Volume 13, Number 4 - April
2012
Hello from Food
Label News.
We're pleased to continue the popular topic about the
differences between U.S. and Canadian labels in our feature
article this month. We also cover the issue of dual
declarations on a Nutrition Facts Panel in our series
enjoyed by our readers and help a start-up company with
formulation and labeling requirements in the Reader Q&A.
Happy Spring!
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It's Tricky: Canadian label for "Made in USA"
In the world of products that
are made in the U.S. and sold in Canada, one might think
that simply adding a French translation to the English
ingredient statement would do the trick. But creating such a
label is a bit more tricky.
As we've previously reported
in Food Label News, it is not possible to create a
single label that satisfies the needs of both U.S. and
Canada, even if it is bilingual English/French. There are
several key differences in ingredient standards of identity
and reporting requirements. Here are some of those
differences:
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Some ingredients such as enriched flour and baking
powder do not require a parenthetical declaration of
sub-ingredients in Canada but they do in the U.S. For
example: enriched flour (wheat flour, niacin, reduced
iron, thiamin mononitrate, riboflavin, folic acid). |
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If a sub-ingredient is present in another ingredient at
a level less than 10%, then a parenthetical declaration
of sub-ingredients is not required in Canada, however it
still is required in the U.S. |
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In Canada, margarine is required to have Vitamins A and
D added. Canadian standards of identity for margarine
and shortening include a list of "may contain"
components and if a product contains other components
that fall outside of those in the "may contain" clause,
those components could disqualify the food from being
labeled as margarine or shortening in Canada. When
margarine or shortening meets the standard of identity
in Canada, it does not require a parenthetical
declaration of sub-ingredients; in the U.S., these
ingredients must always be listed with a parenthetical
declaration of sub-ingredients. |
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Helpful Links
CFR Title 21 for
FDA-regulated foods
CFR Title 9 for
USDA-regulated foods
FDA Food Labeling
Guide
FTC Enforcement Policy on Food Advertising
USDA Policy Book for
Food Standards and Labeling
Canadian Food & Drug
Regulations
CFIA
Guide to Food Labelling and
Advertising
Silliker/Food Consulting Company Label Claims
Guide
Join
Food Label Community for
key takeaways from FDA's March 5-6 food labeling webinar
and other news
Reader
Favorites
Food Labels in U.S. & Canada: The same and different
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Such nuances
between Canadian and U.S. label regulations highlight the
need to be extra careful in your research and label
development. See side panel (above right) for helpful resources to get you
started. |
Examples of Nutrition Facts
Labels:
Part 7 of 10
Requirements for
Nutrition Facts in the U.S. vary based on several
factors. This series continues with examples of dual
declaration on Nutrition Facts labels.
Dual declaration
Nutrition Facts are always optional. Scenarios where
the dual declaration format are used include: 1)
food requiring further preparation, e.g., sauce mix
dry and prepared; 2) typically eaten with another
food, e.g., cereal and cereal with milk; 3) to show
an additional serving size, e.g., entree portion and
appetizer portion.
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See
the
helpful how-to examples for each scenario described
above as well as other examples of Nutrition Facts labels. |
Q. |
I plan on distributing a jarred tomato sauce to my
friends, family and through a farmer's market. I want to
label it as "All Natural." However, the bulk tomato
sauce I buy has some preservatives added to extend the
shelf life. Must I include the preservatives in my label
even though I cook it for hours?
− R.C., Florida, Food Entrepreneur |
A. |
Yes, if preservatives are
used in a product or as a sub-ingredient of another
ingredient, they must be declared on the label.
Therefore, if you want to have an all natural product,
you will need to source a bulk tomato product that does
not contain preservatives.
Read more. |
At Your Service
Food
Consulting Company,
founded in 1993, provides nutrition analysis, food labeling
and regulatory support to ensure 100% compliance with FDA
regulations. With well over 1,500 clients worldwide, we're
pleased to provide
information to address your
food labeling needs.
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are working to stay connected. To build your network, we
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there, join the
Food Label Community.
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© 2012. Food Consulting Company, Del Mar, CA. All rights reserved.
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