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Key Differences in Ingredient Labeling
for U.S. and Canada

 

Ingredient

U.S.

Canada

1

Enriched Flour

must include sub-ingredients:
e.g., enriched flour (wheat flour, niacin, reduced iron, thiamin mononitrate, riboflavin, folic acid)

does not require ingredient sub-listing
NOTE:  The white flour used in all food products sold in Canada must be enriched. 

2

Baking Powder

must include sub-ingredients:
e.g., baking powder (sodium bicarbonate, sodium aluminum sulfate, cornstarch)

does not require ingredient sub-listing

3

Margarine

must include sub-ingredients:
e.g., margarine (liquid soybean oil, partially hydrogenated soybean oil, water, whey, salt, mono & diglycerides, soy lecithin, potassium sorbate-preservative, sodium benzoate-preservative, artificial flavor, phosphoric acid, vitamin A palmitate, beta-carotene color)

does not require ingredient sub-listing
NOTE: Some U.S. foods contain an ingredient identified as “margarine” (with the parenthetical included), but the “margarine” does not meet Canadian standards. Without a formulation change the parenthetical statement must be present and the word "margarine" cannot be used.

4

Shortening

must include sub-ingredients:
e.g., vegetable shortening (partially hydrogenated soybean and cottonseed oils)

does not require ingredient sub-listing
NOTE:  Some U.S. foods contain an ingredient identified as “shortening” (with the parenthetical included), but the “shortening” does not meet Canadian standards. Without a formulation change the parenthetical statement must be present and the word "shortening" cannot be used.

5

Spices

may collectively be declared as “spices” without identifying the specific spice if the ingredient is contained in the listing for spices found in 21CFR101.22
NOTE:  There are differences in FDA & USDA regulations.  For example, FDA does not permit garlic powder and onion powder to be declared as “spices” while USDA does.

may collectively be declared as “spices” without identifying the specific spice if the ingredient is contained in the listing for spices found in the FDR Table following B.01.009 (2)
6

FD&C certified colors

must be declared by color and number:
i.e., Red 3, Red 40, Yellow 5, Yellow 6, Blue 1, Blue 2

may collectively be declared as “colours”, but if specifically named, must be declared by common name:
i.e., Erythrosine, Allura Red, Tartrazine, Sunset Yellow FCD, Brilliant Blue FCF, Indigotine

7

Other added colors

ingredients used as colors may  collectively be declared as “artificial colors” or “colors” OR by common or usual name, except that carmine or cochineal must be specifically listed
NOTE:  Added colors (from any source) are not considered “natural” in U.S.

may collectively be declared as  “colours” (no differentiation from FD&C certified colours)
NOTE:  If the colour is from a natural source (e.g., beet powder), it may be labeled as a “natural colour” in Canada.

8

Flavors

may collectively be declared as “natural flavor” or “artificial flavor” without listing the specific flavor or its components
NOTE:  In both the US and Canada, if an allergen is present, it must be called out in brackets behind the flavor ingredient OR in a separate Contains allergen statement.

may collectively be declared as “natural flavour” or “artificial flavour” without listing the specific flavour or its components
NOTE:  Neither Canada nor U.S. recognize nature-identical flavors used in Europe.  Those flavors are labeled as artificial flavors.

9

Preservatives

function must be declared:
e.g., sodium benzoate (preservative)

function not required

10

Ingredients < X%

U.S. regulations include a provision for listing minor ingredients (those present at 2% or lower) in any order at the end of the ingredient statement with the phrase “Contains X% or less of the following:”

Canadian regulations specify that ONLY specific classes of ingredients can be shown at the end of the ingredient statement in any order.
For details, see:
www.foodlabels.com/q&a.htm#2%-or-less

Note: If you need help with ingredient statements or allergen statements, contract with Food Consulting Company to prepare or review your Ingredient Statements and Allergen Compliance with our Ingredient Statement service or receive ready help for all food labeling questions by purchasing Ongoing Regulatory Support. As always, we will answer client questions related to work completed within the past 90 days without additional charge.  See services.

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