients. For example, the nutrition information provided on the label of Campbell's V8 Cocktail reveals that it has little fat and is a good source of vitamins A and C. However, the label fails to disclose that V8 is high in sodium. That information is important for consumers who are trying to follow a healthful diet and is absolutely essential for consumers who are medically advised to limit their sodium intake.

Campbell's V8 Cocktail lists the amount of energy, protein, fat, carbohydrate, sugars, vitamin A, and vitamin C. However, the sodium content is not listed (left). The U.S. label for V8 indicates that one cup contains 620 mg of sodium (right). According to the manufacturer, the Canadian product contains 730 mg of sodium in a one-cup serving (more than one quarter of a day's worth, based on the U.S. labelling standard).

Similarly, Heinz's canned spaghetti claims on the label that it is a good source of vitamin A and iron, thereby triggering the requirement that the amount of those nutrients be disclosed. However, requiring only the disclosure of those nutrients may give consumers the impression that the product is quite healthful. Consumers are not informed whether this food contains a sizeable amount of other nutrients, such as sodium.

C. Nutrition information is not always provided in a standard, easy-to-read format.
Canadian regulations do not require that nutrition information be provided in any particular format. Although a "standardized presentation format" of nutrition information has been set forth in the Guide to Food Labelling and Advertising, that format is voluntary and only consists of the heading ("Nutrition Information"), a statement of the serving size, the "core list" of nutrients (energy, protein, fat and carbohydrate) plus optional nutrient declarations given equal prominence in a standardized order. That information must be provided in both English and French. The prescribed "format" does not include specifications regarding type style and spacing. Moreover, the nutrition labelling format may appear on any part of the label, except the bottom of the container.

As a result, some Canadian products provide nutrition information that is difficult to read. In some cases, the print is very fine or small, contrasts little with the background, or is placed in an inconspicuous location. For example, nutrition information for Procter & Gamble's Pringles Potato Chips is listed sideways on the canister in fine, small print set against a red background.

Nutrition information on the Canadian label of Pringles is listed sideways in fine, small print set against a red background. Nutrition information on the U.S. label is clearly displayed on the back of the canister.

It is even more difficult to decipher the nutrition information printed on a 1996 carton of Yoplait Yogourt. It was printed in fine, gold type set against a red background, which had to be tilted against the light to be read.

Nutrition information on the label of Yoplait Yogourt (1996) is extremely difficult to read.

D. Nutrition information is based on serving sizes that may vary significantly within food categories.
When nutrition information is provided, it must be based on one serving. The serving size must be reasonable, i.e., "an amount of food which would reasonably be consumed at one sitting by an adult." Manufacturers have the flexibility to determine the serving size for a given product, and therefore the serving size upon which nutrition information is provided. However, the Guide to Food Labelling and Advertising has suggested serving sizes for use in nutrition labelling.

Food Category Serving Size

Snacks (potato chips,
corn chips, popcorn, pretzels)

28 - 40 g

Cereals, ready-to eat
20 - 45 g

Breads, rolls, buns, bagels
25 - 100 g

Peanut Butter
15 - 30 g

Vegetable Oils
5 - 20 mL

This chart shows some of the suggested serving sizes that Health Canada has established for use in nutrition labelling.

But even those suggested serving sizes provide a range for many foods, and therefore do not facilitate inter-brand comparability. The bottom line is that serving sizes are determined by individual manufacturers and may vary significantly among brands within a given food category.

Because nutrition information is based on serving sizes that may vary significantly among brands within food categories, it sometimes can be difficult for consumers to make meaningful nutritional comparisons among similar products. For example, Kraft Peanut Butter lists the amount of nutrients present in one tablespoon of peanut butter, while President's Choice Peanut Butter uses a serving size of two tablespoons. To compare nutrition information between those two products, consumers must double the numbers listed on the Kraft label or halve the numbers on the President's Choice label.

Kraft Peanut Butter lists nutrition information per one-tablespoon serving. President's Choice Peanut Butter lists nutrition information per two-tablespoon serving.

Comparing nutrition information between Mazola and President's Choice oils is even more difficult as the information is based on serving sizes using two different units of measurement. Nutrition information for Mazola Oil is based on a serving size of two teaspoons, and President's Choice bases this information on a one-tablespoon serving. A consumer would have to know that there are three teaspoons in one tablespoon and then multiply and/or divide accordingly to make the appropriate comparisons.

For instance, Mazola Corn Oil lists nutrition information per two-teaspoon serving. per two-teaspoon serving. President's Choice Sunflower Oil lists nutrition information per one-tablespoon serving.

Without standardization, it can be difficult for consumers to make meaningful comparisons among foods. Moreover, the use of standard serving sizes ensures that food companies do not use an unrealistically small or large serving size to favourably portray the nutritional composition of their products.

E. Nutrition information is not expressed in ways that are most meaningful or useful to the average consumer.
Merely listing the amount of nutrients does not help consumers understand how those amounts fit into the total daily diet. For example, a consumer may not know if 1,000 milligrams of sodium in one serving of soup is relatively high or low. In fact, when the United States Food and Drug Administration examined that issue, it found that many Americans could not specify the recommended intakes for nutrients such as sodium, even when those interviewed indicated that the nutrient was important to their health and that they were concerned about their intake of the nutrient. The same is likely true for Canadian consumers. Putting the 1,000 milligrams in a context of a desirable daily goal of, for instance, 2,400 milligrams, enables shoppers to recognize that the soup provides almost half the daily recommended intake of sodium.

IV. Conclusion and Recommended Reforms

Food labels do not provide Canadian consumers with the information that they need to select foods in accordance with the dietary advice of health authorities. Since nutrition labelling is not mandatory, few labels provide adequate nutrition information. As a result, the nutrient content of many foods cannot be determined.

When food labels do provide nutrition information on the label, that information is often limited, difficult to read, or based on serving sizes that vary significantly within food categories. Moreover, nutrition information is not expressed in ways that enable consumers to determine how the quantities of nutrients listed fit into a healthful daily diet.

To address those problems, nutrition labelling should be mandatory and include all nutrients that are essential to follow the recommendations of public health authorities. Nutrition information must also be easy to read and locate on the label. Information should be based on standard serving sizes and expressed in a way that will assist consumers in understanding the significance of the amounts of certain nutrients in the context of a total daily diet.

A. All food labels should be required to provide nutrition information.
All food labels -- not just those that make nutrition claims -- should be required to provide nutrition information. That information should be provided in both English and French. In a 1997 survey of adult Canadian grocery shoppers, 87% said that nutrition information on all packaged foods would be very or somewhat useful. In addition, nutrition information should be provided on labels or by other means for other foods, such as fresh meat, poultry, fish, fruit, and vegetables.

B. Information should be listed for all important nutrients for which public health authorities have made recommendations.
Nutrition information should be linked to the dietary guidance that is considered important for public health, as determined by federal health agencies. For example, information could be provided for calories, fat, saturated fat, trans fat, cholesterol, sugar, fibre, total carbohydrate, sodium, protein, calcium, iron, and selected vitamins.

C. Nutrition information should be easy for consumers to read and locate on the label.
Nutrition information should be presented in a standardized, easy-to-read format that is easy to locate on the label. Federal health agencies should conduct consumer research and then establish regulations governing how nutrition information should be displayed. Such regulations should include specifications regarding type size, style, and spacing requirements, as well as location on the label.

Below is an example of how nutrition information could be presented.

Alternatively, the French and English information could be presented separately. For example, Culinar Foods provides detailed nutrition information on boxes of McCormicks crackers. That information is presented on one side of the box in French and on the adjacent side of the box in English.

Detailed nutrition information for McCormicks crackers is presented on one side of the box in English and on the adjacent side of the box in French.

D. Nutrition information should be based on serving sizes that are standardized within food categories so that consumers can easily compare different products.
Nutrition information should be based on serving sizes that are standardized within food categories. Without standardization, it can be difficult for consumers to make meaningful comparisons among foods. Moreover, the use of standard serving sizes ensures that food companies do not use an unrealistically small or large serving size to favourably portray the nutritional composition of their products.

Health Canada has recently established reference amounts (not expressed in ranges) for food categories for the purpose of nutrient content claims. However, serving sizes for the purpose of nutrition labelling are still expressed as ranges. Health Canada has not indicated any plan to adopt the proposed reference amounts for nutrition labelling. We recommend that those proposed reference amounts be used as the basis for mandatory serving sizes for purposes of nutrition labelling so that serving sizes are standardized within food categories and are more realistic.

E. Nutrition information should be provided in a way that enables consumers to determine how a typical serving of the food fits into a healthful daily diet.
In addition to disclosing the nutrient content of the food, the nutrition label should also assist consumers in understanding how the amounts of certain nutrients fit into a daily diet. That information could be provided to consumers in several ways. For example, in the U.S., labels list the Percent Daily Value for several nutrients. For vitamins and minerals, the Percent Daily Value represents the contribution that one serving of food makes toward the Reference Daily Intake that the U.S. Food and Drug Administration has established for each of those nutrients. For total fat, saturated fat, cholesterol, sodium, potassium, total carbohydrate, and dietary fibre, the Percent Daily Value represents the contribution that one serving of food makes toward the Daily Reference Value established for each of those nutrients.

As another option, the label could state whether the numbers listed represent "high," "medium," or "low" levels of each nutrient. Alternatively, diagrams could be used to illustrate the portion of a food's total calories that come from fat, saturated fat, carbohydrate, and protein. Health Canada should conduct consumer research to determine how nutrition information can be best conveyed to consumers.