List of ingredients and allergens
List of ingredients
All prepackaged products with more than one ingredient must declare their ingredients (definition) and components (definition) in a list of ingredients [B.01.008(1), FDR], unless they are exempt. For more information, refer to Exemptions.
Ingredients must be declared in descending order of proportion by weight, as determined before they are combined to make the food [B.01.008.2(3)(a), FDR].
Food allergen (definition), gluten (definition) and added sulphites (definition) (at levels of 10 ppm or more, and are not already required to be shown in the list of ingredients) must be declared, provided there are no exemptions or exceptions. It is not required to declare food allergens or gluten that is present in a prepackaged product as a result of cross-contamination [B.01.010.1(3), FDR].
The Food and Drug Regulations specify the manner in which ingredients must be declared, including grouping sugars-based ingredients, common names, and declaring food allergens, gluten & added sulphites. For further details, refer to Manner of declaring.
Prepackaged products that do not require a list of ingredients
The following products are exempt from declaring a list of their ingredients:
- Prepackaged products that are packed on retail premises from bulk, including candies, flour, salt, spices, single ingredient nuts, in store baked breads, etc. This exemption does not apply to mixed nuts and to uncured meat and poultry products that contain phosphate salts and/or water and are packaged at retail [B.01.008(2)(a), B.01.091 FDR]
- prepackaged from bulk includes any product made on the retailer's premises (e.g. assembled, baked, transformed) and any product packaged by the retailer from the supplier's containers
- "Packed on the retail premises" including
- foods packaged in the retail establishment where the prepackaged food is sold
- foods packaged on premises (on or off-site) owned by the same person as the retail establishment where the food is sold, as long as these premises supply only that retail establishment
Prepackaged food does not qualify for the exemption when it is packed at off-site premises that are owned by the same person who owns the retail establishment where the food is sold, but these premises supply more than one establishment or company, or sell the product directly to consumers (e.g. product packed at a warehouse or packing house that supplies multiple stores would not be exempt).
Note: Products sold by a single retailer at more than one building on the same premises would be considered to be sold in a single retail establishment (e.g. products packed in a retail store and sold at both that store and in a gas bar at the same address that is owned by the same person would be exempt).
- Prepackaged individual portions of food served with meals or snacks by restaurants, airlines, etc. [B.01.008(2)(b), FDR]
- some examples of individual servings are coffee creamers, jam, tartar sauce, pancake syrup, salad dressing, crackers, ketchup, etc.
- Prepackaged individual servings of food prepared by commissaries and sold in mobile canteens or vending machines [B.01.008(2)(c), FDR]
- for further details on commissaries, refer to Net quantity
- Prepackaged meat and meat by-products that are barbecued, roasted or broiled on the retail premises [B.01.008(2)(d), FDR]
- for example, spare ribs that have been barbequed on the retail premises
- Prepackaged poultry and poultry meat or poultry by-products that are barbequed, roasted or broiled on the retail premises [B.01.008(2)(e), FDR]
- for example, chicken that has been roasted on the retail premises
- Bourbon whiskey and standardized alcoholic beverages [B.01.008(2)(f), FDR]
- standardized alcoholic beverages include whisky, rum, vodka, gin, wine, liquors, beer, malt, etc.
- unstandardized alcoholic beverages require a complete list of ingredients, this includes cream liquors, shandies, coolers, and cocktails
- Standardized vinegars [B.01.008(2)(g), FDR]
- standardized vinegars include wine vinegar, white vinegar, malt vinegar, cider vinegar, blended vinegar, etc.
- unstandardized vinegars require a complete list of ingredients, this includes raspberry vinegar
Prepackaged products that are not required to declare allergens, gluten and/or added sulphites
Food allergens, gluten and added sulphites do not have to be declared when present in prepackaged products that are exempt from bearing a list of ingredients under B.01.008(2)(a)-(e) of the FDR (i.e. items 1-5 in the list above), unless a list of ingredients is voluntarily shown on the product's label [B.01.010.1(4); B.01.010.2(4), FDR]. This exemption however does not apply to distilled vinegars or standardized alcohols regardless of the fact that they are exempt from bearing a list of ingredients under B.01.008(2)(f) and (g) of the FDR.
In addition, food allergens, gluten and added sulphites do not have to be declared when present in standardized Beer, Ale, Stout, Porter, or Malt Liquor [B.02.130; B.02.131, FDR] unless a list of ingredients is shown on the product's label [B.01.010.1(5); B.01.010.2(5), FDR].
Triggers to provide allergen labelling on otherwise exempted products
If a manufacturer chooses to voluntarily declare a list of ingredients on the product label of any product exempt from bearing a list of ingredients, then the prescribed source names for allergens, gluten and added sulphites that are present must be declared in the list of ingredients [B.01.010.1(2); B.01.010.2(3), FDR].
In addition, if a prepackaged product that is exempt from the requirement to carry a label, voluntarily carries a label with a list of ingredients, the allergen labelling requirements apply.
Exceptions from allergen declarations
Although standardized alcoholic beverages are not exempt from declaring allergens, Health Canada has developed a position on the labelling requirements for vintage wines. This position indicates that the allergen labelling regulations apply to all non-vintage wines and vintage wines with a year date of 2012 and later, and that vintage wines with a year date of 2011 or earlier can continue to be sold with their original labels. For more information on this subject, refer to Health Canada's position on Vintage Wine and Application of Enhanced Allergen Regulations.
Foods with temporary marketing authorization letters
Some products that were previously classified as natural health products are now classified as foods by Health Canada. Health Canada has issued Temporary Marketing Authorization Letters to grant these products a transition period to bring labels into compliance with food labelling requirements.
For more information on this subject, refer to Health Canada's Lists of foods that have received temporary marketing authorization letters.
Highly refined oils
Based on a detailed assessment by Health Canada, highly refined (degummed, neutralized, blanched and deodorized) oils derived from food allergen sources are not subject to the enhanced labelling requirements as the refining process has been determined to remove the allergenic protein from the oil. Based on the available science, the very low levels of protein present within highly refined oils are not considered to pose a risk to the health of individuals with food allergies. For more information on this subject, refer to Health Canada's position on highly refined oils derived from food allergen sources.
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