CHAPTER 3
LABEL VERIFICATION
3.1
OBJECTIVE.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1
3.2
SCOPE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1
3.3
REQUIRED FORMS, EQUIPMENT and REFERENCES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1
3.4
3.3.1
Forms. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1
3.3.2
Equipment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1
3.3.3
References. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1
INSPECTION PROCEDURES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2 3.4.1
Select a Product and a Label. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2
3.4.2
Complete the Label Verification Worksheet.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2
3.4.2.1 3.4.2.2 3.4.2.3 3.4.2.4 3.4.2.5 3.4.2.6 3.4.2.7 3.4.2.8 3.4.2.9 3.4.2.10 3.4.2.11 3.4.2.12 3.4.2.13 3.4.2.14 3.4.2.15 3.4.3
Common Name. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4 Net Quantity. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-5 Grade. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-7 Size Grading. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-8 List of Ingredients. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-8 Name and Address of the Responsible Party. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-8 Country of Origin.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3-8 Establishment Registration Number on Products Packed in Canada.. . . . . . . . . . . . . . 3-9 Production Code. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-10 Special Wording. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-10 Nutrition Labelling (Nutrition Facts Table).. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-10 Nutrient Content Claims and Health Claims. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-11 Storage Instructions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-11 Organic Claims. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-11 Other Information. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-13
Movement of Unlabelled or Mislabelled Processed Products. . . . . . . . . . . . . . . . . . . . . . . 3-14
3.4.3.1 Authorization for Movement of Unlabelled or Mislabelled Products under the PPR. . . 3-15 3.4.4
Inspection Results. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-17
3.4.5
Unsatisfactory Inspection Results. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-18
3.4.6
Complete and Distribute the Inspection Report. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-18
APPENDIX 3A: Worksheet 3-1: Label Verification for Processed Products.. . . . . . . . . . . . . . . . . . . . . 3-19
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CHAPTER 3 3.1
LABEL VERIFICATION
OBJECTIVE
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To verify that processed products comply with the:
3.2
i)
labelling requirements of the Processed Products Regulations (PPR), the Food and Drug Regulations (FDR), the Organic Products Regulations (OPR), the Consumer Packaging and Labelling Regulations (CPLR) and/or the applicable policies and guidelines; and
ii)
standard container size requirements of the PPR (as applicable).
SCOPE
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This activity pertains to all labels applied to containers of food products subject to the PPR. This includes the labels found on prepackaged retail containers, institutional containers and shipping containers of both domestic and imported food products. The label verification activity covered by this chapter is limited to cross-referencing the information found on a label with the requirements prescribed in the PPR, FDR, OPR and CPLR. During this activity, products are not opened or analysed. 3.3
REQUIRED FORMS, EQUIPMENT and REFERENCES 3.3.1 • • • • • •
3.3.2 • • 3.3.3
Forms
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Worksheet 3-1: Label Verification for Processed Products (Appendix 3A) Inspector Non-Compliance Report (Short Form) (CFIA / ACIA 5393) Notice of Detention (CFIA / ACIA 3256) Official Seal Tape - Yellow (CFIA / ACIA 4561) Notice of Release from Detention (CFIA / ACIA 3257) Authorization Request for Movement of Products under the Processed Products Regulations (PPR) (CFIA / ACIA 5567) (Note: for requests submitted by industry)
Equipment
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Ruler Calculator References
•
Canada Agricultural Products Act (CAPA)
•
Processed Products Regulations (PPR)
•
Food and Drugs Act (FDA)
•
Food and Drug Regulations (FDR)
• •
Consumer Packaging and Labelling Act (CPLA) Consumer Packaging and Labelling Regulations (CPLR)
•
The Guide to Food Labelling and Advertising (the Labelling Guide)
•
Nutrition Labelling Toolkit
•
Guide to Developing Accurate Nutrient Values
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CHAPTER 3
3.4
LABEL VERIFICATION
•
Guidelines for Product of Canada and Made in Canada Claims
•
Organic Products Regulations (OPR)
•
Organic Products (Main Page)
•
List of Certification Bodies providing organic certification services under the Canada Organic Regime (the CFIA list)
•
Policy on Listeria monocytogenes on Ready-to-Eat Foods
INSPECTION PROCEDURES
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Chapter 11 of the Guide to Food Labelling and Advertising (Guide), identify the labelling requirements specific to processed fruits and vegetables, as per the PPR, the FDR and the CPLR. Chapters 1 to 9 of the Labelling Guide identify other labelling requirements applicable to all foods (including processed fruits and vegetables). Note:
The first number of all sections and tables in the Labelling Guide identify the chapter where these sections and tables are located (e.g., section 4.19 is in chapter 4, Table 11-1 is in chapter 11). Therefore, this document references sections and tables (rather than chapters) of the Labelling Guide.
To assess a label for compliance with the applicable regulations, follow the steps outlined below. 3.4.1
Select a Product and a Label
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Choose a food product subject to the PPR. For ease of reference, consult Table 11-1of the Labelling Guide. If a product is not specifically listed in this Table, it may fall under a class of foods subject to a generic standard of identity in Schedule II, PPR as explained in section 1.7.4.2 in Chapter 1 of this manual. According to these priorities, choose a label: i)
with a known or suspected non-conformity (e.g., as a result of a complaint, spotted during other inspection activities);
ii)
that is on a product for which an ingredient verification is also being performed (as per Chapter 4 of this manual);
iii) that is new or revised; or iv) that is on any other processed product. Note:
“Low priority” label reviews include the labels applied to:
1) products destined exclusively for export and accompanied by the shipper’s signed statement confirming that the label and markings comply to the importing country requirements, as per Section 57, PPR; and 2) individual portion sizes served with meals or snacks. These only need to declare the common name of the product, the name and address of the responsible party and for imported products, the country of origin. 3.4.2
Complete the Label Verification Worksheet
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LABEL VERIFICATION
Use the information found on the label to complete Worksheet 3-1: Label Verification for Processed Products (Worksheet 3-1) in Appendix 3A. On the Upper Portion of Worksheet 3-1: a)
Record your name, the date of inspection, the name and address of the facility being inspected, and the product description.
b)
Measure the dimensions of the “Principal Display Surface (PDS)” of the container (i.e., the total area visible under normal conditions of sale or use). Record your measurements on Worksheet 3-1 and calculate the total area of the PDS according to one of the methods described below. On the PDS Chart, circle the minimum type height required for the numerical part of the net quantity and the grade declarations. If the container: (i) Has a particular side for display (e.g., a box, a plastic bag), the PDS is the length of the container multiplied by the width:
Width Length
PDS = Length x Width Example: If the length is 36.0 cm and the width is 21.0 cm then, PDS = 36 x 21 = 756 cm2. According to the PDS chart, the minimum type height for the numerical part of the net quantity and the grade declarations is 9.5 mm (3/8 inch) when the PDS is 756 cm2. (ii) Does not have a particular side for display (e.g., cylindrical can), the PDS is 40 percent of the total area of the sides of the cylinder. This is calculated by multiplying the height of the container by the circumference by 40 percent: PDS = Height x Circumference* x 40% * To measure the circumference: 1) Use a flexible ruler and measure all around the container: PDS = Height x Circumference x 0.4 Example: If the height is 11.5 cm and the circumference is 26.7 cm then, PDS = 11.5 cm x 26.7 cm x 0.4 = 122.8 cm2. OR 2) Measure the diameter of the container and multiply it by ( (Pi) ((= 3.1416) PDS = Height x Diameter x ( x 0.4 Example: If the height is 11.5 cm and the diameter is 8.5 cm: PDS = 11.5 cm x 8.5 cm x 3.1416 x 0.4 = 122.8 cm2 According to the PDS chart, the minimum type size for the numerical part of the net quantity and grade declarations is 3.2 mm (1/8 inch) when the PDS is 122.8 cm2. Page amended 2013/04/20, Manual published 2009/11/25
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LABEL VERIFICATION Note: Do not confuse the PDS with the Available Display Surface (ADS). The ADS is the surface used to evaluate the size of the Nutrition Facts Table.
The rest of Worksheet 3-1 summarizes the labelling requirements for processed products. Assess the label according to the requirements outlined in each element of Worksheet 3-1. Record your findings as satisfactory (S), unsatisfactory (U) or not applicable (N/A). Be sure that unsatisfactory assessments are not rendered satisfactory by a Test Market Authorization, as explained in Chapter 13 of this manual. The sections below are numbered to correspond to the elements of Worksheet 3-1 and to the sections in chapter 11 of the Labelling Guide. Example:
Section 3.4.2.1 below corresponds to element # 1 of Worksheet 3-1 and section 11.1 in chapter 11 of the Labelling Guide.
3.4.2.1 Common Name
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The common name declared on the label, including the style of preparation (if applicable), must be acceptable. The common name of the food must be the name prescribed by the PPR and/or the FDR. If the common name is not prescribed by these Regulations, the common name is the name by which the food is generally known. All words in the common name: •
must be grouped together and appear in the same order as prescribed by the Regulations;
•
must appear in the same plane (e.g., all horizontally), but may appear on separate lines (one on top of the other);
•
must be printed in letters at least 1.6 mm in height, based on the lower case letter “o”; and
•
should be printed in identical size and prominence (e.g., font style and colour). Exception:
when the common name is lengthy, part of the common name can be in type not less than one half the size of the largest type used for the other part of the common name.
Example: both of these are acceptable: Apple Juice from Concentrate ($ 1.6 mm)
Apple Juice (3.2 mm) from Concentrate (1.6 mm) For graded foods for which a style of preparation is prescribed, the style of preparation must be part of, or in close proximity to, the common name. Exception:
In the case of whole style canned tomatoes that are graded Canada Fancy or Canada Choice, the labelling of the style is optional. Canned tomatoes that are graded Canada Standard shall not be labelled with a style.
Example:
“Sliced Carrots” (canned): “Carrots” is the common name and “sliced”
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LABEL VERIFICATION is a style of preparation prescribed in Schedule I, Table I, Section 21, PPR. The words “sliced” and “carrots” must appear on the Principal Display Panel in close proximity to one another. The word “canned” is not required. For frozen products, the common name must include the word “frozen” unless the statement “keep frozen” is declared on the Principal Display Panel. Assess the location, type size and language of the common name according to the requirements summarized on Worksheet 3-1 and explained in section 11.1 of the Labelling Guide.
3.4.2.2 Net Quantity
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Indicate, on Worksheet 3-1, which unit of measurement is used to declare the net quantity of the product. The unit of measurement must comply with Schedule V, Section 4 of the PPR which requires the net quantity to be expressed as follows: •
in Metric Volume [millilitres (or mL, ml or ml) or litres (or L, l or l)] for: Liquid foods, viscous foods, all canned fruits, all canned vegetables, cranberries (cranberry sauce), cranberry jelly (jellied cranberries), tomato chili sauce, mincemeat, and all foods identified in Table 11-1 of the Labelling Guide, for which column 6 (largest container prescribed) is expressed in litres (L) or millilitres (ml);
•
in Metric Weight [grams or kilograms (and in French: grammes and kilogrammes) or their bilingual symbols g and kg] for: Solid foods, except those listed under metric volume or count; or
•
by Count: for canned or frozen corn on the cob.
Imperial units [e.g., fluid ounces (fl oz), ounces (oz) or pounds (lbs)] may be declared, in addition to metric volume or weight, providing they are not more predominately displayed than the metric declaration. Assess the location and type size of the net quantity according to the requirements summarized on Worksheet 3-1 and explained in section 11.2 of the Labelling Guide. Assess the rounding of numbers in the net quantity declaration. Section 25 of the CPLR requires the metric net quantity to be shown in the decimal system in three figures, unless the quantity is below 100 g or 100 ml, when it may be shown in two figures. Any final zero(s) to the right of a decimal need not be shown.
Table 3-1: Examples of rounding the numbers in net quantity declaration Unacceptable (Reason)
Acceptable (Reason)
75.23 ml
(4 figures)
75.2 ml 75 ml
(3 figures); or (< 100 ml so 2 figures are acceptable)
250.4 g
(4 figures)
250 g
(3 figures required)
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LABEL VERIFICATION 1000 ml
(4 figures)
1.00 L (3 figures); or 1.0 L or 1 L (zeros to the right of the decimal are optional)
1.822 L
(4 figures)
1.82 L
(3 figures required since > 100 ml)
Prescribed Container Sizes: If the product is subject to standard container sizes in Schedule III, PPR (for a quick reference, see Table 11-1 of the Labelling Guide), verify that the net quantity declared on the label meets one of the 4 conditions below, i.e.: The net quantity declared is: 1) one of the sizes prescribed in Schedule III, PPR: Examples: •
The container sizes prescribed for Apple Juice [Table I, Section 3, PPR] are 200 ml, 250 ml, 284 ml, 398 ml, 500 ml, 540 ml, 750 ml, 796 ml, 1 L, 1.36 L, 1.5 L, 1.82 L and 2 L
•
The container sizes prescribed for Canned Whole Apricots [Table I, Section 1, PPR] are 142 ml, 284 ml, 398 ml, 540 ml, 796 ml, 1.36 L and 2.84 L
2) larger than the largest (LTL) volume or weight set out in Schedule III, must be a whole number, multiple of 500 g or 500 ml, and must not exceed 20 kg or 20 L [Subsection 25(1), PPR]: Examples: •
The largest container size prescribed for Apple Juice is 2 L (as indicated above and as summarized in the 6th column of Table 11-1 of the Labelling Guide). Therefore, the possible LTL container sizes for Apple Juice are 2.5 L, 3.0 L, 3.5 L, up to 20 L.
•
The largest container size prescribed for Canned Whole Apricots is 2.84 L. Therefore, the possible LTL container sizes for Canned Whole Apricots are 3.0 L, 3.5 L, 4 L, up to 20 L.
Note:All food products subject to standard container sizes may be packed in Larger than the largest prescribed container size. 3) smaller than the smallest size set out in Schedule III and if: a) the product is sold to consumers, the product is listed in Subsection 21(2), 25(2) or 25(3), PPR and the net quantity is shown in 1 g or 1 ml decrements starting from the smallest prescribed container size; or Example: Apple Juice MAY be packed in any size container between 1 ml and 199 ml. Note:
Smaller than the smallest sizes are only allowed for some of the food products that are subject to standard container sizes. These are quickly identified in the 7th column of Table 11-1of the Labelling Guide. The product must be fully labelled with all the mandatory information.
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LABEL VERIFICATION b) the product is a portion pack (i.e., a single serving) served with a meal or snack by an institution. Any product may be packed in portion packs providing they are given away with the meal or snack (i.e., this option is not limited to products listed in Subsections 21(2), 25(2) and 25(3) of the PPR). Note:
The label applied to the portion pack must declare the common name of the product, the name and address of the responsible party and if the product is imported, the country of origin must also be declared. The label on the shipping container must be fully labelled with all the mandatory information.
4) a non-prescribed container size for which a Test Market Authorization (TMA) has been granted. For more information, see Chapter 13 of this manual. Examples: •
Apple juice can be packed in a 473 ml bottle (i.e., not a prescribed container size) providing the company received a TMA.
•
Canned whole apricots can be packed and sold in a container smaller than the smallest size prescribed (i.e., smaller than 142 ml), if a TMA has been granted.
If one of the 4 conditions above is met, indicate the prescribed container size as satisfactory. Note:
Products not meeting the standard container sizes may be conveyed between two facilities (interprovincially or imported ), under a Ministerial Exemption (ME). However, the consignee must render the product compliant (e.g., further processing, repacking in a standard container size) prior to further distribution. For more information, see Chapter 14 of this manual. Example: A bulk container of frozen blueberries (> 20 kg) may be imported if an ME has been issued by the Canadian Food Inspection Agency (CFIA) for repacking in 1 kg plastic bags.
3.4.2.3 Grade
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For products subject to grade markings in Schedule I of the PPR, indicate, on Worksheet 3-1, which grade is declared on the label (if any) and assess the declared grade according to the requirements, as explained in section 11.3 of the Labelling Guide. The grade declaration is optional for tomato catsup, tomato chili sauce, tomato paste, concentrated tomato paste, tomato pulp and tomato puree (Schedule I, Table I, Sections 57 to 61, PPR). For these foods, if the grade is: •
declared:
assess the grade declaration according to the requirements of the PPR, as explained in section 11.3 of the Labelling Guide; or
•
not declared: indicate the grade marking as “not applicable (N/A)” on Worksheet 31. Even though a grade is not declared, these products are subject to all other requirements prescribed in Schedule I and any other applicable sections of the PPR.
A grade cannot be declared on a food that is not subject to grade markings unless the Page amended 2013/04/20, Manual published 2009/11/25
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LABEL VERIFICATION declared grade is a foreign grade that meets section 11.3.3 of the Labelling Guide. Record any foreign grade in the space provided under “other” grade declared. Assess the declared foreign grade using section 11.3.3 of the Labelling Guide. Since foreign grade is optional information, no location, type size or language requirements apply. Assess the location, type size and language of the grade declaration according to the requirements summarized on Worksheet 3-1 and explained in section 11.3 of the Labelling Guide.
3.4.2.4 Size Grading
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For processed vegetables subject to size grading (last column in Table 11-1of the Labelling Guide), indicate, on Worksheet 3-1, which size is declared (if any) and whether or not it meets the requirements summarized on the worksheet and explained in section 11.4 of the Labelling Guide. 3.4.2.5 List of Ingredients
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Assess the location, type size and language of the list of ingredients according to the requirements summarized on Worksheet 3-1 and explained in section 2.8 of the Labelling Guide. The label is exempt from declaring an ingredient list if it is applied to: a) a single ingredient food (e.g., frozen peas); b) a product for which the common name declares all the ingredients in descending order of proportion by weight (e.g., frozen peas and carrots); c) an individual serving of food that is served with a meal or snack (e.g., individual serving of strawberry jam served with toast by a restaurant); d) a shipping container, as long as the inner packages declare a complete list of ingredients; or e) a gift pack, such as a basket of assorted jams, providing the inner packages declare a complete list of ingredients. At this point, the list of ingredients is not compared to the product formulation or the compositional standard. However, it is recommended that an ingredient verification be done in conjunction with the label verification. For more information, see Chapter 4 of this manual. 3.4.2.6 Name and Address of the Responsible Party
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Indicate whether or not the name and address declared on the label meet the requirements summarized on Worksheet 3-1 and explained in section 11.6 of the Labelling Guide. 3.4.2.7 Country of Origin
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For products wholly manufactured outside Canada, indicate if the mandatory country of origin requirements are met, as summarized on Worksheet 3-1. An imported product is "wholly manufactured outside Canada" when it has not been additionally processed in Canada and its nature remains unchanged. Example: USA frozen peas are cleaned, graded, packaged and labelled in Canada must declare "Product of USA" or USA in the American name and address Page amended 2013/04/20, Manual published 2009/11/25
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LABEL VERIFICATION (e.g., “DEF Company, 345 Main St., Washington, DC, USA”) Note:
Any product graded in Canada must declare a Canada grade (e.g., CANADA A, CANADA FANCY), as per the PPR.
For all other products (i.e., products NOT wholly manufactured outside Canada), if the label declares the product as being of Canadian origin, indicate whether or not the voluntary claim meets the criteria stated in section 4.19 of the Labelling Guide. A product is "NOT wholly manufactured outside Canada" when its composition or nature has been altered in any way in Canada by either the addition, removal or assembling of an ingredient or component, or physical or chemical processing, including grinding or blending. For these foods, the country of origin requirement under the PPR does NOT apply. Therefore, if the company chooses to declare "Product of Canada / Made in Canada from domestic and imported ingredients / Made in Canada from imported ingredients", the product must meet the guidelines. In summary: 1) The claim “Product of Canada” is permitted when all or virtually all major ingredients, processing, and labour used to make the food product are Canadian. Example: Fresh Canadian peas are cleaned, frozen, graded, packaged and labelled in Canada may voluntarily declare “Product of Canada” 2) The claim “Made in Canada from domestic and imported ingredients” or “Made in Canada from imported ingredients” is permitted on foods substantially transformed in Canada. The food must undergo final preparation and/or processing in Canada which changes its nature such that the food becomes a new product bearing a new name, even if some or all ingredients are sourced from other countries. Any processing method applied to fruit or vegetables as defined in the PPR qualifies as substantial transformation (i.e., "processed" means any product that has been cooked, canned, frozen, pickled, concentrated or otherwise prepared to ensure preservation). Examples: •
USA apple juice concentrate diluted in Canada. The new product "apple juice from concentrate" may voluntarily claim "Made in Canada from domestic and imported ingredients".
•
USA fresh peas subsequently frozen in Canada. The new product "frozen peas" may voluntarily claim "Made in Canada from imported ingredients".
•
Canadian frozen peas mixed with USA frozen peas. The existing product "frozen peas" cannot make the claim "Made in Canada from domestic and imported ingredients" since blending the same ingredient, i.e., peas with peas, is not considered a substantial transformation. They could voluntarily claim "Packed in Canada from domestic and imported ingredients" or "Prepared in Canada from domestic and imported ingredients".
•
Chinese frozen peas mixed with USA frozen carrots. The new product "frozen peas and carrots" may voluntarily claim "Made in Canada from imported ingredients".
For more details on country of origin claims, refer to the Guidelines for Product of Canada and Made in Canada Claims and/or to sections 4.19 and 11.7 of the Labelling Guide. 3.4.2.8 Establishment Registration Number or Identifying Code Mark on Products Packed Page amended 2013/04/20, Manual published 2009/11/25
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LABEL VERIFICATION in Canada
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Labels declaring the first dealer’s name and address and labels applied to shipping containers must identify the establishment in which the product was packed. The information must appear as follows: a) For labels declaring the first dealer’s name and address: The packing establishment’s registration number, or its’ identifying code mark, must be declared on the label or embossed on the container. Note:
If an identifying code is used, the first dealer must be able to recognize and identify the code as belonging to the packing establishment. If other establishments co-pack under the same private label, they must use a different code. Example: If registered establishment # 123 packs a product under a private label for a specific retail chain, the identifying code (e.g., the letter A) must only represent establishment # 123. The code may be incorporated with other codes providing it is identifiable (e.g., A236 where the A stands for establishment #123).
b) For labels applied to shipping containers: The packing establishment’s registration number must be declared on the label. These requirements are summarized in the worksheet 3-1 and explained in Section 11.8 of the labelling guide.
3.4.2.9 Production Code
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For low acid canned foods and graded canned foods, indicate whether or not the coding requirements are met, as summarized on Worksheet 3-1 and explained in section 11.9 of the Labelling Guide. 3.4.2.10 Special Wording
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Some products have additional mandatory labelling requirements. These products are listed in alphabetical order on Worksheet 3-1. Indicate whether or not the label meets the special wording requirements (e.g., solid pack, extra heavy syrup), as summarized on Worksheet 3-1 and explained in Table 11-2 of the Labelling Guide. 3.4.2.11 Nutrition Labelling (Nutrition Facts Table)
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Nutrition labelling and the Nutrition Facts Table requirements are explained in chapters 5 and 6 of the Labelling Guide and in the Nutrition Labelling Toolkit. Indicate, on Worksheet 3-1, whether or not the Nutrition Facts Table meets the regulatory requirements. For assistance, the Checklist for the Nutrition Facts Table, located in the Nutrition Labelling Toolkit, can be used. For assistance developing accurate nutrient values for a variety of purposes, including nutrition labelling, industry representatives may use the Guide to Developing Accurate Nutrient Values found on Health Canada’s website.
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3.4.2.12 Nutrient Content Claims and Health Claims
Return to Index
Chapter 7 of the Guide explains labelling requirements for nutrient content claims value while Chapter 8 describes the requirements for health claims.
For assistance developing accurate nutrient values for a variety of purposes, including nutrition labelling, industry representatives may use the Guide to Developing Accurate Nutrient Values found on Health Canada’s website.
3.4.2.13 Storage Instructions
Return to Index
For products that must be stored at temperatures other than room temperature, assess whether or not the storage instructions (e.g., “keep refrigerated”/”garder réfrigéré” or “keep frozen”/”garder congelé”) are appropriately declared on any label panel except the bottom, in both English and French. Exception:
If “frozen” is included in the common name of the product, the statement “keep frozen” is not required.
3.4.2.14 Organic Claims
Return to Index
If an optional claim (e.g., organic product and\or the organic logo) appears on the label, indicate on Worksheet 3-1whether or not the claim complies with the requirements. The claims allowed, and their conditions of use, are summarized as follows: a) Use of the organic logo: i)
The Canada logo (in colour or black and white) and/or an approved international logo are permitted on the label of products having an organic content of at least 95%.The declaration of the percentage of organic content is optional; Note:Industry can obtain a copy of the Organic Logo from the Certification body that certified the specific product as organic. Products certified by an approved international body may bear the Canada logo in addition to the foreign country’s logo.
ii) The name of the domestic or foreign certification body must appear on the label; iii) The domestic or foreign certification body must be on the List of Certification Bodies providing organic certification services under the Canada Organic Regime (the CFIA list); and Note:Canada and a few other countries have recognized each others' organic certification systems as equivalent. Therefore, the CFIA list includes the Certification Bodies accredited by CFIA or by a foreign competent authority recognized under an organic trade arrangement. The certification bodies are listed by the country in which they provide services (e.g., Canada, USA, the European Union (EU), international). All imported products represented as "organic," certified to these equivalent international standards, are considered to be compliant with the Organic Products Regulations, 2009.
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LABEL VERIFICATION iv) The words “Product of” or “imported by” must immediately precede the declaration of the country of origin and must be in close proximity to the logo (this applies only to imported products). b) The claim “organic”, “organic product”, or “organic (name of the product)”: i)
The claim is permitted on the label of products having an organic content of at least 95%. The declaration of the percent organic content is optional;
ii) The name of the domestic or foreign certification body must appear on the label; and iii) The certification body must be on the List of Certification Bodies providing organic certification services under the Canada Organic Regime (the CFIA list). Notes: 1) These products may use the organic logo. 2) See the note in point (a)(iii) above. c) The claim “organic ingredients": i)
Multi-ingredient products containing > 70% and < 95% organic content: •
The claim is permitted on the label providing the percentage of organic content immediately precedes the “organic ingredients” statement, in the same size and prominence as all other words, numbers, signs or symbols used for the claim;
•
The name of the domestic or foreign certification body is declared on the label; and
•
The domestic or foreign certification body must be on the List of Certification Bodies providing organic certification services under the Canada Organic Regime (the CFIA list). Notes: 1) 2)
The organic logo is not permitted on the label of these products. See the note in point (a)(iii) above.
ii) Multi-ingredient products containing < 70% organic content: The claim “organic (name the of ingredient)” is only permitted in the list of ingredients. The declaration of the percentage of organic content is optional in the list of ingredients. Notes : <
95%
Permitted on imported products if the words “Product of” or “imported by” immediately precede the declaration of the country of origin and are in close proximity to the logo
Mandatory
“Organic” (Single ingredient products or Multi-ingredient products) “ X% organic ingredients” (Multi-ingredient products)
> 95%
Permitted (optional) providing the above conditions are met
Mandatory
> 70% and < 95%
Not permitted
Mandatory
< 70%
Not permitted
Not permitted
“Organic (name of the ingredient” (In the list of ingredients of multi-ingredient products)
For more details on organic products, claims and enforcement actions, refer to the Organic Products (Main Page) on CFIA’s website. 3.4.2.15 Other Information
Return to Index
If optional claims (e.g., no preservatives, fresh, natural, pure) appear on the label, indicate on Worksheet 3-1 whether or not the claim meets the requirements outlined in chapter 4 of the Labelling Guide. If a vignette appears on the label, ensure that it is not misleading, as explained in section 3.3 of the Labelling Guide. Furthermore, if an artificial flavour (e.g., artificial apple flavour) is added to the food, whether alone or with natural flavouring and/or the actual ingredient (i.e., real apples), and the vignette suggests the natural flavour source (e.g., picture of an apple), a declaration, in both French and English, stating that the added flavouring ingredient is an imitation, artificial or simulated flavour must appear on or adjacent to the vignette. This applies to prepackaged foods sold at retail. The declaration must meet the same minimum type height as the one required for the net quantity and grade declarations [34, CPLR].
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LABEL VERIFICATION Cooking instructions are not required on processed products. However, establishments that prepare frozen vegetables that do not provide cooking instructions on their label, or that only provide microwave instructions, should consider applying Health Canada’s Policy on Listeria monocytogenes on Ready-to-Eat Foods in their facility. If a website address appears on the label, assess the information on the website (if possible). When referred to on a label, the information on a website is considered an advertisement for the product and is subject to the Food and Drugs Act and Regulations. Any unacceptable statements or claims on the website should be corrected or removed. If this is not possible, the reference to the website must be removed from the label.
3.4.3
Movement of Unlabelled or Mislabelled Processed Products
Return to Index
Industry may request authorization from CFIA to legally convey within Canada or import unlabelled or mislabelled processed products for one of the following purposes: a)
Labelling or Relabelling (i.e., the food products remain in their original containers) Examples:
b)
•
A registered establishment that processes canned corn and only embosses the lot code on each container may request permission to move these unlabelled containers (i.e., bright stock) within Canada for labelling at destination (i.e., the consignee will apply a compliant label on each container prior to further distribution).
•
An importer may request permission to import a shipment of fruit salad in 398 mL cans, labelled in English only, for relabelling at destination (i.e., the consignee will apply a compliant label on each container prior to further distribution in Canada.
Processing and/or Repacking (i.e., the food products are removed from their original containers): Examples: •
A registered establishment that processes and packs frozen strawberries in 10 kg unlabelled containers may request permission to ship these unlabelled containers to a strawberry pie manufacturer in Canada for processing. The consignee (i.e., the pie manufacturer) processes and labels the strawberry pie.
•
A registered establishment may request permission to import 2 kg containers of frozen peas, labelled in English only, for repacking in 350 g bags. The registered establishment repacks the product and applies a compliant label to the 350 g bags.
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3.4.3.1 Authorization for Movement of Unlabelled or Mislabelled Products under the PPR Return to Index Table 3-3 below summarizes the type of authority needed depending on whether the consignee will subsequently label, process and/or repack the unlabelled or mislabelled product. Each shipment of unlabelled product must be accompanied by a specification sheet declaring the mandatory information that is missing from the label (e.g., common name of the product, name and address of the responsible party, net quantity, list of ingredients (if more than one ingredient), nutrition facts table). For traceability purposes, unlabelled product must have markings identifying the manufacturing establishment, the product and the lot code (if applicable). Mislabelled product must not be contain false or misleading information. For the purpose of this authorization, mislabelled products include products for which the labels do not meet: •
the minimum type height requirements;
•
the bilingual labelling requirements;
•
the required location for the mandatory information; and/or
•
other similar errors.
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LABEL VERIFICATION Table 3-3: Type of Authority Needed to Legally Convey Unlabelled or Mislabelled Product
Movement
Intraprovincial
For Processing and/or Repacking
For Labelling or Relabelling Only
(Product Removed from Original Container)
(Product Stays in Original Container)
Prior to the shipping period, the shipper must Request Permission to Label or Relabel at Destination and receive such permission from CFIA [45(1)(a), PPR].
Prior to the shipping period, the shipper must Request Permission to Process and/or Repack at Destination and receive such permission from CFIA [45(1)(b), PPR].
Prior to the shipping period, the shipper must Request Permission to Label or Relabel at Destination and receive such permission from CFIA [45(1)(a) and 59.3, PPR].
In order to be able to convey the product elsewhere in Canada, the shipper must, prior to the shipping period: •
Request a Ministerial Exemption and obtain a Ministerial Exemption from CFIA [59.2, PPR] (see Chapter 14 of this manual); or
•
Request Permission to Process and/or Repack at Destination and receive such permission from CFIA [45(1)(b), PPR].
Interprovincial
The importer must provide evidence, that the food product will be labelled at destination to comply with the PPR [64(1), PPR]. Therefore: •
Import
•
Prior to the importing period, the importer or shipper may Request Permission to Label or Relabel at Destination and receive such permission from CFIA. At the time of entry into Canada, the importer must submit a completed and signed Import Declaration*, with the following statement entered in box 21 of the Import Declaration: “The product will be labelled at destination to comply with the Regulations” (similar wording may be used) [64(2), PPR].
Prior to the importing period, the importer must Request a Ministerial Exemption and obtain a Ministerial Exemption from CFIA [63(1),PPR] (see Chapter 14 of this manual). At the time of entry into Canada, the importer must submit a completed and signed Import Declaration*, with the Ministerial Exemption control number specified in box #20 of the Import Declaration.
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LABEL VERIFICATION * An Import Declaration must accompany each shipment and be submitted to Canada Border Services Agency at the time of entry in Canada. For details, see Chapter 9 of this manual. To request and receive the authority to move unlabelled or mislabelled product: •
The applicant (e.g., shipper, importer) must complete, sign and send the Authorization Request for Movement of Products under the Processed Products Regulations (PPR) (CFIA / ACIA 5567) to the appropriate CFIA contact listed therein. For traceability purposes, unlabelled product must have markings identifying the manufacturing establishment, the product and the lot code (if applicable).
•
The CFIA contact person in the Receiving Area may consult CFIA staff in the shipping and receiving regions to assess the outcome of the application. Permission for the purpose of processing or repacking may be granted without a CFIA inspector detaining the shipment if the shipper and consignee act responsibly in the movement of unlabelled or mislabelled goods. The CFIA contact person must complete, sign and date the shaded area ”for Agency Use Only” and send the form to the applicant, and to CFIA’s Sending and Receiving Regions, as applicable.
•
If the authority is granted:
40 to100) >645 to 2580 (>100 to400) >2580 (>400)
S = Satisfactory U = Unsatisfactory N/A = Not Applicable
1. COMMON NAME
Declaration: must be acceptable common name. May declare style of preparation separately (if applicable) Location: must appear on the Principal Display Panel (PDP) Type Size: minimum type height required on all containers: 1.6 mm Language: must be bilingual (except shipping containers) 2. NET QUANTITY mL (ml or ml)
g or kg Declared by:
L (l or l)
Count
Number + size of containers (for shipping containers) Imperial units (if declared, e.g., fl oz, lb) are not more predominantly displayed than the metric units
Location: must appear on the PDP Type Size: numerals must be in bold font and meet minimum type height requirements based on PDS Chart Rounding of Numbers: 3 figures, or can be 2 if 284 mL) if Canadian address declared) Language: must be bilingual unless it is part of the foreign address Optional on all Other Products:“Product of Canada”, “Made in Canada from domestic and imported ingredients” and similar claims must meet section 4.19 of the Labelling Guide 8. REGISTRATION NUMBER or IDENTIFYING CODE MARK OF THE ESTABLISHMENT (Products Packed in Canada) a) Shipping containers must declare the establishment registration number; b) Containers labelled with first dealer name & address must declare the establishment registration number or its identifying mark. Location: any panel except the bottom Type Size: minimum type height on all containers: 1.6 mm 9. PRODUCTION CODE Required on a) Graded Canned Foods (the code identifies the establishment and packing date) b) Low Acid Canned Foods (the code identifies the establishment, product and processing date)
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N/A
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Appendix 3A
Location: any panel, including the bottom Type Size: minimum type height: 1.6 mm (embossed on the can or marked in indelible ink) 10. SPECIAL WORDING
N/A
Satisfactory
U = Unsatisfactory
Location (for all statements): any label panel except the bottom, except if otherwise stated below Type Size (for all statements): minimum type height required on all containers: $1.6 mm Language (for all statements): must be bilingual Apple Juice with added a) Vitamin C: “Vitamin C Added” or “Vitaminized”, or; b) Carbon Dioxide: “Sparkling” or “Carbonated” Apple Juice from Concentrate with added Carbon Dioxide: “Sparkling” or “Carbonated” Apple Slices : “solid pack” (if little or no free liquid) or “heavy pack” (if max. drained weight processing permits) Apricot Nectar with added Vitamin C: “Vitamin C Added” or “Vitaminized” Asparagus Cuts or Cuttings Packed Without Tips (Canned - Canada Choice Grade): “tips removed” or “without tips” immediately below the product name Beans: Green or Wax (canned or frozen): “whole”, “cut”, “whole vertical pack”, “asparagus style”, “french style” or “french cut” Blueberries (frozen): “Wild” or “Cultivated” and “I.Q.F.” (Individually Quick Frozen) or “Non-Free Flowing” Corn (canned): “Cream style”, “Vacuum pack”, “Brine pack”, “Packed in brine” or “Packed in liquid” Fruits (canned or frozen) packed in juice or syrup + listed in Schedule IV, Table III, PPR: “Extra heavy syrup”, “Heavy syrup”, “Light syrup”, “Slightly sweetened water”; “Extra heavy fruit juice syrup”; “Heavy fruit juice syrup”; “Light fruit juice syrup”; “Slightly sweetened fruit juice”, “Packed in (name of fruit(s)) juice* ”, or; “Packed in (name of fruit(s)) juice from concentrate* ” * the last 2 options apply only to unsweetened juice and unsweetened juice from concentrate Fruits (frozen) packed in sugar, invert sugar, dextrose of glucose in dry form: “x % sugar, invert sugar, dextrose or glucose added“ Fruit Juice packed in a non-hermetic container: “Keep refrigerated” Grape Juice, Grape Juice from Concentrate with added: a) Vit C: “Vitamin C Added” or “Vitaminized” b) Carbon Dioxide: “Sparkling” or “Carbonated” Jam, Jelly or Marmalade with Added Pectin: “with pectin” immediately below the product name in letters of at least: 1/8" in height (containers > 284 mL) and 3/32" in height (containers < 284 mL) Low Acid Foods in Hermetic Containers which must be continuously refrigerated or frozen: “Keep refrigerated” or “Keep frozen” Orange Marmalade made from Seville, or similar bitter varieties: “Seville”, “Extra Bitter” or “Bitter” Orange Juice (Sweetened Frozen Concentrated): “Sweetened” on the PDP and in the same type height as “Concentrated Orange Juice” Peaches (Canned): “Freestone” or “Clingstone” Pie Fruits : “solid pack” (if little or no free liquid); “heavy pack” (if max. drained weight that processing permits)
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U
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Appendix 3A
Prune Nectar: a) with added Vitamin C: “Vitamin C Added” or “Vitaminized”, and; b) the statement “A water extract of dried prunes” immediately following product name Sauerkraut with Preservative packed in a non-hermetic container: “Keep refrigerated” Vegetable Juices (Mixed), with added Vitamin C: “Vitamin C Added” or “Vitaminized” 11. NUTRITION FACTS TABLE
S
U
N/A
S
U
N/A
Use the Checklist for the Nutrition Facts Table (in the Nutrition Labelling Toolkit). Indicate the final assessment in the applicable column on the right. 12. NUTRIENT CONTENT CLAIMS and HEALTH CLAIMS Indicate the final assessment in the applicable column on the right. 13. STORAGE INSTRUCTIONS Required on foods needing refrigeration or freezing (e.g., “Keep Refrigerated”, “Keep Frozen”) Location: any label panel, except the bottom Type Size: minimum type height: $ 1.6 mm 14. ORGANIC CLAIM Location (for all statements): any label panel, including the bottom Language (for all statements): must be bilingual (except shipping containers) The organic logo (product contains > 95 % organic ingredients): the certification body is identified on the label and appears on CFIA’s list. In addition, for imported products, the statement "Product of" or "Imported from" precedes the country of origin’s name and is near the logo
“Organic” product (product contains > 95 % organic ingredients): the certification body is identified on the label and appears on CFIA’s list "x% organic ingredients" (multi-ingredient product contains > 70% and < 95 % organic ingredients): the % of organic ingredients and the certification body are declared on the label. The certification body appears on CFIA’s list. National logo is not allowed on the label "Organic (name of the ingredient)" in the list of ingredients (multi-ingredient product contains < 70% organic ingredients): Allowed. Organic logo and the certification body cannot appear on the label 15. OTHER INFORMATION Optional Claims:
No preservatives (Sections 4.3.1 & 4.3.2 of the Labelling Guide Fresh (4.5 of the Labelling Guide) Natural (4.7 of the Labelling Guide) Pure/100% (4.10 of the Labelling Guide) Other:
Vignettes or Pictures / Artificial Flavours [34 CPLR; 2.10 of the Labelling Guide]: Type size as per PDS Chart “Brand” or “Marque” if geographic or descriptive name is declared Website address on the label (is considered part of the label and must be evaluated as such)
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FINAL ASSESSMENT:
LABEL VERIFICATION
Satisfactory
Unsatisfactory
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