TECH TALK
Are your Labels Compliant? By Daphne Nuys-Hall, Technical Director, Meat & Poultry Ontario
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abels are an essential component of selling prepackaged meat products. It tells the consumer who you are, what products you are selling and why they should buy your products above all others in the meat counter. However, inaccurate, misleading or incomplete labels could negatively affect your consumer’s perception of your product or could be in violation of one or more labelling regulations which could lead to an immediate audit failure or potentially a product recall. Finding the answer you need when it comes to labelling your pre-packaged meat products can be challenging and onerous considering companies must adhere to requirements under several pieces of legislation including the Food and Drugs Act (FDA) and Regulations (FDR), the Safe Food for Canadians Act (SFCA) and Regulations, and Ontario Meat Regulation 31/05 for provincially licensed meat plants. This article will help you navigate the regulatory landscape to find the answers to your most frequently asked labelling questions.
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The Food and Drugs Act and Regulations The Food and Drugs Act and Regulations (FDA and FDR) provide the regulatory framework for the manufacture and labelling of all foods in Canada, whether federally, provincially, or municipally manufactured. Specifically, the FDR is where food manufacturers will find the requirements for general, allergen, and nutrition labelling (including the Nutrition Facts Table (NFT)), and health claims for foods. The FDR also includes several standards for foods, including meat, which prescribe additional labelling and packaging requirements such as for mechanically tenderized beef. It is important to note that Health Canada published amendments to the nutrition labelling requirements in December 2016 with a five (5) year transition period, ending December 2021. However, given the challenges imposed by COVID-19, the Canadian Food Inspection Agency (CFIA) will focus its efforts on education and compliance promotion for the first year, until December 14, 2022. The key changes relate to the format of the nutrition facts panel to make the information more relevant, consistent, and easier to read and are reflected in the diagram below.
One often asked question is “when is it required to have the nutrition facts panel?”. Nutrition facts tables are required on prepackaged products with more than one ingredient, those that make any health or nutrition claims and on all ground meat products. Along with the changes to the NFT, Health Canada made amendments to the requirements for the list of ingredients that must be implemented at the same time as the NFT. The changes to the list of ingredients include grouping sugars-based ingredients in brackets after the name ‘sugars, making the text in black font on white or neutral background, creating minimum type height requirements for ingredients, using bullets or commas to separate ingredients and using both upper- and lower-case letters for the ingredients in the list. Continued on page 28
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BlockTalk - Summer 2022
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