New Trends in Consumption and Food Information

Transcription

New Trends in Consumption
and Food Information
Research Project - Final Report
Submitted to Industry Canada’s
Office of Consumer Affairs
By
April 2007
Research report published by:
6226 Saint-Hubert
Montreal, Que H2S 2M2
Telephone: 514-521-6820
Toll-free: 1 888 521-6820
Fax: 514-521-0736
[email protected]
www.consommateur.qc.ca/union
Union des consommateurs’ membership
ACEF Abitibi-Témiscamingue
ACEF Amiante – Beauce – Etchemins
ACEF de l’Est de Montréal
ACEF de l'Île-Jésus
ACEF de Lanaudière
ACEF Estrie
ACEF Grand-Portage
ACEF Montérégie-Est
ACEF du Nord de Montréal
ACEF Rive-Sud de Québec
Association des consommateurs
pour la qualité dans la construction
Individual members
Union des consommateurs is a member of the organization Consumers International (CI), a federation
with 234 members from 113 countries.
Researched and written by
• Jean-François Henry, Charles Tanguay, Marcel Boucher
Editor in chief
• Marcel Boucher
Acknowledgements
• Marie Marquis, Ph.D., Dt.P. Professeure agrégée, Faculté de Médecine, Département de
nutrition, Université de Montréal
• Yves Jalbert, Ph.D., Conseiller scientifique, Institut national de santé publique du Québec
ISBN : 978-2-923405-16-2
Union des consommateurs would like to thank Industry Canada for its financial assistance to this
research project. The opinions expressed in this report are not necessarily shared by Industry Canada or
the Government of Canada.
In the interests of concision, we chose to not feminize the text herein.
© Union des consommateurs 2007
Union des consommateurs, report 2006-2007
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UNION DES CONSOMMATEURS, strength through networking
Union des consommateurs is a non-profit organization whose membership is comprised of
several ACEFs (Associations coopératives d’économie familiale), l ‘Association des
consommateurs pour la qualité dans la construction (ACQC), as well as individual members.
Union des consommateurs’ mission is to represent and defend the rights of consumers, with
particular emphasis on the interests of lo w-income households. Union des consommateurs’
activities are based on values cherished by its members: solidarity, equity and social justice, as
w ell as the objective of enhancing consumers’ living conditions in economic, social, political and
environmental terms.
Union des consommateurs’ structure enables it to maintain a broad vision of consumer issues
even as it develops in-depth expertise in certain programming sectors, particularly via its
research efforts on the emerging issues confronting consumers. It activities, which are nationwide in scope, are enriched and legitimated by its field work and the deep roots of its member
associations in the community.
Union des consommateurs acts mainly at the national level, by representing the interests of
consumers before political, regulatory or legal authorities or in public forums. Its priority issues, in
terms of research, action and advocacy, include the following: family budgets and indebtedness,
energy, telephone services, radio broadcasting, cable television and the Internet, public health,
food and biotechnologies, financial products and services, business practices, and social and
fiscal policy.
Finally, regarding the issue of economic globalization, Union des consommateurs works in
collaboration with several consumers groups in English Canada and abroad. It is a member of
Consumers International (CI), a United Nations recognized organization.
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TABLE OF CONTENTS
UNION DES CONSOMMATEURS, strength through networking ...........................................3
INTRODUCTION ........................................................................................................................6
1.
1.1
1.2
2.
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
3.
3.1
3.2
3.3
EVOLUTION OF CONSUMER CONCERNS AND PRESENT AND EMERGING
CONSUMER TRENDS IN RELATION TO FOOD ISSUES AND FOOD LABELLING.....8
New concerns driving the emergence of new consumer trends .....................................10
Consumers and labelling ...............................................................................................15
REVIEW OF THE CODEX ALIMENTARIUS COMMISSION’S STANDARDS AND
GUIDELINES ON THE LABELLING OF PREPACKAGED FOODS .............................18
General Standard for the Labelling of Prepackaged Foods............................................18
2.1.1 Mandatory labelling particulars .............................................................................19
Guidelines on Nutrition Labelling ...................................................................................21
General Guidelines on Claims .......................................................................................22
Guidelines for using nutrition and health claims .............................................................22
Guidelines on the labelling of organically produced foods..............................................23
Labelling of genetically modified (GM) foods .................................................................25
Labelling of foods that respect fair trade principles ........................................................26
Summary .......................................................................................................................26
REVIEW OF EXISTING REGULATORY FRAMEWORKS ON FOOD LABELLING .....28
Canada..........................................................................................................................28
3.1.1 General requirements concerning the labelling of prepackaged foods ..................29
3.1.2 Claims concerning food composition and quality ..................................................32
3.1.3 Food origin claims ................................................................................................33
3.1.4 Nutrition labelling ..................................................................................................34
3.1.5 Claims concerning nutritional value ......................................................................35
3.1.6 Health claims ........................................................................................................36
3.1.7 Labelling of organically farmed foods....................................................................38
3.1.8 Labelling of genetically modified (GM) foods.........................................................40
3.1.9 Labelling of foods that respect fair trade principles ...............................................40
3.1.10 Utilization of third party endorsements, logos and seals of approval ...................40
In the United States .......................................................................................................41
3.2.1 General requirements concerning labelling of prepackaged foods ........................42
3.2.4 Claims concerning nutritional value ......................................................................43
3.2.5 Health claims ........................................................................................................44
3.2.9 Claims on livestock production methods in relation to animals raised for human
consumption .........................................................................................................46
The European Union .....................................................................................................46
3.3.1 General requirements concerning labelling of prepackaged foods ........................48
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3.4
3.3.4 Nutrition labelling ..................................................................................................52
3.3.5 Nutritional value and health claims .......................................................................52
3.3.6 Health claims ........................................................................................................52
Australia/New Zealand ..................................................................................................55
3.4.1 General requirements on the labelling of prepackaged foods.................................................56
3.4.2 Claims in relation to food origin .................................................................................................57
3.4.3 Claims concerning nutritional value ..........................................................................................57
3.4.4 Health claims ..............................................................................................................................57
3.4.5 Labelling of organically farmed foods .......................................................................................58
3.4.6 Labelling of genetically modified (GM) foods ...........................................................................58
3.4.7 Labelling of foods that respect fair trade principles..................................................................58
3.5
Summary of regulatory practices concerning food labelling ...........................................59
3.5.1 Regulation as a function of consumers’ “convenience” related concerns ..............................59
3.5.2 Regulation as a function of consumers’ nutrition and health concerns ..................................60
3.5.3 Regulation as a function of diverse consumer concerns (health issues, the environment,
and social, cultural, ethical, political issues) ............................................................................61
4.
4.1
4.2
4.3
4.4
OVERVIEW OF INITIATIVES IN SUPPORT OF LABELLING POLICIES.....................63
Canada..........................................................................................................................63
United States.................................................................................................................65
The European Union .....................................................................................................65
Australia/New Zealand ..................................................................................................65
5.
5.1
5.2
5.3
5.4
SURVEY ON FOOD LABELLING .................................................................................66
Objectives and Methodology .........................................................................................66
Profile of respondents....................................................................................................68
Highlights and analysis of survey results .......................................................................69
The fit between information needs and presently available information .........................75
5.4.1 Satisfaction of needs and concerns regarding nutrition and health issues ............76
5.4.2 The satisfaction of needs and concerns related to the environment, society,
culture, ethics and politics .....................................................................................77
Respondents’ additional comments ...............................................................................78
Squaring present awareness and education strategies with survey results....................79
The study’s limitations ...................................................................................................80
5.5
5.6
5.7
CONCLUSIONS .......................................................................................................................81
RECOMMENDATIONS.............................................................................................................84
MEDIAGRAPHY .......................................................................................................................89
APPENDIX 1 ..........................................................................................................................101
APPENDIX 2 ..........................................................................................................................102
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INTRODUCTION
In a context where market liberalization is ascendant and where the consumer is sometimes
overwhelmed by the effects of globalization, consumers are showing a growing interest in
agrifood issues. Certain factors—such as the recognition of the links between the quality of
one’s diet and health,1 the increasing prevalence of obesity and the costs of chronic illnesses
caused by poor diets—favour consumer awareness of the importance of food production and
processing methods, as well as regarding the quality of food and diets in general. Moreover, in a
market where food products come from every corner of the earth, making the long journey from
the farm to the consumer’s fork, consumers are led to reflect on the operating methods of the
entire “farm to fork” chain and to question their purchases as they integrate environmental,
social, cultural, ethical and political considerations into the criteria governing their grocery
shopping.
These reflections are the source of new concerns and new consumer trends. However, the
information presently available on food labels doesn’t always meet consumers’ requirements.
These new concerns have in effect created new needs in terms of information disclosure to
consumers. The latter, in addition to demanding detailed nutritional information, notably
concerning health claims, demand information that is clearer, complete, transparent, coherent
and even standardized, particularly regarding production methods, processing processes and
food origins.
“Consumers are of the opinion that government and industry do not provide them with
enough information to make informed choices. Very often, the information on food labels
is insufficient and hard to read. The information provided by governments, industry or
other sources is often less than clear and sometimes contradictory.”2
Appropriate knowledge of the products they intend to purchase seems of increasing importance
to the consumer. The latter’s choices are, after all, influenced by more and more factors. This is
especially the true for food products since they undergo modifications and transformations of
which the consumer is often unaware. As the information presently available on food labels isn’t
necessarily sufficient to answer their questions, many consumers are left with a feeling of
dissatisfaction. A deeper look into the question of food labelling is needed if such labelling is to
meet the needs of consumers who wish, through the vehicle of responsible consumption, to not
only live healthier lives but also have an effect on society by exercising their sovereignty in the
agrifood market to force it to move closer to the principles of sustainable development.
This study presents a portrait of the new consumer trends in the agrifood sector, with a view to
identifying the information needs that they engender.
1
“89% of Canadians recognize the links between diet and long term health”. This quote, drawn from
L'alimentation santé: quand trois acteurs se rencontrent, (SS. Julien, et al), was reproduced in BioClips+,
Vol. 8, No 3, April 2005, a publication of le Ministère de l'Agriculture, des Pêcheries et de l'Alimentation du
Québec (MAPAQ).
2
Food and Agriculture Organisation FAO), Comprendre le Codex Alimentarius (version revised and
updated in 2005), <http://www.fao.org/docrep/008/y7867f/y7867f07.htm#bm07> (consulted on 31 January
2006).
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Our study examines the regulatory framework governing food labelling in North America,
Europe and Australia/New Zealand. This is done using an analysis grid based on the standards
and guidelines of the Codex Alimentarius Commission. Our study also endeavours, via a survey
done with consumers, to identify 1) the likely determinants of consumer behaviour as regards
purchasing decisions and 2) their emerging concerns in terms of food and dietary issues.
The results of our study should, on the one hand, make it possible to sensitize consumers
regarding the information required to satisfy their concerns and foster more responsible
consumer trends, as well as, on the other hand, provide information that may be useful to the
regulatory authorities in the development of labelling policies that are in tune with and facilitate
these new consumer trends.
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1.
EVOLUTION OF CONSUMER CONCERNS AND PRESENT AND EMERGING
CONSUMER TRENDS IN RELATION TO FOOD ISSUES AND FOOD
LABELLING
In the not so distant past—before the industrialization of agriculture and before basic crops and
staples fell under the sway of the rules and regulations of international trade—the main concern
of consumers, who then consumed more locally produced food, was to avoid paying too much
for the food they needed to keep body and soul together and to continue working simply to
ensure the basic needs of the families. Large low-income families could survive by eating food
grown in their own gardens or on neighbouring farms. It was only decades later, at the height of
the Green Revolution,3 that consumers’ food-related concerns began to broaden. Families
gradually became smaller, employment opportunities expanded and agricultural yields
experienced spectacular growth. As a result, food prices, while still important in the eyes of
consumers, were no longer the only issue. Consumers came to see the links between a good
diet and good health. As a result, diversifying their diets and food quality arose as new
consumer concerns.
An Agriculture and Agri-Food Canada (AAFC) report has suggested that health and
convenience are now the two main factors influencing consumers when it comes to their food
purchasing decisions. 4 For example, in 2005, Canadian consumers consumed less processed
foods and more fruits and vegetables—a reflection of their greater concern over health.
However, other foods also became more popular including, for example, instant coffee, pizzas,
submarine sandwiches (fresh, frozen and refrigerated), i.e. foods that are apparently convenient
and adapted to contemporary lifestyles. Beverages with added functions, such as smart-drinks,
enriched and mineralized drinks and “beverages as a nutritional supplement or marketed as the
ultimate convenience food”5 are also increasingly popular with youth. They see them as natural
and healthy, as well as a way of obtaining the energy needed to make it through their exams.6
3
The term “Green Revolution” was popularized around 1970 in reference to a period of technology
induced change that occurred in agriculture between 1944 and 1970. This revolution made it possible to
double world food production via, notably, the massive use of inputs and chemical fertilizers. See: “La
FAO lance un appel à une deuxième ‘révolution verte,’”
<http://www.un.org/apps/newsFr/storyF.asp?NewsID=12930&Cr=FAO&Cr1=verte>. See also: 1) M.
Griffon, Révolution Verte, Révolution Doublement Verte : Quelles technologies, quelles institutions et
quelle recherche pour les agricultures de l'avenir ? Centre de coopération internationale en recherche
agronomique pour le développement (CIRAD),
<http://www.cirad.fr/fr/regard_sur/devdur/pdf/doc_griffon2.pdf>, and 2) Wikipedia, “Révolution verte,”
<http://fr.wikipedia.org/wiki/R%C3%A9volution_verte>. (Consulted on 9 October 2006).
4
Agriculture and Agri-Food Canada (AAFC), “What’s Hot and What’s not in the Canadian Food Market
2005,” <http://www4.agr.gc.ca/AAFC-AAC/display-afficher.do?id=1170954034728&lang=e> (consulted on
20 September 2006).
5
Agriculture and Agri-Food Canada (AAFC), “Canadian Food Trends to 2020,”
<http://www4.agr.gc.ca/AAFC-AAC/display-afficher.do?id=1170944121865&lang=e> (consulted on 2
October 2006).
6
Radio-Canada, “Enquête: les boissons énergisantes,” L’épicerie television program, broadcast on 28
February 2003), <http://radio-canada.ca/actualite/lepicerie/docArchives/2003/02/28/enquete.html>
(consulted on 2 October 2006).
page
8
However, the concerns of consumers in the 21st Century go beyond health and convenience.
Due to policies favouring market liberalization and international trade, agrifood multinationals
are constantly increasing their control over what we eat and are increasingly imposing their
models in the farming and food sectors. One notable result is the impoverishment of our “food
culture” and a distancing of consumers from actual producers and their resources. The
application of export market oriented policies also have an impact on food security 7 even as
they contribute to widening the disparities between rich and poor, and between the global North
and the Global South. Moreover, such policies compromise our capacity to exercise certain
rights as consumers, particularly the right to information and the right to choose. New
technologies (e.g. genetic engineering of crops and the use of pesticides and high yield mashes
and chemical fertilizers) are fundamental to modern agriculture’s production methods, but create
considerable stress on the environment. Today’s agrifood system is engendering new problems
in ecosystems and in society as well. New consumer concerns have arisen in parallel with these
problems.
The questions of concern to consumers, long restricted to the issues of price and food safety,
have widened greatly and now include, in addition to health and convenience, environmental,
social, cultural, ethical and political issues.8
These values favouring responsible consumption in the food sector reflect an international
phenomenon. Thus, a survey of Europeans’ attitudes regarding the environment published in
November 2004—i.e. the first following the EU’s expansion to 25 countries—revealed that 88%
believe that political leaders should integrate environmental issues into the elaboration of public
policy. Europeans are as likely to identify the environment as a factor influencing the quality of
life as they are social factors (i.e. 72% in both cases), which is almost as many as identify
economic factors (78%). 9
In a document entitled “Canada’s National Strategy for Agri-Food Research and Technology
Transfer - 1997-2002,” the Canadian Agri-Food Research Council (CARC) recognized that
consumers, in addition to being more concerned about the quality and the nutritional content of
the food they consume, demand “assurances that environmental (...) issues are being properly
addressed in the production of food.”10 The Council further states that “meeting consumer
demands will be one of the top issues facing Canadian agri-food researchers and managers
(...).”
Agriculture and Agri-Food Canada (AAFC), which arrived at the same conclusion as the CARC
by analyzing the results of its own surveys,11-12 identified, in its report on food trends in Canada
7
"Food security exists when all people, at all times, have physical and economic access to sufficient, safe
and nutritious food to meet their dietary needs and food preferences for an active and healthy life. “ Food
and Agriculture Organisation, Rome Declaration on World Food Security,
<http://www.fao.org/docrep/003/w3613e/w3613e00.htm> (consulted on 19 October 2006).
8
S.S. Julien, “Produits biologiques et équitables: quels types de consommateurs y seraient les plus
sensibles ?” BioClips, Vol. 14, No 1 (January, 2006).
9
European Commission, “Special Environment Eurobarometer: Attitudes of Europeans towards the
Environment,” <http://ec.europa.eu/environment/barometer/index.htm> (consulted on 25 September
2006).
10
Canadian Agri-Food Research Council (CARC), “Canada's National Strategy for Agri-Food Research
and Technology Transfer -1997 – 2002,” <http://www.carc-crac.ca/english/national_strategy/strge.htm>
(consulted on 20 September 2006).
11
M. Marcotte, “Canadian Consumer Food Buying Trends and Canadian Consumer Attitudes Towards
Agri-Food Issues,” a study for Agriculture and Agri-Food Canada (September 1998).
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9
between now and 2020, several elements that will influence consumers in their food choices in
the coming years.13 By comparing generations of consumers from 1944 to 1995, the AAFC
report was able to paint a picture, over time, of consumers’ formative influences and
characteristics and thus, indirectly, a picture of the factors influencing consumer’s diets over
several generations. The following were among the factors of note: globalization related-issues,
environmental awareness, media fragmentation, obesity and its attendant issues, the advent of
a generation of labelling/packaging readers, the share of income allocated to food expenditures,
consumer confidence re the production of “safe” foods, food spoilage, food-related illnesses,
additives and contaminants, food traceability, the ethical treatment of animals, and the country
of origin. 14 The last factor suggests an interesting finding: 60 years after the dawn of the Green
Revolution, consumers are, to a certain extent, advocating a back to the basics trend as they
increasingly demand locally grown food.
1.1
New concerns driving the emergence of new consumer trends
This evolution in consumers’ food-related values and concerns is already evident in the growing
demand for certain food products. For example, more and consumers are opting for organically
farmed foods. In the 1980s and 1990s, the main reason consumers sought organically farmed
foods was to protect the environment. However, today, polling data indicates that in addition to
these concerns, consumers’ consumption of such products is motivated by a variety of other
factors. Consumers believe that organic foods are healthier, more nutritional and have more
taste.15 Furthermore, they believe that buying such foods is a way to support small farms and
local producers, 16 as well as promote a healthy relationship between people and farming,
sustainable development and water conservation.17 In a word, the consumers who opt for
organic foods do so in response to health-related concerns, as well as out of concern for social,
cultural and environmental issues.
In effect, organic farming is based on environmentally friendly ecological principles. Organic
farming makes it possible to avoid using chemical pesticides or herbicides, synthetic fertilizers
or genetically modified seeds. It also contributes to soil recuperation through proven methods
12
Senate of Canada - Report of the Standing Committee on Agriculture and Forestry, Value-Added
Agriculture in Canada, December, 2004, <http://www.parl.gc.ca/38/1/parlbus/commbus/senate/Come/agri-e/rep-e/rep02dec04-e.htm> (consulted on 23 February 2006).
13
Serecon Management Consulting Inc., Canadian Food Trends to 2020: A Long Range Consumer
Outlook, Prepared for Agriculture and Agri-Food Canada (Edmonton: Serecon Management Consulting
Inc., July 2005).
14
Agriculture and Agri-Food Canada (AAFC), “Canadian Food Trends to 2020,”
<http://www4.agr.gc.ca/AAFC-AAC/display-afficher.do?id=1170944121865&lang=e> (consulted on 20
September 2006).
15
Inter-American Institute for Cooperation on Agriculture (IICA), “Canada: An Emergent Market for
Organic Products,” <http://www.iica.int/comuniica/n_17/art.asp?art=3> (consulted on 21 September
2006).
16
L. Oberholtzer, et al, Price Premiums Hold on as U.S. Organic Produce Market Expands (United States
Department of Agriculture: May 2005),
<http://www.ers.usda.gov/publications/vgs/may05/VGS30801/VGS30801.pdf> (consulted on 21
September 2006).
17
A. Kremen, et al, Organic Produce, Price Premiums, and Eco-Labeling in U.S. Farmers’ Markets
(United States Department of Agriculture: April 2004),
<http://www.ers.usda.gov/publications/VGS/Apr04/vgs30101/vgs30101.pdf#search=%22Organic%20Pro
duce%2C%20Price%20Premiums%2C%20and%20EcoLabeling%20in%20U.S.%20Farmers%E2%80%99%20Markets%22> (consulted on 22 September 2006).
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such as crop rotation, the spreading of composted organic matter and the use of natural
fertilizers. As for organic livestock production, no growth hormones, meat and bone meal or
antibiotics are used. In addition, animals are given decent living conditions that allow them to
move freely and enjoy regular exposure to sunlight. Finally, processed organic farming products
do not contain colouring agents, chemical preservatives, artificial flavours or synthetic additives,
and they are not irradiated. 18
In Canada, organic food consumption is growing by over 20% per year and nearly 40% of
Canadians (18% on a regular basis and 22% occasionally) consume organic products.19 The
same trends may be observed in other countries. Since 1998, the annual world-wide growth rate
of the organic farming industry is about 20%. Experts predict that in 2025 organic products of all
kinds will be widespread and an integral part of the daily environment.20
The U.S. Department of Agriculture’s Economic Research Service (USDA-ERS) reports that the
European market for organic foods, which has an average annual growth rate of 6-8%, is more
mature in comparison with its American counterpart. The latter will continue to expand rapidly
with annual growth rates oscillating around 9 to 16 until 2010. Consumers of organic foods, 95
to 97% of whom live in North America and Europe, constitute a world market of about 25 billion
dollars, which should peak at 80 billion dollars (U.S.) in 2008.21
According to a report published in 2004 by the International Federation of Organic Agriculture
Movements (IFOAM), markets for organic foods, which are presently almost exclusively
restricted to industrialized countries, should develop in several emerging countries such as
Brazil, China, India and South Africa, i.e. in areas of rapid economic growth. 22
An opinion survey by the Quebec magazines Protégez-vous and Québec Sciences indicated
that 78% of consumers are ready to pay more for organic foods rather than buy cheaper
genetically modified products.23 This finding was confirmed by the AAFC, which recognizes that
consumers seek foods that are superior in quality.24
Moreover, it’s hard to talk about organic farming without also addressing genetically modified
(GM) crops. As demonstrated by increasingly numerous reports and studies, coexistence
between these two types of agriculture is practically impossible due to the cross contamination
18
Conseil des appellations agroalimentaire du Québec (CAAQ), “Qu’est-ce qu’un produit bio ?”
<http://www.caaq.org/appellation-biologique/espace-consommateurs/produit-bio.asp> (consulted on 5
October 2006).
19
S. Ben Salha, et al, “Les produits biologiques: quel est leur avenir sur le marché canadien ?” in
BioClips+, Vol. 8, No 1, (MAPAQ: January 2005).
20
M. Laux, “Organic Food Trends Profile,” in Agricultural Marketing Resource Center (June 2006),
<http://www.agmrc.org/agmrc/markets/Food/organicfoodtrendsprofile.htm> (consulted on 21 September
2006).
21
Conseil des appellations agroalimentaire du Québec (CAAQ), “FAQ – Consommation,”
<http://www.caaq.org/faq/consommation.asp> (consulted on 21 September 2006).
22
H. Willer and M. Yussefi, The World of Organic Agriculture – Statistics and Emerging Trends – 2004
(International Federation of Organic Agriculture Movements: 2004), <http://orgprints.org/2555/>
23
Office de la protection du consommateur (OPC), “alimentation” in OPC Jeunesse – Libre service,
<http://www.opc.gouv.qc.ca/jeunesse/service/affiche.asp?page=savaistu_aliment&section=savaistu>
24
Agriculture and Agri-Food Canada (AAFC), Canadian Consumers, <http://www4.agr.gc.ca/AAFCAAC/dsplay-afficher.do?id=1170860293780&lang=e> (consulted on 20 September 2006).
page
11
between related species. This means, consequently, that GM crops are a threat to organic
farming. 25 GM crops and the patenting of genetically engineered seeds are increasing the
appropriation of the world’s genetic patrimony by multinationals and reducing farmers’
independence, as these practices enable multinationals to demand that farmers pay royalties on
seeds, year after year. Therefore, in general, due to the same concerns cited above with
respect to organic products, to which must be added concerns of an ethical and political nature,
consumers wish to see mandatory labelling for genetically modified organisms (GMOs). That
would enable them to exercise their right to choose to not consume foods produced via geneticengineering.26 Several opinion polls conducted over the last ten years clearly indicate that over
80% of Canadians wish to see Canada make such labelling mandatory.27
Many studies conducted in Russia, Switzerland, Japan and EU member countries, 28 confirm
that consumers in the entire world favour mandatory labelling of GMOs. In the United States, a
poll commissioned in April 2001 by the American affiliate of the Center for Science in the Public
lnterest (CSPI) revealed that some 62 to 70% of Americans also wish to see mandatory
labelling of GM foods.29 The same poll also showed that consumers would like to see labels
identifying other food production methods in certain instances where such labelling is not
presently mandatory. This is the case, for example, with food produced using pesticides (76%)
or plant hormones (65%).
Furthermore, more and consumers are turning towards the consumption of locally grown foods.
This trend reflects a variety of consumer concerns, including health, as well as social, cultural,
environmental, economic and political issues. Many initiatives demonstrate that communitybased food systems are beneficial for several reasons. By buying food locally, consumers are
able to eat fresh food produced in their region, lessen the use of preservatives, minimize the
long distance transportation of food (and thus reduce the production of greenhouse gases),
contribute to lessening problems connected with chronic hunger and promote rural development
by stimulating the regional economy. 30
In Canada, farmers’ markets are experiencing a tremendous boom in popularity. In Ontario, for
example, Mr. Robert Chorney, Director of Farmers’ Markets Ontario (FMO), reports that the
25
AK. Bock, et al, Scenarios for co-existence of genetically modified, conventional and organic crops in
European agriculture. This is a synthesis report done by the Institute for Prospective Technological
Studies of the European Commission’s Joint Research Centre (JRC). It bears on six studies
commissioned by the EU in May 2000 and conducted by different research institutes in France, the UK
and Germany. <http://www.jrc.cec.eu.int/download/GMCrops_coexistence.pdf> (consulted on 6 October
2006).
26
On this subject, several opinion polls are available on the website of the group OGM dangers:
<http://www.ogmdangers.org/enjeu/politique/sondage.htm> (consulted on 25 September 2006).
27
Greenpeace Canada sums up ten years of opinion surveys in Canada and Quebec on GMO labelling,
<http://www.greenpeace.org/canada/fr/documents-et-liens/documents/ogm-les-canadiens-et-canadien>
28
In this regard, 94.6% of Europeans—a record number—believe they have the right to choose whether
or not to buy genetically modified foods. See: Commission européenne – recherche européenne – l’info,
<http://ec.europa.eu/research/news-centre/fr/soc/02-03-soc06.html> (consulted on 25 September 2006).
29
Center for Science in the Public Interest (CSPI), National Opinion Poll on Labeling of Genetically
Engineered Foods, <http://www.cspinet.org/reports/op_poll_labeling.html> (consulted on 27 September
2006).
30
InterPares, Systèmes de sécurité alimentaires axés sur la communauté: des solutions locales pour
mettre fin à la faim chronique et promouvoir le développement rural,
<http://www.interpares.ca/fr/publications/pdf/systemes_securite_alimentaire.pdf> (consulted on 22
September 2006).
page
12
province’s 128 farmers’ markets are experiencing an annual growth rate of 5%. Mr. Chorney
adds that customers come to these markets for two main reasons: to buy fresh local produce
and to support farmers and local institutions. 31 Thus, according to an FMO study, 60 to 70% of
the people visiting these markets also visit small neighbouring businesses.32 In Quebec, Mr.
André Filteau, President of the Quebec Association of Public Markets (AMPQ), observes that
the number of visitors to the market in Montreal’s Old Port increased from 150,000 in 1996 to
about 700,000 in 2005. According to Mr. Filteau, public markets are more in sync with the
values of young people, whose leanings are “more pro-organic, pro-fair trade, anti-globalization
and pro-environment.”33 Farmers’ markets and public markets allow consumers to buy directly
from producers, thus cutting out the middlemen (processors and distributors), and that not only
allows consumers to pay reasonable prices for fresh staple foods, but also allows producers to
earn better profits on their products.
Supermarkets too are allocating more space on their shelves to local products in response to
demand. For example, in 2005, a popular supermarket chain launched an advertising campaign
with the slogan “Savourez le Québec” (“Savour Quebec”) to promote products from Quebec. 34
This chain even concluded an historic marketing agreement with la Fédération des producteurs
de pommes de terre du Québec (the Quebec Potato Growers Federation) which prioritized
Quebec suppliers in meeting the needs of consumers in Quebec. 35 André Turenne, Executive
Director of l’Association des jardiniers maraîchers du Québec (the Quebec Association of
Market Gardeners), states that, in season, the three biggest food chains in Quebec are mostly
supplied by Quebec producers.36
Furthermore, certain initiatives help to raise consumers’ interest in local consumption and food
self-sufficiency. The “achat local, toujours en tête” (“always remember to buy local”) public
education campaign in Quebec, jointly launched in June 2006 by Équiterre, l’Union des
producteurs agricoles (UPA) and la Fédération des coopératives d’alimentation du Québec, is
an example. 37 In April 2006, Quebec’s National Assembly adopted its Loi sur les appellations
réservées et les termes valorisants in order to develop regional food products. It should also
help sensitize consumers regarding the particular characteristics of locally produced foods.38
Local food systems are also gaining in popularity in other countries. Populations in the least
developed countries are constantly seeking to meet their food needs through local agriculture.
31
Comments gathered during a phone conversation with Mr. Robert T. Chorney, Secretary (ex officio),
Farmers’ Markets Ontario, on 22 September 2006.
32
Farmers’ Markets Ontario, “About us,” <http://www.farmersmarketsontario.com/about.php> (consulted
on 22 September 2006).
33
M. A. Soucy, “Marchés publics: bien plus que des commerces !”, La terre de chez nous, Vol. 77, No 21
(June 2006).
34
P. Vallée, “La table de ‘chez nous’ : Les grandes surfaces affichent les produits locaux,” Le Devoir,
September 21, 2005, p. D4.
35
J. Mercier, “Metro donne la priorité à la pomme de terre du Québec,” La terre de chez nous, Vol. 77, No
21 (June 2006).
36
Vallée, P. “La table de ‘chez nous’: Les grandes surfaces affichent les produits locaux,” Le Devoir,
September 21, 2005, p. D4.
37
M-A. Soucy, “Consommation solidaire : Campagne de sensibilisation à l’achat local,” La terre de chez
nous, Vol. 77, No 21 (June 2006).
38
Ministère de l’agriculture, des pêcheries et de l’alimentation du Québec (MAPAQ), “La Page du
MAPAQ,” <http://www.mapaq.gouv.qc.ca/NR/rdonlyres/AC9976BB-03FF-4249-B0DF55F62B23EE94/0/42069_MAPAQTCN_0405.pdf#search=%22place%20aux%20appellations%20r%C3%
A9serv%C3%A9es%20et%20aux%20termes%20valorisants%22> (consulted on 22 September 2006).
page
13
Even the World Health Organisation (WHO) and the Food and Agriculture Organisation (FAO) 39
realize that local food systems could be the solution for these countries, especially in light of the
devastation wrought by various free trade agreements on the local economies and domestic
agricultural production of developing countries. 40
Yet another consumer trend, which allows consumers to address some of their social,
economic, ethical and political concerns, is growing in popularity in Canada: fair trade food
products. In particular, fair trade contributes to economic development “by offering better
marketing conditions to marginalized producers, essentially in the countries of the Global South,
and by strengthening their rights. 41 According to the organization TransFair Canada (TFC), a
national non-profit organization engaged in certifying fair trade products and raising public
awareness around this issue, consumer awareness has risen appreciably in Canada, in recent
years. Since 2001, the sales in Canada of certified fair trade products has recorded an average
annual growth rate of 55%. 42
According to figures from the TFC, fair trade is also popular in the rest of the world. In May 2006,
there were 550 certified producers’ organizations, adhering to fair trade certification, in 51
producer countries in Africa, Latin America and Asia. TFC reports that in 2004, fair trade
certification generated revenues of approximately 100 million dollars (U.S.), an increase of 49%
over 2003, “demonstrating that for producers, industry and consumers Fair Trade is an attractive
w ay to make the world a better place.”43
In a speech pronounced at the European Parliament in June 2005, Ms. Carol Wills, Director of
the International Fair Trade Association, affirmed that the basin of consumers favourable to fair
trade in the world is immense and still growing: half of the population of England is now aware
of fair trade. Moreover, in 2004, the sales of fair trade products increased by 102% in France,
50% in Belgium and 60% in Italy.44 Fair trade is such a great success in Europe—60 to 70% of
world sales of fair trade products are in Europe—that the European Commission adopted a
resolution in July, stating:
“(...) whereas Fair Trade sales have been growing in Europe by on average 20% per
year since 2000, with more than one million producers and their families benefiting from
them and proving that European consumers are increasingly interested in responsible
purchasing; (...) the overall market share of Fair Trade is still small but is developing
rapidly, while international trends are similarly encouraging. 45
Through this resolution, which underlines the fact that “the most significant part of the increase
in Fair Trade sales has been achieved with respect to labelled products,” the European
39
Food Agriculture Organisation (FAO), 1. Food self-reliance of developing countries and trade-distorting
subsidies, <http://www.fao.org/docrep/005/y4852e/y4852e01.htm> (consulted on 22 September 2006).
40
B. Halweil, “ESSAY: The Rise of Food Democracy,” in UN Chronical Online Edition, No 1, (2005),
<http://www.un.org/Pubs/chronicle/2005/issue1/0105p71.html> (consulted on 22 September 2006).
41
Wikipédia, “Commerce équitable,” <http://fr.wikipedia.org/wiki/Commerce_%C3%A9quitable>
42
TransFair, Questions and Answers about Fair Trade, <http://www.transfair.ca/en/faq/> (consulted on
20 September 2006).
43
Ibid.
44
International Fair Trade Association (IFAT), General Info, Facts & Figures, Speeches, Presentations,
Workshops, <http://www.ifat.org/downloads/otherdownloads.shtml> (consulted on 22 September 2006).
45
European Parliament, Report on Fair Trade and Development, (2005/2245(INI)),
<http://www.europarl.europa.eu/omk/sipade3?OBJID=122170&L=EN&NAV=X&LSTDOC=N> (consulted
page
14
Parliament urged the European Commission “to take appropriate measures to ensure that
consumers have access to all the information they need in order to make informed choices” and
“liase with the international fair trade movement in supporting clear and widely applicable
criteria.”46
1.2
Consumers and labelling
Consumers’ existing and emerging concerns in relation to food and diet—convenience, health,
the environmental, and social, cultural, ethical and political issues—are thus reflected in a
certain number of consumer trends, such as foods and drinks that may be frozen or with added
functions or organic or non-genetically modified or locally produced or products of fair trade.
However, the capacity of consumers to purchase products meeting their needs and satisfying
their new requirements depends on appropriate product identification. Not that all of these
concerns entail the same type of labelling requirements. For example, a consumer looking for a
“convenience” food that only requires reheating in a microwave doesn’t need a label indicating
that the product is frozen since this kind of product is usually found in the frozen foods aisle of
the supermarket. On the other hand, a consumer that is socially and politically aware, who is
concerned about his health and the environment, who wishes to purchase a locally grown
organic food, will need specific information on the food’s packaging regarding its nutritional
value, its provenance, and the production and processing methods used.
To achieve this, consumers believe that the labels found on food products must communicate a
clear and precise message, which, furthermore, should be validated by a reliable and neutral
organization, subject to government oversight.47 Otherwise, consumers are left to their own
devices, adrift in a sea of symbols, logos and pictograms. These latter may serve to identify any
number of different products: from foods sold in biodegradable containers, to foods produced in
ways that respect the welfare of animals (e.g. without using antibiotics or growth hormones), to
niche products and 100% vegetarian products.
For example, in Canada, Local Flavour Plus, a non-profit organization based in Toronto that
works to foster the development of a sustainable food system, has developed a logo to
encourage consumers to consume foods that are produced locally and in a “socially
responsible” fashion, i.e. in accordance with principles and criteria that are respectful of the
environment and animal welfare.48
In British Columbia, a joint government-industry initiative in 1993 led to the adoption of a label
identifying food produced in the province. Today, the “Buy BC” logo is found on over 5,000
foods and is used by over 1,200 companies and associations for promotional purposes. This
logo has achieved a 75% recognition rate among the province‘s consumers. 49
46
European Commission, “Development Cooperation,” Bulletin EU 7/8-2006,
<http://europa.eu/bulletin/en/200607/p129001.htm> (consulted on 22 September 2006).
47
European Food Information Council (EUFIC), Consumer attitudes to nutrition information & food
labelling,
<http://www.eufic.org/web/genpdf.asp?cust=1&lng=en&type=F&url=%2Fweb%2Fpdfarticle%2Easp%3Fc
ust%3D1%26lng%3Den%26colour%3DD%26show%3DCONS%26expid%3D19> (consulted on 28
September 2006).
48
Local Flavour Plus, <http://www.localflavourplus.ca/> (consulted on 28 September 2006).
49
British Columbia Agriculture Council (BCAC), “About Buy BC,” <http://www.bcac.bc.ca/buybc/>
page
15
Also in British Columbia, The BC Society for the Prevention of Cruelty against Animals
(BCSPCA) has developed a program for the voluntary certification and identification of food
products based on five animal welfare criteria,50 initially published in the 1965 Brambell
Report.51 The Canadian Food Inspection Agency (CFIA), the federal agency responsible for the
enforcement of the Consumer Packaging and Labelling Act, has stated that it would like to
conduct broad public consultations before approving such labels.
Several other non-governmental labelling initiatives exist in other countries, including the United
States, Australia, New Zealand and several EU member countries. 52 Some of have become
popular with consumers. A notable example is the program in England set up in 1994 by the
Royal Society for the Prevention of Cruelty against Animals, under which the sale of eggs with
the label “Freedom Food” skyrocketed from 100,000 in 1994 to 80 million in 2000. 53
So-called “eco-label“ initiatives (“ecological,” “green,” etc.) are so numerous and based on so
many different criteria that several consumers’ associations have deemed it necessary to study
the issue in depth. One such association is the Institut national de la consommation (INC), an
information centre and thinktank for consumers and consumer associations. The INC published
its Guide du consommateur responsable (Guide for the Responsible Consumer) to help
European consumers obtain information on the different standards, labels and certifications
used by products and services adhering to a sustainable development perspective.54
Consumers International, an international organization which represents over 230 consumers’
associations from 113 countries, published a report on voluntary claims and “eco-labels” in July
2004. 55 This report, entitled Green Food Claims, aimed, in particular, to determine whether
consumers could really trust the different labels found on food packaging. It discovered that in
reality a large number of labels and logos were vague or without meaning, communicated
messages lacking in transparency, were not based on any defined standard and/or were not
subject to verification by a third party—which is essential to certification.
In effect, a label that, in theory, should help the consumer make informed and responsible
choices, may only truly achieve this objective if it is subject to standards or appropriate
oversight. Without the latter, such labelling is likely to resemble an exercise in marketing for the
50
British Columbia Society for the Prevention of Cruelty to Animals (BCSPCA), SPCA Certified
Standards, <http://www.spca.bc.ca/farm/standards.asp> (consulted on 27 September 2006).
51
This Report was published following an inquest commissioned by the British government in 1964. See
Wikipedia: <http://en.wikipedia.org/wiki/Animal_welfare> (consulted on 27 September 2006).
52
British Columbia Society for the Prevention of Cruelty to Animals (BCSPCA), “Humane Labelling
Programs in Other Countries,” <http://www.spca.bc.ca/farminfo/world.asp> (consulted on 28 September
2006).
53
D. McCue, “Do you know where your food comes from?” Canadian Broadcasting Corporation (CBC),
February 13, 2001, <http://www.cbc.ca/consumers/market/files/food/humanelabels/index.html>
54
Institut national de la consommation (INC), Le guide du consommateur responsable,
<http://www.conso.net/page/bases.1_pour_comprendre_agir.5_dossiers.8_le_guide_du_consommateur_
responsable./Item-itm_ccc_admin_20050627133819_133819_Leguideduconsommateurresp.txt>
55
Consumers International (CI), Green Food Claims - A Comparative Survey,
<http://www.consumersinternational.org/Templates/Internal.asp?NodeID=90907&int1stParentNodeID=89
652&int2ndParentNodeID=89792&int3rdParentNodeID=89704&int4thParentNodeID=89704&int5thParent
NodeID=89704&int6thParentNodeID=89704&int7thParentNodeID=89704&int8thParentNodeID=89704&st
rSubSite=1&strLHSMenu=89652> (consulted on 28 September 2006).
page
16
benefit of companies which may, in the absence of a rigorous certification and verification
process, be tempted to market an “eco-label” liable to mislead consumers, undermine their trust
and slow the progress towards responsible and sustainable food production and consumption.
page
17
2.
REVIEW OF THE CODEX ALIMENTARIUS COMMISSION’S STANDARDS
AND GUIDELINES ON THE LABELLING OF PREPACKAGED FOODS
The Codex Alimentarius Commission was created in 1963 by two UN agencies, the Food and
Agriculture Organisation (FAO) and the World Health Organisation (WHO), “to develop food
standards, guidelines and related texts such as codes of practice under the Joint FAO/WHO
Food Standards Programme.” The Codex’s main mission is to implement this Program in order
to protect consumers’ health and to promote fair practices in the food industry. 56 The
Commission is responsible for coordinating all standardization efforts in relation to food, whether
such are undertaken by governmental organizations or others.
The standards and guidelines of the Codex Alimentarius Commission do not have force of law.
Their main purpose is to orient the policies of UN member states in such a manner as to
promote the elaboration and establishment of definitions and requirements concerning
foodstuffs and to facilitate international trade, via the harmonization of said definitions and
requirements. In this perspective, “food labelling is the primary means of communication
between the producer and seller of food on the one hand, and the purchaser and consumer on
the other.”57
2.1
General Standard for the Labelling of Prepackaged Foods
The General Standard for Labelling Prepackaged Foods, which was adopted in 1981 and
subsequently revised in 1985, 1991, 1999, 2001, 2003 and 2005, applies to the labelling of all
prepackaged foods offered to consumers or for catering purposes, as well as certain aspects
relating to the presentation thereof.
As a general principle, the Standard stipulates that “a prepackaged food shall not be described
or presented on any label or any labelling in a manner that is false, misleading or deceptive or is
likely to create an erroneous impression regarding its character in any respect.”58 Furthermore,
labels or labelling must not use “words, pictorials or other devices which refer to or are
suggestive, either directly or indirectly, of any other product with which such food might be
confused, or in such a manner as to lead the purchaser or consumer to suppose that the food is
connected with such other product.”
56
Codex Alimentarius, “Welcome,” <http://www.codexalimentarius.net/web/index_en.jsp> (consulted on
29 September 2006).
57
The Codex Alimentarius Commission, The Codex Alimentarius Commission and FAO/WHO Food
Standards Programme – Food Labelling - Complete Texts,
ftp://ftp.fao.org/codex/Publications/Booklets/Labelling/foodlabelling_2005e.pdf> (consulted on 29
September 2006).
58
Codex Alimentarius, General Standard for the Labelling of Prepackaged Foods,
<http://www.codexalimentarius.net/download/standards/32/CXS_001e.pdf> (consulted on 29 September
2006).
page
18
2.1.1 Mandatory labelling particulars
2.1.1.1 Name of the food
According to the Codex, certain information is mandatory on the labelling of prepackaged foods,
unless otherwise expressly provided in an individual Codex standard. The name shall indicate
the true nature of the food and normally be specific and not generic.
Where a name or names have been established for a food in a Codex standard, at least one of
these shall be used. In other cases, the name prescribed by national legislation shall be used. In
the absence of any such name, either a common or usual name existing by common usage as
an appropriate descriptive term shall be used—the latter may include a “coined,” “fanciful,”
“brand” name or “trade mark,” provided that the utilization of these names does not contravene
national legislation and that it does not mislead consumers.
There shall appear on the label, either in conjunction with or in close proximity to the name of
the food, clear wording—to avoid misleading the consumer—as regards the true nature and
physical condition of the food, as well as the treatment it has undergone (e.g. concentrated,
reconstituted, dried, smoked).
2.1.1.2 List of ingredients
The labels of foods composed of more than one ingredient must also include a complete list of
ingredients, listed in descending order of initial weight at the time of the food’s manufacture.
Where an ingredient is itself the product of two or more ingredients, it may be declared in the list
of ingredients, provided that it is immediately accompanied by a list, in brackets, of its
ingredients, in descending order of proportion. Where a compound ingredient, for which a name
has been established in a Codex standard or in national legislation, constitutes less than 5% of
the food, it need not be declared, except in the case of food additives 59 which serve a
technological function in the final product (e.g. taste enhancers).
The presence of allergens from the following ingredients or foods—including those obtained
using biotechnologies—shall be declared in the list of ingredients: cereals containing gluten;
crustaceans, and products of these; fish and fish products; eggs and egg products; peanuts,
soybeans and products of these; milk and milk products; tree nuts and nut products; and
sulphite in concentrations of 10 mg/kg or more. When it is not possible to provide adequate
information on the presence of an allergen through labelling, the food containing the allergen
shall not be marketed.
As is the case with the product name (see the preceding section), if a name exists that has been
specified by a specific Codex standard or by national legislation, the ingredient shall, barring
exceptions, use this specific name. In the case of food additives figuring in Codex food additives
lists, the relevant class title (e.g. acidity regulators, gelling agents, emulsifiers, sweeteners, etc.),
59
According to the Codex General Standard for the Labelling of Food Additives when Sold as Such,
adopted in 1981, “food additive means any substance not normally consumed as a food by itself and not
normally used as a typical ingredient of the food (...) the intentional addition of which to food for a
technological (including organoleptic) purpose (...) may be reasonably be expected to result in it or its byproducts becoming a component of or otherwise affecting the characteristics of such foods.”
<http://www.codexalimentarius.net/download/standards/2/CXS_107e.pdf> (consulted on 2 October 2006).
page
19
of the ingredient or constituent shall appear beside its specific name or recognized numerical
identification, as required by national legislation. A food additive shall be declared in the list of
ingredients only if it is carried over into the food in a large and/or sufficient quantity to perform a
technological function in the food
Moreover, the initial quantity (as a percentage) of one or more ingredients, at the time of
manufacture, shall be indicated on the labelling when the latter or the food’s designation 1)
places special emphasis on said ingredient(s) or 2) places special emphasis of the food’s low
content in said ingredient(s).
“A reference in the name of a food to a particular ingredient shall not of itself constitute
the placing of special emphasis. A reference in the labelling of a food to an ingredient
used in a small quantity and only as a flavouring shall not of itself constitute the placing
of special emphasis”.60
2.1.1.3 Net contents and drained weight
The quantity of the food at the time of its packaging (net contents) shall be declared in the
metric system: for liquid foods by volume; for solid foods by weight; for semi-solid or viscous
foods either by volume or weight. If a food is packaged in a liquid medium, the label shall
declare the drained weight of the food.
2.1.1.4 Name and address
The label shall declare the name and address of the manufacturer, packer, vendor, distributor,
importer or exporter of the food.
2.1.1.5 Country of origin
The country of origin of the food shall be declared if its omission would mislead or deceive the
consumer. When a food undergoes processing in a second country that changes its nature, the
latter country shall be considered to be the country of origin for the purposes of labelling.
2.1.1.6 Lot identification
The producing factory and lot shall be clearly indicated on each container via an indelible code.
2.1.1.7 Date marking, storage instructions and instructions for use
Unless otherwise specified in an individual Codex standard, the food’s “date of minimum
durability” shall be declared on the label. This declaration shall consist of the day and the month
for products of a minimum durability of not more than three months, and the month and year for
products of a minimum durability of more than three months. The date of minimum durability is
not, however, required for certain foods: fresh fruit and vegetables, wines and other spirits,
including beverages with an alcohol content of at least 10% (in volume), bakery products and
pastries, vinegar, salt and sugar (in solid form), sweets and chewing gum.
60
Op.cit. 59.
page
20
If the food’s durability depends on any special conditions for its storage, these conditions must
be indicated on the label. Similarly, instructions shall be included on the label if this is required
to ensure correct utilization of the food.
2.1.1.8 Irradiated foods or ingredients
The label of any food or ingredient which has been treated with ionizing radiation shall carry a
written statement indicating that treatment, in close proximity to the name of the food, when the
food has been so treated in its entirety, or in the list of ingredients, when an ingredient has been
irradiated. The use of the international food irradiation symbol (the Radura logo) is optional, but
when it is used, it shall be in close proximity to the name of the food.
2.2
Guidelines on Nutrition Labelling
The Guidelines on nutrition labelling establish recommended procedures to ensure, notably, that
the consumer is provided with information about a food such that he may make an informed
choice and to offer the manufacturer the means to convey information on the food’s nutritional
properties. Of course, nutrition labelling must not describe a product or present information
about it which is false, misleading or deceptive. In addition, any nutritional claim must be
supported by a declaration on the nutrients contained in the food. Nutrition labelling consists of
two components: the nutrient declaration61 and the declaration of supplementary nutritional
information.
The nutrient declaration is optional, unless a nutrition claim or claims are made about the food,
i.e. “any representation which states, suggests or implies that a food has particular nutritional
properties.”62 In cases where such claims are stated on the label, the label’s nutrient declaration
becomes mandatory.
The guidelines also establish the nutrient reference values that should be utilized for the
presentation of nutrient content and for labelling purposes.
Supplementary nutritional information may be provided to facilitate the consumer’s
understanding and interpretation of the nutritional value and nutrient declarations of the foods
he consumes. Such supplementary nutritional information, which may take the form of symbols,
pictures or colours, should be instructive and complement, rather than replace, the declaration
of nutritional contents.
61
According to the definition in the Codex Alimentarius Guidelines on Nutrition Labelling, a nutrient
normally means “any substance normally consumed as a constituent of food: a) which provides energy;
b) which is needed for growth, development and maintenance of life; or c) a deficit of which will cause
characteristic biochemical or physiological changes to occur.”
<http://www.codexalimentarius.net/download/standards/34/CXG_002e.pdf> (consulted on 4 October
2006).
62
Ibid.
page
21
2.3
General Guidelines on Claims
In general a claim is “any representation which states, suggests or implies that a food has
particular characteristics related to its origin, nutritional properties, nature, production,
processing, composition or any other quality.”63
Any person who markets a food about which a claim is made must be capable of justifying said
claim. For example, one may indicate that a food has acquired particular nutritional qualities
through, the addition, omission or reduction of nutrients “provided that this addition was done on
the basis of nutritional considerations consistent with the ‘General Principles for the Addition of
Essential Nutrients to Foods.’”64 These Principles provide orientation to persons in charge of
elaborating guidelines in order, notably, to prevent practices apt to mislead the consumer, to
maintain or improve the nutritional quality of foods and to reduce health risks due to deficiencies
or the unbalanced intake in essential nutrients, which may result from the “arbitrary” addition of
said nutrients.
One may also indicate that a food is “natural,” “pure,” “fresh,” “home-made” and organically
grown,” provided that these expressions are used in accordance with the national practices of
the country where the food is sold. These claims must, however, be well-founded and must not
“give rise to doubt about the safety of similar food or which could arouse or exploit fear in the
consumer.”65
2.4
Guidelines for using nutrition and health claims
The object of these guidelines is to complement the general guidelines on claims (see section
2.3). They concern the use of nutrition and health related claims in all food labelling. Nutrition
claims should only be authorized where a nutritional reference value has been established in
the Codex Guidelines on Nutrition Labelling. 66 There are two types of nutrition claims:
• Claims in relation to the nutrient content, which describe the quantity of a nutrient contained
in a food (e.g. “a source of calcium” and “low in fat”; and
• Comparative claims on nutrients, which compare the energy value and/or the nutrient
contents of two or more foods (e.g. “more than” and “low in”).
The Guidelines for the Use of Nutrition and Health Claims summarize in a chart the conditions
to be respected in the case of claims on nutrient content and comparative claims on nutrients.
For example, foods that are subject to comparison should be different versions of the same food
or similar foods, that are easily identifiable by consumers, and, finally, the quantitative difference
in their nutrient content should be indicates. Furthermore, the comparison should be based on a
relative difference of at least 25% in terms of nutrient content or energy value—except in the
case of vitamins and mineral salts, for which a relative difference of at least 10% of the
nutritional reference value may justify the making of a claim.
63
Codex Alimentarius, Codex General Guidelines on Claims, (CAC/GL 1-1979),
2006).
64
Codex Alimentarius, General Principles for the Addition of Essential Nutrients to Foods, (CAC/GL 091987), <http://www.codexalimentarius.net/download/standards/299/CXG_009e.pdf> (consulted on 4
October 2006).
65
Op.cit. 64
66
Op.cit. 62.
page
22
As for health claims, 67 three different types are possible:
• Functional claims, which describe the nutrient’s role in the body’s growth or development as
well as normal functions (e.g. “Nutrient ‘x’ plays physiological role ‘y’.” “Food ‘a’ is a source
of nutrient ‘x’.”);
• Other functional claims, which concern the positive contribution of the consumption of foods
or their constituents, in the context of one’s overall diet, on health or the improvement of a
physiological function (e.g. “Substance ‘x’ has effect ‘y’ on health.” “Food ‘a’ contains ‘n’
grams of substance ‘x’.”); and
• Claims re the reduction of the risk of illness, in the context of one’s overall diet (e.g. “A diet
rich in substance ‘x’ may reduce the risk of disease ‘y’.” “Food ‘a’ is rich in substance ‘x’.”).
Thus, in the context of an overall diet, it is permitted to state that a food contains a given
quantity of a nutrient and that the latter has one or more beneficial effects on the physiological
functions or health of an individual, but it is not permitted to directly attribute the beneficial
effects to the food itself.
Nutrition and health claims must be consistent with national nutrition policies. Furthermore,
health claims should “health claims should be supported by a sound and sufficient body of
scientific evidence to substantiate the claim, provide truthful and non-misleading information to
aid consumers in choosing healthful diets and be supported by specific consumer education.” 68
When new scientific information becomes available, the scientific justification on which a health
claim is founded should be re-examined. Functional claims should only be made for those
essential nutrients for which a nutritional reference value has been established in the Codex
Guidelines on nutrition labelling or for nutrients mentioned in national nutrition policies. Health
claims should be regulated by member countries such that the admissibility and nonadmissibility criteria for any particular claim are clear.
The labelling of the food for which a health claim is made must mention the quantity of the
relevant nutrient or constituent and specify its target group, if need be. Furthermore, the label
must specify how the food is to be utilized to obtain the alleged benefit, advise which vulnerable
groups should avoid this food and affirm the importance of maintaining a balanced diet.
Moreover, a health claim should not encourage excessive consumption of any food whatsoever,
nor should it disparage good dietary habits.
2.5
Guidelines on the labelling of organically produced foods
The Codex Guidelines on the production, processing, labelling and marketing of organically
produced foods, last amended in 2004, constitute a first step in the harmonization of
international regulations in relation to organic products, notably regarding the identification of
these products and their labelling requirements. These guidelines, which seek to protect
consumers “against fraud and deception in the marketplace and against unsubstantiated claims”
re organic foods, are intended to help countries to elaborate their own regulations. Of course
they “do not prejudice the implementation of more restrictive arrangements and more detailed
67
The Guidelines for the Use of Nutrition and Health Claims defines a health claim as “any representation
that states, suggest or implies that a relationship exists between a food or a constituent of that food and
health.” Codex Alimentarius, Guidelines for the Use of Nutrition and Health Claims, (CAC/GL 23-1997).
<http://www.codexalimentarius.net/download/standards/351/CXG_023f.pdf> (consulted on 9 October
2006).
68
Op.cit. 68.
page
23
rules by member countries” as regards labelling, or the application of “such rules to products
from other countries on the basis of equivalency to these more restrictive provisions.”69
The Codex Guidelines on the production, processing, labelling and marketing of organically
produced foods apply to plants, plant products and derivatives, livestock, non-processed
livestock products and derivatives, as well as the processed products of crops and livestock
intended for human consumption. These guidelines utilize terms such as “organic” and
“ecological” in an endeavour to more clearly define the production and processing system of
organic products. “Organic” labelling refers to products produced in a manner that respects
standards of organic production. Therefore, the utilization of terms suggesting the use of such
production methods must consequently be restricted to products from operations subject to
monitoring on the part of a qualified organization or a duly constituted official inspection and
certification authority.
In general, the labelling of organic products should conform to the provisions of the Codex’s
General Standard for Labelling Prepackaged Foods (see section 2.1). However, organically
farmed foods have different labelling requirements from those applicable to other farm products
as “requirements for organically produced foods differ from those for other agricultural products
in that production procedures are an intrinsic part of the identification and labelling of, and
claims for, such products.”70
“A product will be considered as bearing indications referring to organic production
methods where, in the labelling or claims (...) the product, or its ingredients, is described
by the terms “organic,” “biodynamic,” “biological,” “ecological” or words of similar intent
including diminutives, which in the country where the product is placed in the market,
suggests to the purchaser that the product or its ingredients were obtained according to
organic production methods.”71
The labelling and claims re a non-processed organic product may refer to organic production
methods only where:
• Such indications show clearly that they refer to a method of agricultural production;
• The product was produced in accordance with the rules of production and preparation, and
the importing requirements described in the guidelines;
• The product was produced or imported by an operator who is subject to the inspection and
certification procedures specified in the guidelines; and
• The labelling refers to the name and/or code number of the officially recognized inspection
or certification body to which the operator is subject.
The labelling and claims re a processed organic product may refer to organic production
methods only where:
• Such indications show clearly that they refer to a method of agricultural production and are
linked with the name of the agricultural product in question, unless such indication is clearly
given in the list of ingredients;
69
Codex Alimentarius, Guidelines for the Production, Processing, Labelling and Marketing of Organically
Produced Foods, (GL 32-1999),
2006).
70
Ibid.
71
Ibid.
page
24
•
•
•
•
•
All of the product’s ingredients of agricultural origin were obtained in accordance with the
rules of production and preparation, and the importing requirements described in the
guidelines; 72
The product does not contain any ingredients of non-agricultural origin that are nonauthorized for the production of organic foods 73 and that these same ingredients are not
derived from both an organic and a non-organic origin;
The product or its ingredients have not been subjected, during preparation, to treatments
involving the use of ionizing radiation or processing aids whose utilization is not permitted in
the preparation of organic products;74
The product was produced or imported by an operator who is subject to the inspection and
certification procedures specified in the guidelines; and
The labelling refers to the name and/or code number of the officially recognized inspection
or certification body to which the operator is subject.
Furthermore, products of farms in transition towards organic production methods may be
labelled as “in transition to organic” or “under conversion towards organic farming”75 after twelve
months of production using organic methods and providing that the above-mentioned points are
respected. The mentioning of such a transition period must not mislead the consumer regarding
its different nature in comparison with “products obtained from farms and/or farm units which
have fully completed the conversion period.”76
2.6
Labelling of genetically modified (GM) foods
For the past eight years, the Codex Committee on Food Labelling (CCFL) has been trying to
develop standards and guidelines on the labelling of foods produced using genetic engineering
techniques. The CCFL, which meets annually, has in fact produced a draft of possible standards
supported by the majority of member countries, including the 25 countries of the European
Union, Brazil and a number of countries from Asia and Africa, Japan, Thailand, India, Indonesia,
Morocco and Ghana among them. 77 However, in accordance with the Codex process, the
adoption of standards and/or guidelines requires the unanimous or quasi-unanimous consent of
participants. The delicate question of genetically modified (GM) foods, constitutes a major
challenge, due in particular to the major economic issues at stake and the sustained opposition
of a few countries, including Canada, the United States and Argentina, all of which are major
producers of genetically modified organisms.
72
Certain ingredients of agricultural origin not satisfying requirements may however be used in the final
product, up to a maximum of 5% of the total weight of all ingredients, not including salt and water.
73
See Table 3 of Annex 2 of the Guidelines for the Production, Processing, Labelling and Marketing of
Organically Produced Foods, (GL 32-1999). Op.cit. 70.
74
See Table 4 of Annex 2 of the Guidelines for the Production, Processing, Labelling and Marketing of
Organically Produced Foods (GL 32-1999). Op.cit. 70.
75
Any other similar wording is acceptable, provided that it is approved by the competent authorities of the
country where the product is marketed and that it is written in a colour and a font size equal to that used
for the product’s name.
76
Op.cit. 70.
77
Consumers International, “UN food standards body to address GMO labelling,” press release, Ottawa,
3 May 2006,
<http://www.consumersinternational.org/Templates/News.asp?NodeID=92710&int1stParentNodeID=8965
0&int2ndParentNodeID=89677> (consulted on 11 October 2006).
page
25
Confronted with this impasse, the participants—representatives from over sixty countries—
agreed at the most recent meeting, held in Ottawa, in May 2006, to form a working group
mandated to study the question and propose a text for CCFL’s 35th session, which will also take
place in Ottawa, from 30 April to 4 May 2007. In the meantime, the working group is scheduled
to meet in January 2007 in Oslo, Norway, to prepare a working document, based on the
experience of the over forty countries that have already enacted mandatory labelling of GM
foods. 78
2.7
Labelling of foods that respect fair trade principles
There are Codex principles and guidelines applicable to the design, application, evaluation and
certification of systems for the inspection and certification of food imports and exports. Codex
guidelines also exist on food importation control systems, which aim “to protect consumers and
facilitate fair practices in food trade while ensuring unjustified technical barriers to trade are not
introduced.”79 However, there are no Codex standards or guidelines on the labelling of foods
that respect fair trade principles.
The Codex Alimentarius Commission’ Code of Ethics on international trade in food products is
based on the Codex General Standard for the labelling of prepackaged foods (section 2.1). 80
2.8
Summary
“The Codex Alimentarius, or the food code, has become the global reference point for
consumers, food producers and processors, national food control agencies and the
international food trade. (…) Its influence extends to every continent, and its contribution
to the protection of public health and fair practices in the food trade is immeasurable.
The Codex Alimentarius system presents a unique opportunity for all countries to join the
international community in formulating and harmonizing food standards and ensuring
their global implementation.”81
The importance of the Codex Alimentarius in the standardization and harmonization of rules
governing the agrifood sector and its influence on the regulation of this sector by the regulatory
authorities of member countries, including Canada, are beyond doubt. In effect, since 2005,
member countries represent 98% of the world’s population. This is why we elaborated our food
regulation analysis grid based on Codex food labelling standards. This analysis grid was used to
effect our comparative study of regulation of the agrifood sector in Canada.
78
Ibid.
Codex Alimentarius, Guidelines for Food Import Control Systems, (CAC/GL 47-2003),
2006).
80
Codex Alimentarius, Code of Ethics for International Trade in Food, (CAC/RCP 20-1979),
<http://www.codexalimentarius.net/download/standards/1/CXP_020e.pdf> (consulted on 11 October
2006).
81
World Health Organisation and Food and Agriculture Organisation of the United Nations,
Understanding the Codex Alimentarius, Preface,
<http://www.fao.org/docrep/008/y7867e/y7867e00.htm> (consulted on 29 September 2006).
79
page
26
For comparison purposes, we also examined food regulation in certain other countries. Aside
from linguistic and accessibility considerations, the countries selected for this study (the U.S.,
the countries of the EU and Australia/New Zealand) reflect the fact that 95 to 97% of consumers
of organic foods reside in North America and Europe (note 21). Moreover, a certain number of
labelling programs of interest have been instituted in Australia, New Zealand, the United States
and the European Union (note 53).
The various standards and guidelines of the Codex Alimentarius on food labelling will therefore
serve as the basis for our review of the regulatory frameworks presently in force in Canada, the
U.S., certain countries in the European Union and Australia and New Zealand. We used the
Codex standards and guidelines as reference points to develop the analysis grids that
subsequently served as tools in our examination of the regulatory provisions in these countries.
These standards were allocated as a function of the different categories of consumer concerns
that may be influenced by various types of labelling information: 1) convenience, 2) nutrition and
health, and 3) a variety of other concerns (health, the environment and other issues of a social,
cultural, ethical and political character). 82
Labelling particulars were shared between these three categories as follows:
1. Convenience related concerns: product name, list of ingredients, minimum durability,
directions for use, net content/drained weight, name and address.
2. Nutrition and health concerns: energy value, list of ingredients, nutrition facts table,
declaration of allergenic ingredients, nutrition claims and health-related claims.
3. Various concerns: country of origin, organically farmed foods, genetically modified foods,
irradiated foods and ingredients, fair trade foods, claims related to livestock production
methods, other logos and claims (e.g. “fresh,” “100% pure,” “natural,” “authentic,” “homemade,” etc.).
82
Table 1, on page 57, compares food labelling regulations as a function of consumers’ “convenience”
related concerns. Table 2, on page 58, food labelling regulations as a function of consumers’ nutrition and
health concerns And, finally, Table 3 on page 59 compares regulations as a function of diverse consumer
concerns (health issues, the environment, and social, cultural, ethical, political issues).
page
27
3.
REVIEW OF
LABELLING
EXISTING
REGULATORY
FRAMEWORKS
ON
FOOD
This section is concerned with the national regulations covering all forms of food labelling in
Canada, the United States, the European Union, Australia and New Zealand. The United States
was a must because it is Canada’s main trade partner in the agrifood sector and because its
policies influence Canada’s. The European Union as well was a must because it’s one of the
most important players on the international level and because its policies are often described as
the most advanced and the strictest, and as such have an undeniable influence on international
food exports and imports. Finally, Australia and New Zealand were selected because, as was
discovered during our preliminary documentary research, these jurisdictions were likely to
present certain recently adopted labelling policies apt to be of interest for comparison purposes.
For practical reasons, these jurisdictions were also chosen because it would be easy to review
their policies in French or English and because the principal documents were available on the
Internet.
The examination of these regulatory frameworks will be enriched by a comparative analyse
articulated around the Codex Alimentarius standards and guidelines. This information will be
summarized in three tables at the end of this section.
3.1
Canada
Under the provisions of the Food and Drugs Act (R.S, 1985, c. F-27), 83 two Ministries share the
responsibility of elaborating and enforcing Canadian food labelling requirements: Health Canada
and Agriculture and Agri-Food Canada, the latter through the agency of the Canadian Food
Inspection Agency (CFIA). 84 To be more specific, Health Canada is responsible for elaborating
nutritional standards and policies and the CFIA is responsible for seeing to their application.
The laws pertaining to food labelling in Canada are: the Food and Drugs Act (FDA), which
stipulates the rules applicable to the labelling of all prepackaged foods imported into or sold in
Canada, the Consumer Packaging and Labelling Act (CPLA) (R.S, 1985, c. C-38), 85 which aims,
notably, to ensure the uniformity of food labelling methods and to prevent misleading statements
and fraud in labelling.
On January 1st 2003, in Part II of the Canada Gazette, Health Canada published its new
requirements governing nutrition labelling. In addition to making nutrition labelling mandatory for
most prepackaged foods sold in Canada, these modifications to the Food and Drugs
83
Department of Justice Canada, Food and Drugs Act (R.S., 1985, c. F-27),
<http://lois.justice.gc.ca/en/showdtm/F-27/index.html> (consulted on 12 October 2006).
84
The Canadian Food Inspection Agency (CFIA) is an agency of Agriculture and Agri-Food Canada
(AAFC).
85
Department of Justice Canada, Consumer Packaging and Labelling Act (R.S., 1985, c. C-38),
<http://lois.justice.gc.ca/en/showtdm/cs/c-38/index.html> (consulted on 12 October 2006).
page
28
Regulations (FDR) (C.R.C., ch. 870), 86 introduced the regulation of a certain number of nutrient
content and health claims.87
Food labelling in Canada has three objectives:
• To provide basic information on the food product (list of ingredients, country of origin, etc.);
• To provide health and nutrition information on the food (fat content, vitamins, etc.); and
• To serve as a marketing, promotional and advertising tool via, notably, promotional
information and claims (“low-fat,” “natural,” etc.).88
3.1.1 General requirements concerning the labelling of prepackaged foods
Let’s first note that the requirements imposed on the labelling of prepackaged foods sold in
Canada are generally consistent with Codex Alimentarius standards and guidelines. This report
will therefore highlight the differences between national regulations and the Codex standards
and guidelines.
As a general rule, all prepackaged foods in Canada must bear an easily discernible label that
may appear on any side of the container (except the bottom)—unless such information is
required on the packaging's principal display surface—and must display certain mandatory
information.89
3.1.1.1 Common Name
The common name of a food, i.e. the name prescribed by the Food and Drug Regulations
(FDR) or by any other federal regulation, (e.g. “orange juice from concentrate” or “mixed
vegetables”) must appear on the principal display surface of the food’s packaging. If the food’s
name is not prescribed by regulation, the food must bear the name by which it is usually known
(e.g. “chocolate cake,” “vanilla cookies,” etc.).
The food’s common name must not be misleading. Nor may it incorporate words unwarranted
by the composition of the food, improperly suggest a place of origin, suggest improbable
advantages or results, or resemble the name of another product for which it is an imitation or
substitute.
86
Department of Justice Canada, Food and Drug Regulations (C.R.C., c. 870)
<http://lois.justice.gc.ca/en/showtdm/F-27/C.R.C.-c.870.html> (consulted on 12 October 2006).
87
Canada Gazette, Regulations Amending the Food and Drug Regulations (Nutrition Labelling, Nutrient
Content Claims and Health Claims), Vol. 137, No 1, 1 January 2003,
<http://canadagazette.gc.ca/partII/2003/20030101/html/sor11-e.html> (consulted on 12 October 2006).
88
Canadian Food Inspection Agency (CFIA), Guide to Food Labelling and Advertising 2003, Chapter 1 –
1.4 Purpose of Food Labelling, <http://www.inspection.gc.ca/english/fssa/labeti/guide/ch1e.shtml - 1.4>
89
All mandatory information on food labels must be shown in both official languages, i.e., French and
English, with the following exceptions, which may be in one official language only: The identity and
principal place of business of the person by or for whom the pre-packaged product was manufactured,
processed, produced or packaged for resale; Local products sold in a local area in which one of the
official languages is the mother tongue of less than 10 percent of the residents; Official test market
products; and Specialty foods, as defined by the Food and Drug Regulations. Canadian Food Inspection
Agency (CFIA), Guide to Food Labelling and Advertising 2003, Chapter 2 – 2.4 Bilingual Requirements
[B.01.012, B.01.054; 6,CPLR]], <http://www.inspection.gc.ca/english/fssa/labeti/guide/ch2e.shtml - 2.4>
page
29
3.1.1.2 Net Quantity
The net quantity must be declared in metric units on the principal display panel of prepackaged
foods, by volume for liquid foods, by weight for solid foods and by count for certain other foods.
3.1.1.3 Name and Address
The name and address which must appear on the food’s packaging are those of the person or
establishment who manufactured or produced the food, or of the person or establishment for
whom the food was manufactured or produced. If the prepackaged product was entirely
produced or made outside of Canada and the name and address of the person or establishment
appearing on the food’s label are those of a Canadian vendor, the expression “importé
par/imported by” or “importé pour/imported for” must appear before the vendor’s name and
address (unless the product’s origin is specified beside the vendor’s name and address). 90 The
latter is not a requirement of the Codex standards and guidelines (see section 2.1.1.4).
3.1.1.4 Durable Life Date
The durable life of a food is the period that the food will retain its normal wholesomeness,
palatability and nutritional value, when it is stored under appropriate conditions. The durable life
date must be displayed—year, month and day—on the label of prepackaged foods for which the
durable life is 90 days or less. This requirement does not, however, apply to the following
prepackaged foods: fresh fruits and vegetables, doughnuts, individual portions or snacks served
with meals by a restaurant, airline, etc., individual portions sold by vending machines or catering
trucks.91 Unlike the Codex standards and guidelines (see section 2.1.1.7.), Canadian
regulations do not require directions for ensuring a food’s proper utilization.
3.1.1.5 List of Ingredients
With the exception of certain prepackaged products 92 specified by the Food and Drug
Regulations, prepackaged foods containing more than one ingredient must have a list of
ingredients, which shall be listed in descending order according to their weight before their use
in the manufacture of the food.
Constituents—i.e. the ingredients of ingredients, such as salt, aspartame, hydrolyzed plant
protein or any other constituent which serves a function in the food or has an effect on it (e.g.
taste enhancers)—must also appear in the list of ingredients, either in brackets after the name
of the ingredient in which they are contained, or in descending order by weight in the end food
90
2.7 Name and Address [B.01.007; 10, CPLA; 31, CPLR],
<http://www.inspection.gc.ca/english/fssa/labeti/guide/ch2e.shtml - 2.7> (consulted on 12 October 2006).
91
Ibid. Chapter 2 – 2.11 Durable Life Date [B.01.007].
<http://www.inspection.gc.ca/english/fssa/labeti/guide/ch2ae.shtml - 2.11> (consulted on 12 October
2006).
92
A list of these exceptions is given in the Guide to Food Labelling and Advertising 2003 in Chapter 2 –
2.8 List of Ingredients [B.01.008, B.01.010],
page
30
product. 93 The common names of ingredients and constituents, when specified by the Food and
Drug Regulations, are the ones that must be used in food labelling. 94 Canadian labelling
requirements with respect to constituents differ from the Codex standards and guidelines in that
the latter only require a declaration of ingredients (see section 2.1.1.2.).
Concerning the labelling requirements for food ingredients or constituents liable to cause
allergies, there are provisions in Canadian regulations that permit exemptions in the list of
ingredients, notably certain ingredient and constituents used in the manufacture of food
products, such as flavouring, seasoning, spices and vinegar. However, some of these
ingredients or constituents are known to “cause life-threatening or severe adverse reactions in
individuals with food sensitivities.”95 These regulatory provisions are inferior to the provisions of
the Codex standards and guidelines, which require the declaration of a complete list of foods
and ingredients (including food additives) known to provoke allergic reactions (see section
2.1.1.2.). 96
Moreover, it is deemed misleading to unduly emphasize the importance, presence or absence
of an ingredient or a substance due to its desirable or undesirable qualities or for any other
reason. Any special emphasis on an ingredient, constituent or substance should be
accompanied by a statement of its quantity in the list of ingredients. Moreover, a food label
should not highlight the presence of nutrients or substances contained in the food as a trace
quantity or in tiny quantities. 97
3.1.1.6 Labelling of irradiated foods or ingredients
Domestic and imported foods sold in Canada which have undergone irradiation treatment must
bear on the label the word(s) “irradiated,” “irradiation treated,” “radiation treated” or words with
the same meaning. Furthermore, they must display the internationally recognized “Radura” food
irradiation symbol. Only those irradiate ingredients which constitute over 10% of the food must
be identified as “irradiated in the list of ingredients.98 That, in fact, could allow the presence in
the food of an unlimited number of irradiated ingredients, without these ingredients or the
93
Certain foods, mixes and food preparations, when used as ingredients in other foods, are exempt from
mandatory component declaration. For a list of these exemptions, please consult appendices 2-3 and 2-4
of the Guide to Food Labelling and Advertising 2003,
<http://www.inspection.gc.ca/english/fssa/labeti/guide/ch2-1e.shtml> (consulted on 13 October 2006).
94
The mandatory common names of ingredients and components are given in Appendix 2-1 of the Guide
to Food Labelling and Advertising 2003, <http://www.inspection.gc.ca/english/fssa/labeti/guide/ch21e.shtml> (consulted on 13 October 2006).
95
Health Canada, “Allergen Labelling” in Food and Nutrition, <http://www.hc-sc.gc.ca/fn-an/labeletiquet/allergen/index_e.html> (consulted on 13 October 2006).
96
To this end, Health Canada intends to propose amendments to the FDR in order “to enhance labelling
requirements for priority allergens, gluten sources and sulphite in pre-packaged foods sold in Canada.”
Health Canada, “Food Allergy Factsheets,” <http://www.hc-sc.gc.ca/fn-an/securit/allerg/fs-if/index_f.html>
97
For example, a claim may not be made for a vitamin or mineral nutrient unless a serving of the food
contains at least 5% of the "recommended daily intake." Canadian Food Inspection Agency (CFIA), Guide
to Food Labelling and Advertising 2003, Chapter 7 – 7.25 - Vitamin and Mineral Nutrient Claims,
<http://www.inspection.gc.ca/english/fssa/labeti/guide/ch7be.shtml - 7.25> (consulted on 20 October
2006).
98
Let’s note that while one may make a claim to vaunt the merits of a product if the presence of nutrients
per portion of the food represents at least 5% of the “daily recommended intake,” declaring the presence
of irradiated ingredients is only mandatory for any individual irradiated ingredient constituting over 10% of
the food.
page
31
product being labelled as “irradiated” provided that each irradiated ingredient constitutes 10% of
the food or less. Canadian regulations are, therefore, more lax than the Codex standards and
guidelines, which require the labelling of all irradiated foods and ingredients (see section
2.1.1.8.).
3.1.2 Claims concerning food composition and quality
Certain claims on food composition and quality are permitted provided that such claims are not
false, misleading or deceptive, or likely to create a false impression regarding the nature, value,
quantity, composition, advantages or safety of the food to which the claim refers. 99
For example, utilization of the term “fresh” to indicate that the food has not been processed
should be used in reference to a food that has not been conserved, treated, dried, frozen or
processed in any fashion whatsoever. The utilization of the term “fresh” to designate a food’s
age or indicate that it was prepared recently is also permitted provided that the food was
recently produced, obtained or grown and that this claim is accompanied by a date of packing.
The term “home-made” suggests that a food was prepared at home and requires no further
preparation before consumption. The utilization of this term is permitted provided that the food
was not made in a commercial establishment (small-scale establishments included). Other
claims such as “home-style” or “home-made style” may be utilized to describe a food that may
contain mixes, in whole or in part, from commercial or private recipes.100
Certain other expressions, such as “nature,” “natural,” “Mother Nature,” or other terms affirming
that a food contains “natural ingredients” may only be used if the foods referred to have not
been subject to any processes which appreciably modified their physical, chemical or biological
state101 (such as decaffeination for example). “Natural” foods or ingredients must not contain
any added vitamins, mineral nutrients, artificial flavourings or food additives. Furthermore, no
component or part of the food or “natural” ingredient shall be eliminated, with the exception of
water.
Although no regulation banning the utilization of the terms “pure,” “100% pure” or “100%” has
existed since 1952, these terms should only be used in relation to foods not containing any antifoaming agents, preservatives or food colouring. Nor should these terms be used for a food that
is a compound, mixture, imitation or substitute—otherwise, such a declaration could be
considered misleading.
Terms such as "true", "real", "genuine" and the like should be used with care. Such terms
should not be used to describe foods or ingredients that are imitations or substitutes. Nor should
99
Department of Justice Canada, Food and Drugs Act (R.S., 1985, c. F-27). Part1 – Food , Drugs,
Cosmetics and Devices, General, <http://lois.justice.gc.ca/en/F-27/242565.html - rid-242570> (consulted
on 16 October 2006).
100
4.6 Homemade, <http://www.inspection.gc.ca/english/fssa/labeti/guide/ch4e.shtml - 4.6> (consulted on 16
October 2006).
101
A list of processes that have an influence on foods in their natural state is available the Guide to Food
Labelling and Advertising 2003, Chapter 4 – 4.7 Nature, Natural,
2006).
page
32
they be used in a manner which suggests that any product is the “exclusively true, real or
genuine article.”102
3.1.3 Food origin claims
In addition to the provisions of the Food and Drugs Act (FDA) and the Consumer Packaging and
Labelling Act (CPLA), the provisions of the Competition Act (R.S., 1985, c. C-34)103 on false and
misleading representations also apply to food labelling.
A food label containing the phrase ‘Made in Canada’ or ‘Product of Canada’ signifies that the
food’s origin is exclusively Canadian or that it was entirely made in Canada. It is possible to
utilize this expression to designate foods that have no ingredients of Canadian origin. In effect,
one may declare that a food was “Made in Canada” if it underwent substantial processing in
Canada104 (said substantial processing must also be the final processing to which the food was
subject) and over 50% of the total direct manufacturing or production costs 105 were Canadian,
even though the food is entirely constituted of ingredients from outside of Canada.
To reduce the risks of deceiving or misleading the consumer, it is also permitted to add
information such as "roasted and blended in Canada,” “fermented and bottled in Canada using
Canadian and imported grapes,” “packaged in Canada” or “processed in Canada.”106 However,
such information is not mandatory.
A food origin claim may be implicit. This is so when pictorial representations are used (e.g.
logos, pictures or symbols such as the Canadian flag107), as these may communicate as strong
and effective an impression as a written declaration, if not more so. Such claims are permitted if
they do not mislead consumers and provided the above-mentioned conditions are respected.
Furthermore, the term “imported” signifies that a food was imported from another country and
sold in Canada without undergoing any modification whatsoever.
102
4.12 True, Real, Genuine, <http://www.inspection.gc.ca/english/fssa/labeti/guide/ch4ae.shtml - 4.12>
103
Department of Justice Canada, Competition Act (R.S., 1985, c. C-34),
<http://lois.justice.gc.ca/en/showtdm/cs/C-34/index.html> (consulted on 20 October 2006).
104
A transformation is said to be substantial when the form, appearance or nature of a food product has
been fundamentally modified, such that “the goods existing after the change are new and different
goods from those existing before the change.” Competition Bureau, “Guide to ‘Made in Canada’ Claims,”
<http://www.competitionbureau.gc.ca/internet/index.cfm?itemID=1231&lg=e> (consulted on 20 October
2006).
105
The direct costs of production and manufacturing include expenditures in materials and manpower
hired by the producer/manufacturer in connection with the production or manufacture of the product.
Competition Bureau, “Guide to ‘Made in Canada’ Claims,”
2006).
106
4.19 Imported, Product of Canada, Made in Canada, Country of Origin,
2006).
107
Utilization of the Canadian flag is however reserved under the provisions of the Trade-marks Act,
paragraph 9(1). Department of Justice of Canada, Trade-marks Act (R.S., 1985, c. T-13),
<http://lois.justice.gc.ca/en/showtdm/cs/T-13/index.html> (consulted on 20 October 2006).
page
33
In Quebec, a new law adopted by the National Assembly in April 2006, entitled An Act
Respecting Reserved Designations, introduces new terms concerning the region of production
which highlight ties to the soil, i.e. designation of origin (DO) and protected geographic
indications.108 The utilization of these reserved designations by producers or processing firms
requires, in particular, that their products comply with official product specifications. They must
as well obtain an attestation from an accreditation board duly authorized by the government of
Quebec.
3.1.4 Nutrition labelling
In contrast to the standards and guidelines of the Codex Alimentarius, which establish a
framework for it without, however, making it mandatory (see section 2.2.), nutrition labelling has
been mandatory in Canada since December 12, 2002. 109 Canadian regulations on nutrition
labelling were elaborated in order to provide a standardized presentation of nutrient content
information and to enable consumers to compare foods at the time of purchase. 110
Thus, the labels on prepackaged foods must include a Nutrition Facts Table stating, per serving
of stated size,111 the food’s energy value, and the food’s nutrient content. Specifically, nutrient
content information on the following thirteen nutrients is mandatory: fat, saturated fatty acids,
trans fatty acids, cholesterol, sodium, carbohydrates, fibre, sugar, protein, vitamins A and C,
calcium and iron. Certain foods are not required to present a Nutrition Facts Table. 112 This,
notably, is the case for spices and certain bottled waters, fresh fruits and vegetables without
added ingredients, meat and meat by-products composed of a single ingredient. However, most
of these exemptions may not apply in the following cases:
108
Ministère de l’Agriculture, des Pêcheries et de l’Alimentation du Québec (MAPAQ), “Le ministre Yvon
Vallières annonce l’adoption de la Loi sur les appellations réservées et les termes valorisants,” Press
release, 13 April 2006,
<http://www.mapaq.gouv.qc.ca/Fr/Centre_Presse/Communiques/2006/06127.htm> (consulted on 20
October 2006).
109
A three-year transition period has been granted to businesses with gross annual food sales in Canada
above one million dollars during the 12 months preceding December 12, 2002. A five-year transition
period has been granted to businesses with gross annual food sales in Canada under one million dollars
over the same period. The latter must be in compliance with the new regulations as of December 12,
2007. Canada Gazette, Regulations Amending the Food and Drug Regulations (Nutrition Labelling,
Nutrient Content Claims and Health Claims), Vol. 137, No 1 — January 1, 2003,
<http://canadagazette.gc.ca/partII/2003/20030101/html/sor11-f.html> (consulted on 20 October 2006).
110
5.1 Purpose of the New Nutrition Labelling Regulations,
111
We believe it is important to point out that the information contained in the Nutrition Facts Table is
based on the concept of the serving of stated size (i.e. nutritional value per “x” ml or g.) and that
manufacturers dispose of a wide latitude in setting the portions of their products to be used as a basis for
the nutritional value information they provide. Consequently, it may be rather difficult for the consumer to
cross compare the nutritional value of similar foods should the latter not use standardized portions. See
the Reference Amounts Table, <http://www.inspection.gc.ca/english/fssa/labeti/guide/ch6e.shtml - tab63> (consulted on 9 November 2006).
112
Exempted foods may nevertheless voluntarily display a Nutrition Facts Table, provided that it complies
with the requirements of the Food and Drug Regulations (FDR). A complete list of these exemptions is
included in Article B.01.401(2) of the FDR, which may be found on-line at the Department of Justice’s
website <http://lois.justice.gc.ca/fr/F-27/C.R.C.-ch.870/article-B.01.401.html> (consulted on 20 October
2006).
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34
• If a vitamin or mineral nutrient has been added to the product
• If a vitamin or mineral nutrient is declared a constituent of an ingredient (other than flour)
• If aspartame, sucralose or acesulfame-potassium is added to the product (...)
• If the product is ground meat, a by-product of ground meat, ground poultry meat or a byproduct of ground poultry meat
• If the label or advertisement contains one of the following elements (...):
> a nutritional reference or a nutrient content claim,
> a claim re a biological role,
> a health claim,
> a name, statement, logo, symbol, seal of approval or any other representation that is
health-related, and
> the expressions “nutrition facts,” “nutritional value” or “nutritive value.”113
Under the provisions of regulations, complementary declarations may also be demanded in the
Nutrition Facts Table or apart from it. This is notably the case for elements for which a nutrient
value or health claim is made.
3.1.5 Claims concerning nutritional value
The Food and Drug Regulations authorize a certain number of claims in relation to the
nutritional value of prepackaged foods, i.e. “statements or expressions which describe, directly
or indirectly, the level of a nutrient in a food or a group of foods.”114 Such authorized claims
apply to all foods, whether sold to the food industry or at the retail level, to restaurants or to any
other food services establishment.
The FDR prescribes the mandatory wording, the compositional criteria for each claim and any
other related additional labelling requirements. The compositional criteria considered for most of
these claims are based on standardized and regulated “reference amounts,”115 as well as the
“stated serving size” of a given food. 116
Subject to the satisfaction of the prescribed criteria, certain references to a food’s nutrient
contents are authorized. Claims may appear on food labels in relation to:
• energy value/caloric efficiency (e.g. “zero energy,” “low in calories,” “hypocaloric,” “source of
energy,” provides more calories” or “low-cal”)117
• protein (e.g. “contains less than X grams per serving” or “excellent source of protein”)
• fat (e.g. “100% fat free,” “less fat,” “light” or “thin”)118
113
5.3 Exemptions [B.01.401(2)], Op.cit. 110.
114
7.1 Introduction, <http://www.inspection.gc.ca/english/fssa/labeti/guide/ch7e.shtml - 7.1> (consulted on
20 October 2006).
115
A “reference amount” is a “specific regulated quantity of a type of food usually eaten by an individual
at one sitting.” Canadian Food Inspection Agency (CFIA), Guide to Food Labelling and Advertising 2003,
Chapter 6 – 6.2.1 Reference Amounts, <http://www.inspection.gc.ca/english/fssa/labeti/guide/ch6e.shtml
- 6.2.1> (consulted on 10 November 2006).
116
Op.cit.115.
117
Let’s note that it is permitted to write “zero calories” on a food label if the food contains less than five
calories per reference amount and stated serving size.
118
It is permitted to write “100% fat free” on a food label if a food contains less than 0.5 grams of fat per
100 grams, less than 0.5 grams of fat per reference amount and serving of stated size, and contains no
added fat .
page
35
•
•
•
•
•
•
saturated fatty acids, trans fatty acids and cholesterol (e.g. “low in saturated fatty acids,” “0
trans fatty acids,” 119 or “no cholesterol”120)
omega-3 and omega-6 polyunsaturated fatty acids (e.g. “source of omega-3
polyunsaturated fatty acids” or “contains omega-6 polyunsaturated fatty acids”)
sodium (salt) and potassium (e.g. “no salt,”121 “no sodium added” or very high in potassium”)
carbohydrates and sugar (e.g. “zero sugar”122)
dietary fibre (e.g. “very high source of [designate origin or type of fibre] fibre”)
nutrient content in vitamins and mineral nutrients 123 (e.g. ”contains eight essential nutrients,”
“enriched in vitamins or minerals,” “excellent source of” or “higher in [name of vitamin or
mineral nutrient] than...”).
In cases where a nutritional value claim is made for a food, the nutrient for which the claim is
made—along with its quantity—must appear in the Nutrition Facts Table.
Certain comparative claims are also permitted by the FDR, i.e. claims that compare the
nutritional properties of two or more foods. Such claims must however refer to important
differences from a nutritional standpoint between two or more similar foods from the same food
group, “chicken as a reference food for tofu.”124
3.1.6 Health claims
The object of health claims, which specify certain characteristics of a food purportedly apt to
lessen the risks of illnesses related to dietary habits, is in particular to help consumers make
informed choices so as to lessen their risk of developing chronic diseases. Such claims must be
coherent, not misleading and based on scientifically recognized health criteria.
Following the most recent amendments to the FDR, health claims on food labels are permitted
in Canada, which is a departure from past practice. Such claims must be founded on “on sound
scientific evidence that has established a relationship between certain elements of healthy diets
119
It is permitted to write “zero trans fat” if the food contains less than 0.5 grams of fat per 100 grams,
less than 0.5 grams of fat per reference amount and stated serving size, and if the energy value from
saturated fatty acids and trans fatty acids does not exceed 15% of the food’s total energy value.
120
It is permitted to write “no cholesterol” if a food contains less than 2 mg of trans fatty acids per
reference amount and serving of stated size, if the sum of saturated fatty acids and trans fatty acids
contained in the food does not exceed 2 grams per reference amount and serving of stated size, and if
the energy value from saturated fatty acids and trans fatty acids does not exceed 15% of the food’s total
energy value.
121
It is permitted to write “no salt” if a food contains less than 5 mg of sodium per reference amount and
stated serving size.
122
It is permitted to write “zero sugar” if a food contains less than 0.5 grams of sugar per reference
amount and per stated serving size and if the food provides less than 5 calories per reference amount
and per stated serving size.
123
A claim may not be made for a vitamin or mineral nutrient unless a serving of the food contains at least
5% of the "recommended daily intake" of said vitamin or mineral nutrient. Canadian Food Inspection
Agency (CFIA), Guide to Food Labelling and Advertising 2003, Chapter 7 – 7.25 Vitamin and Mineral
Nutrient Claims, <http://www.inspection.gc.ca/english/fssa/labeti/guide/ch7be.shtml - 7.25> (consulted on
20 October 2006).
124
7.9 Comparative Claims, <http://www.inspection.gc.ca/english/fssa/labeti/guide/ch7e.shtml - 7.9>
page
36
and reduction of risk of certain diseases.”125 Heart disease, hypertension and cancer are the
only illnesses referred to in Schedule A of the Food and Drugs Act (FDA) for which such claims
are permissible.
In addition to the illnesses for which claims are authorized and the mandatory wording stipulated
in certain cases, the FDR permits the following claims citing certain relationships (subject to the
satisfaction of its criteria on the nutritional composition of foods):
• A diet low in sodium and high in potassium, and the reduction of risk of hypertension (e.g. “A
healthy diet containing foods high in potassium and low in sodium may reduce the risk of
high blood pressure, a risk factor for stroke and heart disease. [Name of food] is sodiumfree.”);
• A diet adequate in calcium and vitamin D, and the reduction of risk of osteoporosis (e.g. “A
healthy diet with adequate calcium and vitamin D, and regular physical activity, help to
achieve strong bones and may reduce the risk of osteoporosis. [Name of food] is a good
source of calcium”);
• A diet low in saturated fat and trans fat, and the reduction of risk of heart disease (e.g. “A
healthy diet low in saturated and trans fats may reduce the risk of heart disease. [Name of
food] is free of saturated and trans fats.”);
• A diet rich in vegetables and fruits, and the reduction of risk of some types of cancer (e.g. “A
healthy diet rich in a variety of vegetables and fruit may help reduce the risk of some types
of cancer.”); and
• Minimal fermentable carbohydrates in gum, hard candy or breath-freshening products, and
the reduction of risk of dental caries (e.g. “Does not promote tooth decay.”)126
As with the Codex standards and guidelines on health claims (see section 2.4.), it is permissible
to advance a claim on the beneficial properties of a nutrient on an individual’s health and to
specify the quantity of said nutrient contained in the food, but it is not permissible to attribute the
beneficial effects to the food itself.
Under the provisions of the FDR, claims in relation to their biological role are permissible for all
nutrients.127 Such claims refer to the generally recognized functions of nutrients or to the energy
value of a food “as an aid in maintaining the functions of the body for the maintenance of good
health, or for normal growth and development.”128 For example, it is acceptable to state that the
energy value of a food or a nutrient contributes to the maintenance of good health or to normal
growth and development. In addition to these two claims of a general character, i.e. which are
applicable to all nutrients, claims in relation to the biological role of specific nutrients are also
admissible.129
As with health claims, claims in relation to the biological role of nutrients should not, however,
imply that consumption of the food, by itself, would have the effect attributed to the nutrient.
125
8.4 Diet-Related Health Claims, <http://www.inspection.gc.ca/english/fssa/labeti/guide/ch8e.shtml - 8.4>
126
Ibid.
127
A claim may not be made for the biological role of a vitamin or mineral nutrient unless a serving of the
food contains at least 5% of the "recommended daily intake" of said vitamin or mineral nutrient.
128
8.5 Biological Role Claims, <http://www.inspection.gc.ca/english/fssa/labeti/guide/ch8e.shtml - 8.5>
129
Ibid. A list of permitted claims is given in Table 8-2 of the Canadian Food Inspection Agency’s Guide
to Food Labelling and Advertising 2003.
page
37
Thus, whereas an acceptable claim could state, for example, that “Milk is an excellent source of
calcium which helps build strong bones and teeth,” the claim that “Milk helps build strong bones
and teeth” would, however, be unacceptable. 130
Moreover, it is acceptable to use the heart symbol in association with cardiovascular health
claims on food labels, provided that this utilization is consistent with the “Policy Respecting the
Use of Heart Symbols and Heart Health Claims on Food Labels and in Food Advertisements,”
contained in the 2003 Guide to Food Labelling and Advertising. This policy stipulates, in
particular, that it may be considered misleading—and consequently is liable to constitute an
infraction under the FDA—to state, suggest or imply, via the utilization of the heart symbol, that
a particular food is nutritionally superior to or healthier than other foods since one's entire food
intake, not a single part of it, is the critical variable in determining the nutritional adequacy of
one’s diet and its contribution to reducing risk for chronic disease. 131
3.1.7 Labelling of organically farmed foods
As with the Codex Guidelines on the labelling of organically farmed foods (see section 2.5.),
Canada does not require the labelling of organically farmed foods. Nevertheless, on 29 June
1999, the Standards Council of Canada (SCC) adopted and published, the National Standard
for Organic Agriculture, which concerns the general principles and management standards
pertaining to organic production systems. This Standard, which was revised in September 2006,
applies “to products that carry or are intended to carry descriptive labelling referencing organic
production,”132 including non-processed plants and plant products, livestock and livestock
products, as well as processed agricultural crop and livestock products intended for human
consumption derived from said items.
“A product will be regarded as bearing indications referring to organic production
methods where, in the labelling or claims, including advertising materials or commercial
documents, the product or its ingredients are described by the terms organic,
biodynamic, biological and ecological or by words of similar intent, including diminutives,
which suggest to the purchaser that the product or its ingredients were obtained
according to organic production methods.”133
The labelling and claims in relation to non-processed plants and plant products, non-processed
livestock and livestock products, as well as processed agricultural crops and livestock products
derived from the former and intended for human consumption, may only refer to organic
production methods 134 where:
130
Ibid.
Canadian Food Inspection Agency (CFIA), Guide to Food Labelling and Advertising 2003, Annex 8-2,
Policy Respecting the Use of Heart Symbols and Heart Health Claims on Food Labels and in Food
Advertisements, <http://www.inspection.gc.ca/english/fssa/labeti/guide/ch8-1e.shtml - 2> (consulted on
23 October 2006).
132
Canadian General Standards Board, Organic Production Systems General Principles and
Management Standards - CAN/CGSB-32.310-2006,
<http://www.tpsgc.gc.ca/cgsb/on_the_net/organic/scopes-e.html - 32_310> (consulted on 23 October
2006).
133
<http://www.tpsgc.gc.ca/cgsb/on_the_net/organic/032_0310_2006-e.pdf> (consulted on 23 October
2006).
134
Organic production criteria prohibit, notably, using any of the following: materials obtained through
genetic engineering, synthetic pesticides, wastewater sludge, artificial plant growth regulators, synthetic
131
page
38
•
•
•
•
•
•
•
such indications clearly show that they relate to a method of agricultural production and are
linked with the name of the organic product in question, and this information is clearly given
in the list of ingredients;
the product and its ingredients were obtained in accordance with the National Standard for
Organic Agriculture;
the product was obtained, imported or processed by an operator that has been certified in
accordance with the National Standard for Organic Agriculture;
the product only contains ingredients of non-agricultural origin mentioned in permitted
substances lists;135
the product contains no ingredients found under both organic and non-organic form;
the product or its ingredients have not been subject, during its preparation, to irradiation or
to treatment with substances not mentioned in permitted substances lists; and
the label specifies the name of the certification authority to which the operator that carried
out the production—or the most recent food preparation process (conditioning, processing,
labelling)—is subject.
The label, which may be affixed to products of which at least 70% of the ingredients are of
organic agricultural origin (i.e. obtained in accordance with the National Standard for Organic
Agriculture), must be found on the product’s principal display panel and read as follows:
“Contains x% of organic.”136 Only products containing 70% or more ingredients of organic origin
are admissible for certification.
Moreover, in order to “facilitate international market access, provide protection to consumers
against deceptive and misleading labelling practices and support the further development of the
domestic market,”137 the Canadian organic products sector has decided to support a regulatory
bill, published in Part I of the Canada Gazette on September 2, 2006, which aims to transform
the present voluntary regime into a system through “which the Canadian Food Inspection
Agency (CFIA) as competent authority can regulate the use of the ‘Canada Organic’ agricultural
product legend.”138 At the present time, British Columbia139 and Quebec 140 are the only
provinces in Canada to have implemented regulated organic certification regimes.
allopathic veterinary drugs, including antibiotics and parasiticides, synthetic processing substances, aids
and ingredients, and food additives and processing aids including sulphates, nitrates and nitrites, ionizing
radiation and forms of irradiation on products destined for food or their inputs.
135
These lists indicate which substances are authorized in organic agriculture, notably with respect to
crop production (for example re soil amendments and combating weeds) livestock production (for
example, animal feed, additives and food supplements) food processing and hygiene (for example,
organic and non-organic ingredients sanitizers and disinfectants, and pest-control substances), Canadian
General Standards Board, Organic Production Systems: Permitted Substances Lists,
2006).
136
2006).
137
In effect, “under the current European regulations, the European Union requires that all countries
exporting organic food to the European Union be on an approved third-country equivalency list by
December 31, 2006.” Canada Gazette, Vol. 140, No 35 — 2 September 2006, Organic Products
Regulations, <http://canadagazette.gc.ca/partI/2006/20060902/html/regle2-e.html> (consulted on 23
October 2006).
138
Canada Gazette, Vol. 140, No 35 — 2 September 2006, Organic Products Regulations,
<http://canadagazette.gc.ca/partI/2006/20060902/html/regle2-e.html> (consulted on 23 October 2006).
page
39
3.1.8 Labelling of genetically modified (GM) foods
In contrast to the Codex Alimentarius Commission, which is without a standard or guidelines on
genetically engineered foods, Canada adopted a voluntary standard on the labelling of
genetically modified foods in April 2004. 141 Health Canada’s policy as regards the labelling of
genetically engineered foods, which is consistent with the FDA and the CPLA, is founded on the
following principles and guidelines:
• require mandatory labelling if there is a health or safety concern, i.e. from allergens
or a significant nutrient or compositional change (these decisions will be made by
Health Canada);
• ensure that labelling is understandable, truthful and not misleading;
• permit voluntary positive labelling on the condition that the claim is not misleading or
deceptive and the claim itself is factual; and
• permit voluntary negative labelling on the condition that the claim is not misleading or
deceptive and the claim itself is factual. 142
The Standard on Voluntary Labelling and Advertising of Foods that Are and Are not Products of
Genetic Engineering “limits to less than 5 per cent the amount of accidental co-mingling of
genetically-engineered and non genetically-engineered food when a labelling claim is made.”143
The Standard, which is intended as a guide for food manufacturers and businesses, also
defines the various conditions and criteria governing statements on the presence or absence of
genetically engineered ingredients in a food. Its objective is to help consumers in their grocery
shopping decisions. 144
3.1.9 Labelling of foods that respect fair trade principles
Presently, there is no particular standard in Canada intended as a regulatory framework for the
labelling of food products that respect fair trade principles. These products are nevertheless
subject to the same laws and regulations as other food products (the Food and Drugs Act and
Regulations and the Consumer Packaging and Labelling Act and Regulations) and must not
bear labels that are false or are liable to mislead consumers.
3.1.10 Utilization of third party endorsements, logos and seals of approval
139
Certified Organic Associations of British Columbia (COABC), “COABC – Certification,”
<http://www.CertifiedOrganic.bc.ca/cb/certification.htm> (consulted on 25 September 2006).
140
Conseil des appellations agroalimentaires du Québec, Quebec Organic Reference Standard,
<http://www.caaq.org/appellation-biologique/normes-biologiques.asp> (consulted on 25 September
2006).
141
Canadian General Standards Board, Voluntary Labelling and Advertising of Foods that Are and Are
not Products of Genetic Engineering - CAN/CGSB-32.315-2004,
<http://www.tpsgc.gc.ca/cgsb/on_the_net/032_0315/032_0315_1995-e.pdf> (consulted on 23 October
2006).
142
Canadian Food Inspection Agency (CFIA), “Labelling of Genetically Engineered Foods in Canada,”
<http://www.inspection.gc.ca/english/sci/biotech/labeti/response.shtml> (consulted on 23 October 2006).
143
Canadian Food Inspection Agency (CFIA), “Voluntary Standard for Labelling of Genetically Engineered
Foods Becomes National Standard,” Press Release, Ottawa, 15 April 2004,
<http://www.inspection.gc.ca/english/corpaffr/newcom/2004/20040415e.shtml> (consulted on 23 October
2006).
144
Ibid.
page
40
Food manufacturers and distributors must be prudent in their utilization of third party logos and
seals of approval. "’Third-party endorsement’ means the approval or sanction of a food by any
health professional or health organization, or any individual or group.”145 Consumers may
perceive “approved” foods as superior in terms of health, nutrition or wholesomeness in
comparison with foods lacking such an endorsement. However, any statements of approval
which "state, suggest or imply that a single food or brand of food is ‘nutritionally superior’ to, or
‘healthier’ than, other foods are considered misleading, since health is imparted by the total diet
rather than by individual foods."146
In order to lessen the risks of misleading information, the Policy on the Use of Third Party
Endorsements, Logos and Seals of Approval, elaborated in 1991 by the Food Division of
Consumer and Corporate Affairs Canada, 147 lays out the conditions under which the utilization
of third party endorsements, logos and seals of approval is permissible. These conditions may
require a clear indication on the food label concerning the “the reason for the appearance of the
name, statement, logo, etc. of a third party” or a statement specifying that this utilisation “does
not constitute an endorsement of the food.”148
3.2
In the United States
In the United States, the requirements on the labelling of prepackaged foods sold on US
territory are stipulated under the provisions of the Federal Food, Drug and Cosmetic Act, 149
which is administered by the Food and Drug Administration (FDA). The FDA also works in close
collaboration with the Federal Trade Commission (FTC), the federal agency responsible for
ensuring consumer protection via a variety of laws, in particular the Advertising Law. The latter
includes provisions enabling the regulation of claims made on food labels. This Law stipulates in
particular that advertising must be truthful, that it must not make false or deceptive
representations or harm consumers.150 Whereas the FDA is responsible for enforcing foodlabelling regulations, the FTC sees to the enforcement of regulations governing the advertising
of food products.
The following sections present a general outline of the regulatory framework re the different
types of food labelling in the United States and specify, where required, the principal differences
between this framework and Codex Alimentarius standards and guidelines.
145
8.11: Third-Party Endorsements, Logos and Seals of Approval,
2006).
146
Canadian Food Inspection Agency (CFIA), Guide to Food Labelling and Advertising 2003, Section VII:
Health-Related Claims, Appendix II: Policy on the Use of Third-Party Endorsements, Logos and Seals of
Approval (amended, 31 January 1997), <http://www.inspection.gc.ca/english/bureau/labeti/guide/7-07e.shtml> (consulted on 26 October 2006).
147
Consumer and Corporate Affairs Canada ceased to exist as of 25 June 1993. Its former labelling and
advertising responsibilities have been assumed by the Food Division of the Canadian Food Inspection
Agency (CFIA).
148
Ibid.
149
United States Food and Drug Administration (FDA), Federal Food, Drug, and Cosmetic Act,
<http://www.fda.gov/opacom/laws/fdcact/fdcact4.htm> (consulted on 27 October 2006).
150
Federal Trade Commission, Frequently Asked Advertising Questions: A Guide for Small Business,
<http://www.ftc.gov/bcp/conline/pubs/buspubs/ad-faqs.htm> (consulted on 30 October 2006).
page
41
3.2.1 General requirements concerning labelling of prepackaged foods
As with Canadian regulations, American food labelling regulations require that the following
information be declared on the labels of prepackaged foods:
• the food’s specific name
• the net content
• the “freshness date”151
• the name and address of the manufacturer, packager or distributor
• the list of ingredients and constituents, 152 including those recognized as causes of allergic
responses153
American requirements regarding the disclosure of ingredients recognized as causing allergic
responses match the requirements in the standards and guidelines of the Codex Alimentarius.
As such, they are more stringent than Canadian requirements, which permit certain exemptions
(see section 3.1.1.5).
As in Canada, the Nutrition Facts Table is mandatory in the United States. This table must
include a stated serving size and declare the quantities per serving of energy value
(kilojoules/calories), total fat, saturated and trans fatty acids, cholesterol, sodium,
carbohydrates, fibre, sugar, protein, vitamins A and C, calcium and iron. 154
The fact that the Nutrition Facts Table is mandatory in the United States means its requirements
are more stringent than those stipulated in Codex Alimentarius standards and guidelines, as the
latter permit the voluntary display of information on the nutritional value of foods without making
this mandatory (see section 2.2).
Since 1986, the FDA has required that the Radura international symbol be displayed on the
packaging of foods that are irradiated, whether at the time of manufacture or at the time of sale,
along with the written statement “treated by irradiation” or ‘treated with radiation.” However, in
the case of irradiated ingredients included in the food, no such labelling is required if the food
has not been irradiated in its entirety, regardless of the percentage of irradiated ingredients. 155
American regulations contrast with both regulatory provisions in Canada, which require the
declaring of irradiated ingredients that constitute over 10% of the food, and with the provisions
151
The Orator Network, To amend the Federal Food, Drug, and Cosmetic Act relating to freshness dates
on food [H.R. 3570], 109th Congress - 1st Session, <http://www.theorator.com/bills109/hr3570.html>
152
These labelling requirements regarding constituents differ from the Codex standards and guidelines,
which only require the labelling of ingredients (see section 2.1.1.2.).
153
United States Food and Drug Administration (FDA), Federal Food, Drug, and Cosmetic Act,
<http://www.fda.gov/opacom/laws/fdcact/fdcact4.htm> (consulted on 27 October 2006).
154
United States Government Printing Office (GPO) - National Archives and Records Administration,
Codes of Federal Regulations, Title 21 Food and Drugs, Chapter 1 – Food and Drug Administration
(FDA) and Department of Health and Human Services (DHHS), Part 101- Food Labeling,
<http://www.access.gpo.gov/nara/cfr/waisidx_06/21cfr101_06.html> (consulted on 27 October 2006).
155
US Food and Drug Administration (USFDA) - Center for Food Safety and Applied Nutrition (CFSAN),
“Is irradiated food safe? How is it labeled?” <http://www.cfsan.fda.gov/~dms/qa-fdb33.html> (consulted
on 15 December 2005).
page
42
of Codex standards and guidelines, which require labelling for all irradiate ingredients, whatever
their percentage in the food’s total composition (see section 2.1.1.8).
The utilization of terms describing the “freshness” and “purity” of foods, as well as the presence
of “natural” ingredients in foods, is permitted under the provisions of U.S. food and drug
regulations, provided that such statements are true, that they do not mislead consumers and
that they respect certain conditions in relation to food preparation methods. For example, the
term “fresh” may not be used to describe a smoked or salted food,156 and the term “natural””
may only be used to describe foods containing no artificial ingredients, chemical food colouring
agents or preservatives. 157 Moreover, the terms “pure” or “100%” must only be used to describe
foods containing but a single ingredient. 158
As for disclosure of the country of origin for food products sold in the United States, at present,
this is only required for farmed fish, mollusks and shellfish intended for sale in retail outlets.
Although the US Farm Bill adopted by the U.S. Congress in 2002 requires the specification of
the country of origin of all food products sold in the U.S., a new period of grace was granted by
the Bush administration on November 10, 2005, which postponed this requirement until
September 30, 2008. 159
Moreover, claims alluding to a geographical place, notably terms such as “farm,” “farm-style,”
“country” or “country-style,” are permitted under certain conditions in accordance with a
provision of the Code of Federal Regulations on animals and animal products. 160
156
United States Department of Agriculture (USDA) - Food Safety and Inspection Service (FSIS), “Fresh,
‘Not Frozen’ and Similar Terms when Labeling Meat and Poultry Products” in Regulations and Policies,
<http://www.fsis.usda.gov/regulations_&_policies/Labeling_Fresh_Not_Frozen/index.asp> (consulted on
31 October 2006).
157
United States Department of agriculture (USDA) - Food Safety and Inspection Service (FSIS),
“Labeling and Consumer Protection: Natural and Organic Claims,”
<http://www.fsis.usda.gov/Frame/FrameRedirect.asp?main=http://www.fsis.usda.gov/OPPDE/larc/Claims/
Organic_Claims.htm> (consulted on 31 October 2006).
158
Codes of Federal Regulations, Title 9 Animals and Animal Products, Chapter 3 – Food Safety and
Inspection Service (FSIS) and United States Department of agriculture (USDA), False or misleading
labelling or practices generally; specific prohibitions and requirements for labels and containers,
<http://a257.g.akamaitech.net/7/257/2422/01jan20061500/edocket.access.gpo.gov/cfr_2006/janqtr/pdf/9c
fr317.8.pdf> (consulted on 31 October 2006).
159
United States Department of Agriculture (USDA) - Agricultural Marketing Service (AMS), “Country of
origin labelling,” in 2002 Farm Bill Provisions, <http://www.ams.usda.gov/COOL/> (consulted on 27
October 2006).
160
Codes of Federal Regulations, Title 9 Animals and Animal Products, Chapter 3 – Food Safety and
Inspection Service (FSIS) and United States Department of agriculture (USDA), False or misleading
labelling or practices generally; specific prohibitions and requirements for labels and containers,
<http://a257.g.akamaitech.net/7/257/2422/01jan20061500/edocket.access.gpo.gov/cfr_2006/janqtr/pdf/9c
fr317.8.pdf> (consulted on 31 October 2006).
page
43
Since 1990, federal regulations in the U.S. have authorized the making of claims regarding the
nutrient content in food products,161 as well as comparative claims between similar foods or
foods belonging to the same food group.162 A summary of the conditions permitting the
utilization of the authorized terms (e.g. “rich in...,” “an excellent source of...” “fortified,” “extra,”
“less,” etc.), for different nutrients, is available in Chapter VI of the Food Labelling Guide, a
document jointly published by the FDA and the Center for Food Safety & Applied Nutrition
(CSFAN). 163
American regulatory provisions on nutrition claims are practically the same as their Canadian
counterparts, as well as the standards and guidelines of the Codex Alimentarius Commission.
3.2.5 Health claims
Title 21 of the Code of Federal Regulations on food and drugs
authorizes certain health claims, notably the ones highlighting the
relationships between:
• Calcium content and osteoporosis
• Fat content and cancer
• Sodium content and high blood pressure
• Content in saturated fatty acids and cholesterol and the risk of
heart disease
• Fruits and vegetables and cancer
• Folic acid content and neural tube defects
• Sugar/alcohol content and tooth decay
• The soluble fibre content of certain foods and the risk of heart
disease164
Figure 1. USDA
organic certification
logo
Such claims—including those making use of third party endorsements, logos and seals of
approval—must be scientifically validated and enjoy the support of the scientific community and
qualified experts. In addition, these claims must of course be easy for consumers to understand
and must not be misleading.165 Manufacturers wishing to make health claims on their food labels
161
United States Food and Drug Administration (FDA) and Center for Food Safety and Applied Nutrition
(CFSAN), “Claims That Can Be Made for Conventional Foods and Dietary Supplements,”
<http://www.cfsan.fda.gov/~dms/hclaims.html> (consulted on 30 October 2006).
162
(FDA) and Department of Health and Human Services (DHHS), Nutrient content claims – general
principles,
<http://a257.g.akamaitech.net/7/257/2422/10apr20061500/edocket.access.gpo.gov/cfr_2006/aprqtr/pdf/2
1cfr101.13.pdf> (consulted on 30 October 2006).
163
United States Food and Drug Administration (FDA) and Center for Food Safety & Applied Nutrition
(CSFAN), A Food Labelling Guide, <http://www.cfsan.fda.gov/~dms/flg-toc.html> (consulted on 30
October 2006).
164
(FDA) and Department of Health and Human Services (DHHS), Food Labelling,
<http://www.access.gpo.gov/nara/cfr/waisidx_06/21cfr101_06.html> (consulted on 30 October 2006).
165
(FDA) and Department of Health and Human Services (DHHS), Health claims: general requirements,
<http://a257.g.akamaitech.net/7/257/2422/10apr20061500/edocket.access.gpo.gov/cfr_2006/aprqtr/pdf/2
1cfr101.14.pdf> (consulted on 30 October 2006).
page
44
must comply with certain conditions. These latter are presented in Appendix C of Chapter VI of
the FDA/CSFAN Food Labelling Guide.166 Health claims must not suggest that health benefits
are attributable to the food itself, as opposed to the nutrient or nutrients that it contains (or does
not contain).
In December 2000, the U.S. Department of Agriculture (USDA) developed a set of standards
aimed at satisfying the requirements of the Organic Foods Protection Act, which was passed by
Congress in 1990, and regulating the utilization of the terms “organic,” “100% organic” and
“made with organic ingredients” in relation to organically farmed foods.
Thus, since October 21 2002, all organically farmed food products sold in the United States may
bear the USDA-Organic label (figure 1), provided that they’ve been certified by a duly USDA
accredited agency. Violations may be sanctioned by fines of up to $10,000 per infraction.167
To be certified as organic, at least 70% of a food’s ingredients must be organically farmed. 168
Concerning the labelling of genetically engineered foods, the Food and Drug Administration
published a policy statement in 1992 affirming that it was unnecessary to provide such
information to consumers since food produced with these new methods does not differ from
food produced via conventional methods, and therefore do not pose any additional health
risks.169
This position of the FDA in favour of voluntary as opposed to mandatory labelling of genetically
modified foods was reaffirmed in a document submitted to the food industry for consultation
purposes on January 17, 2001,170 and remains to this day the official position of the U.S.
government on this issue.
166
(CSFAN), A Food Labelling Guide – Appendix C, <http://www.cfsan.fda.gov/~dms/flg-6c.html> (consulted
on 30 October 2006).
167
Agricultural Marketing Service (AMS) - United States Department of agriculture (USDA), “Organic
Food Standards and Labels: The Facts” in The National Organic Program,
<http://www.ams.usda.gov/nop/Consumers/brochure.html> (consulted on 30 October 2006).
168
Agricultural Marketing Service (AMS) - United States Department of agriculture (USDA), “NOP
Background information” in The National Organic Program
<http://www.ams.usda.gov/nop/FactSheets/Backgrounder.html> (consulted on 30 October 2006).
169
Center for Food Safety & Applied Nutrition (CSFAN). Federal Register. Part IX. Department of Health
and Human Services (DHHS) – Food and Drug Administration (FDA). Statement of Policy: Foods Derived
From New Plant Variety; Notice, 29 May 1992. <http://www.cfsan.fda.gov/~acrobat/fr920529.pdf>
170
(CSFAN), Guidance for Industry: Voluntary Labeling Indicating Whether Foods Have or Have Not Been
Developed Using Bioengineering, <http://www.cfsan.fda.gov/~dms/biolabgu.html> (consulted on 30
October 2006).
page
45
U.S. regulations lack any provisions intended as oversight for foods that respect fair trade
principles. These products are nevertheless subject to the FTC’s and the FDA’s regulatory
provisions on business practices and the labelling of consumer products. Thus, the labels on fair
trade products must not bear false or deceptive information, liable to prejudice consumers.
3.2.9 Claims on livestock production methods in relation to animals raised for human
consumption
U.S. authorities permit claims on the livestock production conditions of animals raised for human
consumption. Thus, in addition to the “USDA Certified” seal, since 1978 the USDA’s Livestock
and Seed Program authorizes American producers and processors to utilize—subject to the
inspection of end products by authorized agents—the terms “raised without added hormones,”
“raised without antibiotics,” “not fed animal by-products,” “free range,” “free roaming,” “grass
fed,” “corn fed” or “grain fed” on the labels of certain products.171 In 1996, the program was
broadened to include an on-site verification service, performed by USDA authorized
independent organizations, to ensure the validity of claims on animal husbandry methods and
manufacturing processes for products which cannot be certified on the basis of an inspection of
the end product. This program allows producers and processors subject to such verification to
add, in addition to the above-mentioned claims, the “USDA Process Verified” seal to their
product labels.
There are no Codex standards or guidelines covering the regulation of claims on the livestock
production conditions of animals raised for human consumption.
3.3
The European Union
This section is concerned with the regulatory framework on food labelling presently in force in
the European Union (EU) and, where pertinent, the national regulations of certain EU member
countries, as the latter have the authority to institute regulatory policies that are more stringent
than those decreed by the EU.
The general principles and prescriptions of the EU’s food policy legislation, as laid down in
Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January
2002, seek to protect consumers’ interests and provide “a basis for consumers to make
informed choices in relation to the foods they consume,” in particular, by preventing fraudulent
or deceptive practices, the adulteration of foods and “any other practices which may mislead the
consumer.”172
The general principles of the food legislation, which must be enacted by all member states by
January 2007, at the latest, are also supported by the regulatory provisions of Directive
171
United States Department of Agriculture (USDA) - Food Safety and Inspection Service (FSIS), “Animal
Production Claims: Outline of Current Process,”
<http://www.fsis.usda.gov/OPPDE/larc/Claims/RaisingClaims.pdf> (consulted on 31 October 2006).
172
EUR-lex, Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January
2002 laying down the general principles and requirements of food law, establishing the European Food
Safety Authority and laying down procedures in matters of food safety. <http://eurlex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexplus!prod!DocNumber&type_doc=Regulation&an_doc
=2002&nu_doc=178> (consulted on 1 November 2006).
page
46
2005/29/EC on Unfair Commercial Practices,173 Council Directive 84/450/EEC on Misleading
and comparative advertising, 174 and Directive 2000/13/EC on Labelling, presentation and
advertising of foodstuffs, which stipulates, notably, that the labelling and presentation of
foodstuffs must not:
• “mislead the consumer as to the foodstuff's characteristics or effects,” or
• “attribute to a foodstuff (...) properties for the prevention, treatment or cure of a
human illness.”175
173
Europa, “Unfair commercial practices,” <http://europa.eu/scadplus/leg/en/lvb/l32011.htm> (consulted
on 1 November 2006).
174
Europa, “Misleading and comparative advertising,” <http://europa.eu/scadplus/leg/en/lvb/l32010.htm>
(consulted on 1 November 2006).
175
Europa, “Labelling, presentation and advertising of foodstuffs,”
<http://europa.eu/scadplus/leg/en/lvb/l21090.htm> (consulted on 1 November 2006).
page
47
3.3.1 General requirements concerning labelling of prepackaged foods
Directive 2000/13/EC of the European Parliament and the Council of 20 March 2000 on the
“Labelling, presentation and advertising of foodstuffs” stipulates certain compulsory labelling
particulars with respect to prepackaged foods:
• name under which the product is sold;
• net quantity;
• date of minimum durability (the day and month for foodstuffs that will not keep for more than
three months, the month and year for foodstuffs which will not keep for more than 18
months, and the year for foodstuffs which will keep for more than 18 months); and
• a list of ingredients (to be designated by their specific name and listed in descending order
of weight), including known allergens. 176
The European Union’s requirements as regards the disclosure of ingredients that are known
allergens are in line with those of the Codex Alimentarius standards and guidelines.
Additional information must be provided on the labels of highly perishable foods:
• name or business name and address of the manufacturer, packager or vendor;
• place of origin or provenance, where the omission of such information might mislead the
consumer; and
• instructions for use, where appropriate. 177
The fact that these latter EU requirements only apply to highly perishable products contrasts
with provisions of the Codex standards and guidelines, which requires the statement of these
particulars on the labelling of all prepackaged foods.
3.3.1.1 Identification and labelling of beef and veal
In the wake of the crisis over "mad cow disease" that wreaked havoc in Europe in the mid
1990s—and the attendant drop in consumer confidence in the beef industry—on 17 July 2000,
the EU adopted new provisions to 1) strengthen the existing regulations on the compulsory
labelling and traceability of beef products throughout the "farm to fork" chain and 2) enhance the
transparency of conditions governing the production and marketing of beef and veal. 178
Thus, according to Regulation (EC) No 1760/2000 of the European Parliament and the Council
of 17 July 2000 on the labelling of beef and beef products, operators or organizations marketing
EU or imported beef are obliged to label the beef at all stages of the marketing process. The
following particulars must appear on the label:
• The reference number or code establishing the link between the meat and the animal, or
group of animals, from which the meat was derived.
176
Allergenic ingredients must be declared in the list of ingredients in accordance with a different
directive: Directive 2003/89/EC of the European Parliament and of the Council of 10 November 2003
amending Directive 2000/13/EC as regards indication of the ingredients present in foodstuffs, <http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32003L0089:EN:HTML> (consulted on 1er
November 2006).
177
<http://europa.eu/scadplus/leg/en/lvb/l21090.htm> (consulted on 1er November 2006).
178
Europa, “Identification and labelling of beef and veal,”
<http://europa.eu/scadplus/leg/en/lvb/l12064.htm> (consulted on 1er November 2006).
page
48
•
•
The phrase "Slaughtered in" (i.e. country where slaughter took place and licence number of
the slaughterhouse).
The phrase "Cutting/cut in" (i.e. country where cutting was performed and licence number of
the cutting plant.179
Moreover, since 1 January 2002, operators must also indicate the country where the animals
were born, the country where the animals were fattened/bred, and the country where the
animals were slaughtered.
If, in the case of imported meat, not all compulsory information is
available, such meat must be labelled "Origin: non-EC", followed
by the name of the country in which it was slaughtered.
Figure 2 - European
Union TSG logo
Furthermore, this Regulation stipulates that the labels on
packaging for minced meat shall display the following mandatory
information:
• The reference number or code establishing the link between
the meat and the animal, or group of animals, from which the
meat was derived.
• The phrase "Produced in" (followed by the name of the country
of production) and the indication "Origin" where the country or
countries concerned are not the same as the country of
production.
• The country of slaughter. 180
Directive 1999/2/EC of the European Parliament and the Council of 22 February 1999
concerning foods and food ingredients treated with ionizing radiation requires that the labels of
all such foods and ingredients181 bear the words “irradiated” or “treated with ionising
radiation.”182
The requirements of this Directive on the labelling of irradiated foods and ingredients are similar
to those of the Codex standards and guidelines. As such they are superior to Canadian
regulations—which only require labelling information on any given irradiated ingredient where
such an ingredient constitutes over 10% of the food—as well as U.S. regulations under which
the labelling of irradiated ingredients is optional.
179
Ibid.
Europa, “Identification and labelling of beef and veal,”
181
Directive 1999/3/EC of the European Parliament and of the Council of 22 February 1999 establishes a
Community list of foods and food ingredients that it is permitted to treat with ionising radiation. Europa,
“Foodstuffs treated with ionising radiation,” <http://europa.eu/scadplus/leg/en/lvb/l21117.htm>
182
EUR-lex, Directive 1999/2/EC of the European Parliament and of the Council of 22 February 1999 on
the approximation of the laws of the Member States concerning foods and food ingredients treated with
ionising radiation, <http://eurlex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexplus!prod!DocNumber&lg=en&type_doc=Directive&an
_doc=1999&nu_doc=2> (consulted on 2 November 2006).
180
page
49
Since March 2006, an EU regulation has been in force establishing a framework for the
recognition of foodstuffs of a traditional composition, or produced according to traditional
production methods. According to EU members, the recognition of certain foods as “traditional
specialities guaranteed” (TSGs)183 offers a number of advantages: it encourages the
diversification of agricultural production; boosts farmers' revenues; promotes the rural economy;
increases the market value of such products; and thanks to the introduction of this designation,
consumers will able be to broaden their range of choices on the basis of clear information on
products, which, due to their specific characteristics, differ from similar products or foods.
Council Regulation No 509/2006 on “Agricultural products and foodstuffs as traditional
specialities guaranteed” stipulates in particular that only producers who comply with the product
specification—a mandatory requirement for the registration of a food product as a TSG—“may
refer to a TSG on the labelling, advertising or other documents relating to an agricultural product
or foodstuff,” either via par the EU’s TSG logo (Figure 2) or by using the term “traditional
speciality guaranteed” on the food’s label. 184
183
This Council Regulation on traditional specialities guaranteed specifies that “this designation is not a
reference of origin but aims to bring added value to a product made from traditional ingredients or a mode
of traditional production.” Europa, “Agricultural products and foodstuffs as traditional specialities
guaranteed,” <http://europa.eu/scadplus/leg/en/lvb/l66043.htm> (consulted on 2 November 2006).
184
Ibid.
page
50
Moreover, the Regulation clearly specifies that member states are
responsible for taking the necessary measures “to ensure legal
protection against any misuse or misleading use of the term
‘traditional speciality guaranteed,’ the abbreviation ‘TSG’ and the
associated Community symbol and against any imitation of names
registered and reserved.” TSG is a registered designation,
“protected against any practice liable to mislead the consumer,
including practices suggesting that a product is a traditional
speciality guaranteed recognised by the Community.”185
Figure 3 - European
Union PDO logo
The European Union has not elaborated any particular directives to
regulate the utilization of the terms “pure,” “fresh,” “natural,”
“traditional,” “original,” “home-made,” etc. However, certain member
states, England186 and France notably, 187 have enacted a degree of
regulation in this regard.
Under Directive 2000/13/EC of the European Parliament and the Council of 20 March 2000 on
the “Labelling, presentation and advertising of foodstuffs,” the place of origin or provenance of
highly perishable foods must be declared on the labels of such foods, where the omission of
such information might mislead the consumer. 188 However, the terms “origin” or “provenance”
are not defined in legislation.
Furthermore, on 20 March 2006, the member countries of the
European Union adopted another regulation establishing provisions
on the protection of geographical indications and designations of
origin with respect to agricultural products and foods. In effect,
Council Regulation No 510/2006 authorizes the use of the terms
"Protected Designation of Origin" (PDO) and "Protected
Geographical Indication" (PGI) or the associated European Union
symbols on the labels of certain EU products satisfying specific
conditions (see figures 3 & 4). Thus, foods “which are produced,
processed and prepared in a given geographical area using
recognised know-how” may bear the PDO designation while those
with a “a link with the area in at least one of the stages of
production, processing or preparation” may use the PGI
designation. 189
Figure 4 - European
Union PGI logo
185
Ibid.
Food Standard Agency (FSA), Criteria for the use of the terms fresh, natural, etc in food labelling,
<http://www.food.gov.uk/multimedia/pdfs/fresh.pdf> (consulted on 6 November 2006).
187
Legifrance, Code de la consommation, Chapitre II – Modes de présentation et inscriptions
<http://www.legifrance.gouv.fr/WAspad/VisuArticleCode?commun=&code=&h0=CCONSOML.rcv&h1=1&
h3=3> (consulted on 6 November 2006).
188
189
Europa, “Protection of geographical indications and designations of origin,”
186
page
51
As with the TSG designation, the PDO and PGI designations are registered and protected, in
particular, against any practice “likely to mislead the consumer as to the true origin of the
product,” as well as against “any misuse, imitation or evocation, even if the true origin of the
product is indicated or if the protected name is translated or accompanied by an expression
such as ‘style,’ ‘type,’ ‘method,’ ‘as produced in,’ ‘imitation’ or a similar expression.”190
3.3.4 Nutrition labelling
Nutrition labelling—i.e. “any information appearing on labelling and relating to the energy value
or the following nutrients: proteins, carbohydrates, fat, dietary fibre, sodium, vitamins and
minerals—shall constitute mandatory information in the European Union only in cases where a
nutritional claim is advanced on the label or advertising of a prepackaged food. 191 Where such
information is required, statements of energy value and nutrient content shall be grouped
together in a clearly visible place and expressed in figures using specific units of measurement.
Nutrition labelling must be harmonized throughout the European Union. Moreover, Council
Directive 90/496/EEC of 24 September 1990 on nutrition labelling of foods specifies that
“member states shall not introduce nutrition labelling specifications that are more detailed than
those contained in this Directive.”
3.3.5 Nutritional value and health claims
Provided that certain specific conditions are satisfied, Directive 90/496/EEC on nutrition labelling
authorizes nutritional claims on the energy value of foods and on their nutrient content (i.e.
protein, carbohydrates, fat, dietary fibre, sodium, and certain minerals and vitamins).192 A list of
the vitamins and minerals for which nutritional claims may be made can be found in an
Appendix of this Directive. 193
3.3.6 Health claims
Until quite recently, Directive 2000/13/CE on the Labelling, presentation and advertising of
foodstuffs generally prohibited claims which attributed to foods preventative, treatment and
curative properties. However, on 17 October 2006, the European Council approved, upon
second reading, the most recent amendments of a draft regulation on nutrition and health claims
made on foods, more than three years after this proposal was tabled by the European
Parliament and the Council.
“In order to ensure the effective functioning of the internal market whilst providing a high level of
protection,” the draft regulation on nutrition and health claims made regarding foodstuffs 194 aims
in particular to complement the general principles laid down in Directive 2000/13/EC and to
establish specific and harmonized provisions throughout the EU in relation to the making of
190
Ibid.
Europa, “Nutrition labelling,“ <http://europa.eu/scadplus/leg/en/lvb/l21092.htm> (consulted on 2
November 2006).
192
Ibid.
193
EUR-lex, Council Directive 90/496/EEC of 24 September 1990 on nutrition labelling for foodstuffs,
<http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31990L0496:EN:HTML> (consulted on 3
November 2006).
194
EUR-lex, “Proposal for a Regulation of the European Parliament and the Council on nutrition and
health claims made on foods,” <http://eurlex.europa.eu/LexUriServ/site/en/com/2003/com2003_0424en01.pdf> (consulted on 3 November 2006).
191
page
52
nutrition claims. This is to be done through the creation of a list of authorized claims 195 subject to
scientific validation on the part of the European Food Safety Authority (EFSA). 196
The European Union’s future regulatory framework will prohibit all health claims which relate to
slimming or weight control, or make psychological or behavioural claims (for example "reduces
stress"). References to doctors or their associations, and vague claims relating to general
"wellbeing," shall also be prohibited. 197
Figure 5 - EU Organic
agriculture logo
Council Regulation (EEC) No 2092/91 “on organic production of
agricultural products and indications referring thereto in agricultural
products and foodstuffs” enabled consumers to benefit, as early as
1991, from a harmonized framework on labelling for this category of
products. For the purposes of this Regulation—which covers nonprocessed agricultural products (plant and animal), processed
agricultural products (plant and animal) intended for human
consumption, as well as animal feed—the term “organic” or their usual
diminutives (such as bio, eco, etc.), whether they are used alone or
combined, “shall be regarded as indications referring to the organic
production method throughout the Community (...).”198
Only foods of which at least 50% of the ingredients are organically farmed may utilize the
“words, particulars, trade marks, brand names, pictorial matter or symbols” referring to this
method of production. Furthermore, such labelling must clearly refer only to those ingredients
obtained through organic methods of production. 199.
On a voluntary basis, producers may use the logo introduced by the European Commission
bearing the words “Organic Farming” (Figure 5). The utilization of this logo on food packaging
serves to ensure consumers that “at least 95% of the product's ingredients have been
organically produced,” that “the product complies with the rules of the official inspection
195
Ibid. A preliminary list of nutrition claims and the requirements for their utilization is available as an
annex to the draft Regulation of the European Parliament and the Council on nutrition and health claims
made on foods, 2003/0165 (COD).
196
The European Food Safety Authority (EFSA) “will provide scientific advice and scientific and technical
support in all areas impacting on food safety.” Europa, General principles of food law - European Food
Safety Authority - Procedures for food safety, <http://europa.eu/scadplus/leg/en/lvb/f80501.htm SECURITE> (consulted on 2 November 2006).
197
Europa, “Nutrition and health claims in consumer information,”
198
EUR-lex, Council Regulation (EC) No 392/2004 of 24 February 2004 amending Regulation (EEC) No
2092/91 on organic production of agricultural products and indications referring thereto in agricultural
products and foodstuffs, <http://eurlex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexplus!prod!DocNumber&lg=en&type_doc=Regulation&
an_doc=2004&nu_doc=392> (consulted on 3 November 2006).
199
EUR-lex, Council Regulation (EEC) No 2092/91 of 24 June 1991 on organic production of agricultural
products and indications referring thereto on agricultural products and foodstuffs, <http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31991R2092:EN:HTML> (consulted on 3 November
2006).
page
53
scheme” and that “the product has come directly from the producer or preparer in a sealed
package.”200
“Organic agricultural production is a management system designed to produce crops
and livestock in an ecologically stable way. Soil fertility is maintained, animals are raised
in a manner appropriate to their behavioural requirements and synthetic fertilizers and
pesticides are not used. The Regulations would restrict the use of the agricultural
product legend to those products which adhere to these principles.”201
Two complementary regulations, Regulation (EC) No 1829/2003 of the European Parliament
and the Council on “Genetically modified foods and animal feed” and Regulation (EC) No
1830/2003 of the European Parliament and the Council on “The traceability and labelling of
genetically modified organisms (GMOs) and of products derived from GMOs,” stipulate the
mandatory labelling of all foods produced from GMOs or containing GMOs.
Thus, these two regulations require that the labels of foods containing GMOs, whether intended
for animal or human consumption, bear the phrase “This product contains genetically modified
organisms” or “This product is produced from GM (name of organism).” However, due to the
possibility of an “adventitious or technically unavoidable” GMO presence, 202 foods containing
GMOs “in a proportion no higher than 0.9 per cent of the food ingredients considered
individually,” are exempt from this mandatory labelling requirement.203
It should be noted that these labelling requirements apply to all stages of production and
distribution, without distinction between foods of which the DNA (deoxyribonucleic acid) has
been modified and foods containing GMO derived proteins. 204 Consequently, this mandatory
labelling also covers highly refined products, such as oil obtained from genetically modified
maize.
This position of the European Union on the labelling of genetically modified foods is in radical
contrast with the positions of Canada and the United States, which advocate the voluntary
labelling of such foods, or that of the Codex Alimentarius Commission, which has yet to
elaborate standards and guidelines in this regard (see section 2.6.).
200
European Commission, “The organic logo,” in Organic farming,
<http://ec.europa.eu/agriculture/qual/organic/logo/index_en.htm> (consulted on 16 November 2006).
201
Under the current European regulations, the European Union requires that all countries exporting
organic food to the European Union be on an approved third-country equivalency list by December 31,
2006. Canada Gazette, Vol. 140, No 35 — 2 September 2006, Organic Products Regulations,
<http://canadagazette.gc.ca/partI/2006/20060902/html/regle2-e.html> (consulted on 23 October 2006).
202
The presence of GMOs in traditional foods may occur due to the potential for contact between GMO
and non-GMO products during the harvesting, storage, transportation or processing of products.
203
Europa, “GM Food and Feed,” <http://europa.eu/scadplus/leg/en/lvb/l21154.htm> (consulted on 3
November 2006).
204
Europa, “Traceability and labelling of genetically modified organisms (GMOs),”
page
54
Although there is no regulatory framework in the European Union on the labelling of food
products that respect fair trade principles, in July 2006, the European Commission nevertheless
voted in favour of a resolution that, notably, called on member states “to take appropriate
measures to ensure that consumers have access to all the information they need in order to
make informed choices” and to “to liaise with the international fair trade movement (...)”.205
“There are several fair trade labels (...) and each has a certification agency which
verifies all the stages in the production process to ensure that the product respects fair
trade principles. The certification bodies also set the criteria that must be respected in
order for a product to carry a fair trade label. (...) All the labels are members of the FLO
(Fair Trade Labelling Organisations International) which is responsible for coordination
at EU and international level.”206
The European Commission’s support for fair trade fits into the Community's broader objectives
in relation to development cooperation, the fight against poverty, economic and social
development and, in particular, “the gradual integration of developing countries into the world
economy.”207
3.4
Australia/New Zealand
In December 2000, the governments of Australia and New Zealand published a common food
standards regulatory code, the Australia New Zealand Food Standards Code, which defines,
notably, labelling requirements in relation to imported foods and foods intended for sale in these
two countries. 208 Businesses were accorded a two-year transition period for coming into
compliance with the requirements of the new code.
This Code applies in conjunction with Australia’s and New Zealand’s regulations governing
business practices, i.e. the Trade Practices Act 1974209 and the Fair Trading Act 1986, 210
respectively. The purpose of these laws is to protect consumers against fraudulent or
misleading business practices, as well as against false or deceptive representations that may
prove prejudicial to consumers.
205
European Commission,. “Development cooperation,” Bulletin EU 7/8-2006,
<http://europa.eu/bulletin/en/200607/p129001.htm> (consulted on 22 September 2006).
206
Europa, “Fair trade,” <http://europa.eu/scadplus/leg/en/lvb/r12508.htm> (consulted on 3 November
2006).
207
Ibid.
208
Food Standards Australia New Zealand, Australia New Zealand Food Standards Code,
<http://www.foodstandards.gov.au/thecode/foodstandardscode.cfm> (consulted on 6 November 2006).
209
Australasian Legal Information Institute, Trade Practices Act 1974 in Commonwealth of Australia
Consolidated Acts, <http://www.austlii.edu.au/au/legis/cth/consol_act/tpa1974149/> (consulted on 6
November 2006).
210
Government of New Zealand, Fair Trading Act 1986 in Public access to legislation project,
<http://www.legislation.govt.nz/browse_vw.asp?content-set=pal_statutes> (consulted on 6 November
2006).
page
55
3.4.1 General requirements on the labelling of prepackaged foods
As observed in the other countries studied, certain particulars must appear on the labelling of
prepackaged foods sold in Australia and New Zealand:
• name of the food
• lot identification
• minimum durability date
• directions for use or any special storage instructions
• name and address of manufacturer
• the list of ingredients and constituents, 211 (to be designated by their specific name and listed
in descending order of weight), including known allergens. 212
A nutrition facts table is also mandatory on the labelling of foods sold in Australia and New
Zealand. This table must include the following: the total number of servings of the food
contained in the packaging; the size of an average serving; the energy value per serving (in
kilojoules/calories); and the quantity per serving of the following nutrients: protein, total fat,
saturated fat, carbohydrates, sugar and sodium. 213
This mandatory statement of nutritional value is in line with Canadian and American regulatory
provisions, but differs from the framework adopted by the European Union and the Codex
Alimentarius Commission, which permit the voluntary, as opposed to the mandatory, statement
of information on the nutritional value of foods.
Under the Australia New Zealand Food Standards Code if any food or ingredient has been
irradiated this fact must be declared on the food’s packaging. For example, the following
phrases may be used: “Treated with ionising radiation,” “Treated with ionising electrons” or
“Irradiated (name of food).”214
The regulatory provisions of the Australia New Zealand Food Standards Code concerning the
labelling of irradiated foods and ingredients are aligned with those of the European Union and
the Codex Alimentarius. They are more stringent than the provisions under Canadian and
American regulations.
211
Labelling requirements regarding constituents differ from the Codex standards and guidelines, which
only require that ingredients be declared on labels (see section 2.1.1.2.).
212
Food Standards Australia New Zealand, Australia New Zealand Food Standards Code, Part 1.2 Labelling and other Information Requirements, Standard 1.2.3 - Mandatory Warning and Advisory
Statements and Declarations,
<http://www.foodstandards.gov.au/_srcfiles/FSC_1_2_3_Warning_Statements_v85.pdf> (consulted on 6
November 2006).
213
Food Standards Australia New Zealand, Australia New Zealand Food Standards Code, Part 1.2 Labelling and other Information Requirements, Standard 1.2.8 - Nutrition Information Requirements,
<http://www.foodstandards.gov.au/_srcfiles/FSC_Standard_1_2_8_Nutrition_Info_v88.pdf> (consulted on
8 November 2006).
214
Food Standards Australia New Zealand, Australia New Zealand Food Standards Code, Part 1.5 Foods Requiring Pre-Market Clearance, Standard 1.5.3 - Irradiation of Food,
<http://www.foodstandards.gov.au/_srcfiles/FSC_Standard_1_5_3_Irrad_v88.pdf> (consulted on 6
November 2006).
page
56
3.4.2 Claims in relation to food origin
As for food origin information, there are differences between the regulations in the two
countries. The packaging of prepackaged foods sold in Australia must indicate the name of the
country where the food was produced, manufactured, processed or packaged. It is possible to
identify a food that includes imported ingredients as “made in Australia” provided said food
underwent substantial processing in Australia and at least 50% of the total direct costs of
manufacture or production were incurred in that country. 215 The Australian authorities also
require the labels of prepackaged foods to disclose whether a food is composed exclusively of
imported ingredients or of both imported ingredients and Australian ingredients. These
regulatory requirements are in line with those of the Codex Alimentarius Commission.
In contrast, regulations in New Zealand do not require that the country of origin be stated on
food labels. However, the Fair Trading Act of 1986 prohibits labelling practices that could
mislead the consumer regarding the provenance of foods.216
Claims concerning the nutritional value of foods are authorized under the Australia New Zealand
Food Standards Code. This Code specifies the conditions applicable to the making of such
claims, notably as regards the energy value, unsaturated fatty acids (including omega 3-6-9),
salt (sodium)217 and vitamins and minerals 218 contained in foods. When such a claim is made on
a food label, the name and quantity of the nutrients for which the claim is made must appear in
the food’s Nutrition Facts Table.
3.4.4 Health claims
In December 2003, the Australia New Zealand Food Regulation Ministerial Council gave a
favourable welcome to the new guidelines proposed by a scientific advisory committee219
regarding health claims. These guidelines shall serve in the elaboration of regulations governing
health claims that are to be integrated into the Australia New Zealand Food Standards Code.
215
Food Standards Australia New Zealand, Australia New Zealand Food Standards Code, Part 1.2 Labelling and other Information Requirements, Standard 1.2.11 - Country of Origin Requirements,
216
Commerce Commission, “False or misleading representations about goods or services,”
<http://www.comcom.govt.nz/FairTrading/TradePracticesCoveredbytheFairTradingAct/falseormisleadinga
dvertising.aspx> (consulted on 6 November 2006).
217
Food Standards Australia New Zealand, Australia New Zealand Food Standards Code, Part 1.2 Labelling and other Information Requirements, Standard 1.2.8 - Nutrition Information Requirements,
<http://www.foodstandards.gov.au/_srcfiles/FSC_Standard_1_2_8_Nutrition_Info_v88.pdf> (consulted on
8 November 2006).
218
Food Standards Australia New Zealand, Australia New Zealand Food Standards Code, Part 1.3 Substances Added to Food, Standard 1.3.2 - Vitamins and Minerals,
<http://www.foodstandards.gov.au/_srcfiles/FSC_1_3_2_Vits_&_Mins_v85.pdf> (consulted on 8
November 2006).
219
Food Standards Australia New Zealand, “Scientific Advisory Group for the Development of the
Substantiation Framework for Nutrition, Health and Related Claims,” in Food matters,
<http://www.foodstandards.gov.au/foodmatters/healthnutritionandrelatedclaims/scientificadvisorygroup/>
page
57
The present plan is to submit final recommendations on these regulations to the Ministerial
Council for its approval in October 2007. 220
In the meantime, however, certain claims are authorized, notably claims that refer to the
relationships between dietary fibre and intestinal functions, between calcium and healthy bones
and teeth, and the relationship between folic acid and preventing the risk of defects in the neural
tube of new-borns. 221
At the present time, no regulatory framework exists in Australia and New Zealand with respect
to organic production methods or the labelling of organically farmed food products.222 Let’s recall
that the Canadian authorities are presently elaborating a standard along the lines of those in
force in the United States and the European Union, and that the Codex Alimentarius has also
developed standards and guidelines on regulating organic production methods and the labelling
of organic products.
Under the provisions of the Australia New Zealand Food Standards Code, the labelling of
genetically modified foods sold in Australia and New Zealand has been mandatory since 13 May
1999. 223 Under the provisions of this Code, all foods or ingredients obtained using genetic
engineering, whether these underwent DNA modification or whether they contain proteins
derived from genetically modified organisms (GMOs), must bear the phrase “genetically
modified.”224
These labelling requirements for GM foods are similar to the ones in force in the European
Union and are in sharp contrast with the voluntary labelling standards in Canada and the United
States. The Codex Alimentarius Commission has yet to elaborate a standard in this regard.
As with Canada, the United States and the European Union, neither Australia nor New Zealand
has introduced any particular standard to regulate the labelling of foods that respect fair trade
principles. Such products are nonetheless subject to the legislative and regulatory provisions of
the Trade Practices Act 1974 and the Fair Trading Act 1986 with respect to business practices
and the labelling of consumer products. The purpose of these laws is to protect consumers
220
Food Standards Australia New Zealand, “Nutrition, Health and Related Claims” in Food matters,
<http://www.foodstandards.gov.au/foodmatters/healthnutritionandrelatedclaims/> (consulted on 8
November 2006).
221
Food Standards Australia New Zealand, “Nutrition and Health Related Claims,” in Fact sheet 2006,
<http://www.foodstandards.gov.au/newsroom/factsheets/factsheets2006/nutritionhealthandre3396.cfm>
222
E. Lawrence, “Organic food ‘rort,’" Australia's news network, 23 September 2006),
<http://www.news.com.au/couriermail/story/0,,20465250-953,00.html> (consulted on 8 November 2006).
223
Food Standards Australia New Zealand, “Genetically modified or GM Foods,” in Food matters,
<http://www.foodstandards.gov.au/foodmatters/gmfoods/> (consulted on 8 November 2006).
224
Food Standards Australia New Zealand, Australia New Zealand Food Standards Code, Part 1.5 Foods Requiring Pre-Market Clearance, Standard 1.5.2 - Food Produced Using Gene Technology,
<http://www.foodstandards.gov.au/_srcfiles/FSC_Standard_1_5_2_GM_v88.pdf> (consulted on 8
November 2006).
page
58
against fraudulent or misleading business practices, as well as against false or deceptive
representations that may prove prejudicial to consumers.
3.5
Summary of regulatory practices concerning food labelling
Tables 1, 2 and 3, below, summarize food labelling regulations in Canada, the United States,
the EU, Australia and New Zealand as a function of consumers’ present and emerging concerns
in relation to food issues. Table 1 presents the principal regulatory provisions affecting
consumers in terms of their “convenience” related concerns Table 2 does the same for
consumers’ health and nutrition concerns. Finally, Table 3 covers regulations pertaining to a
variety of consumer concerns (health, the environment, and social, cultural, ethical and political
issues).
In each case, national regulations may be compared with the provisions of Codex Alimentarius
standards and guidelines, which constitute a compendium of food standards adopted at the
international level with the aim, notably, of encouraging national authorities to elaborate and
establish harmonized definitions and requirements in relation to foodstuffs. 225
3.5.1 Regulation as a function of consumers’ “convenience” related concerns
As Table 1 shows, Canada has the same regulatory requirements as the other countries studied
in terms of product name and net content particulars. Moreover, these requirements are
consistent with Codex standards and guidelines.
Canada is at the head of the class regarding disclosure of the name and address of the person
or establishment which manufactured or produced a food in that it requires, notably, that the
phrase “importé par/imported by” or “importé pour/imported for” appear before the vendor’s
name and address for a product entirely produced or manufactured outside of Canada.
By only requiring a best-before date on foods that keep for up to three months, Canada is,
however, less stringent than the other countries studied and less stringent than the Codex,
which does require that a date of minimum durability be declared for foods keeping for longer
than three months. The European Union has the strictest regulations in this regard, as it
requires that the year be indicated on the packaging of foodstuffs that may keep longer than 18
months.
This study identified no regulations in Canada requiring directions for the proper use of a food.
This is in contrast with all of the countries studied and with the Codex’s standards and
guidelines where such instructions are mandatory.
Canada has instituted stricter requirements than those prescribed by the Codex regarding the
declaration of ingredients 226 in that it, like the United States, has made the declaration of
constituents a mandatory requirement.
225
The Codex Alimentarius Commission, The Codex Alimentarius Commission and FAO/WHO Food
Standards Programme – Food Labelling - Complete Texts,
<ftp://ftp.fao.org/codex/Publications/Booklets/Labelling/foodlabelling_2005e.pdf> (consulted on 29
September 2006).
226
This information is also found in Table 2, as the list of ingredients may also be useful to consumers
concerned about nutrition and health.
page
59
Overall, Canada ranks average among the countries studied in terms of labelling regulations
concerned with consumers’ “convenience” related concerns.
Table Erreur ! Argument de commutateur inconnu..
Comparison of food labelling regulations as a function of consumers’
“convenience” related concerns
Food labelling regulations
Product
name
Codex
standards/guidelines
Canada
United States
Europe
List of
ingredients
Date of
minimum
durability
Directions
for use
Net content/
drained weight
Name and
address
Mandatory
Mandatory
Mandatory
Mandatory
Mandatory
Mandatory
Equivalent
Superior
Inferior
N/A
Equivalent
Superior
Equivalent
Superior
Equivalent
Equivalent
Equivalent
Equivalent
Equivalent
Equivalent
Superior
Inferior
Equivalent
Inferior
Equivalent
Equivalent
Equivalent
Equivalent
Equivalent
Equivalent
Legend:
Mandatory = rules exist requiring mandatory labelling
Superior = requirements are superior to Codex standards
Inferior = requirements are inferior to Codex standards
Equivalent = requirements are equivalent to Codex standards
3.5.2 Regulation as a function of consumers’ nutrition and health concerns
Table 2 indicates that by and large Canadian regulations are in line with Codex Alimentarius
standards and guidelines. The Nutrition Facts Table is a notable exception in that it is
mandatory in Canada but optional under the provisions of the Codex’s standards and
guidelines. Another difference concerns the declaration of irradiated ingredients.
One will note, however, that Canada is the only country among those studied that allows
exemptions regarding the declaration of the presence of allergenic ingredients and constituents.
In certain cases these need not be declared in the list of ingredients.
If one assumes that Canada will indeed modify its Food and Drug Regulations, as is planned,
and require that the presence of priority allergens be indicated on the labels of prepackaged
foods sold in Canada, 227 one could conclude that Canada’s food labelling policies look relatively
good in terms of satisfying consumers’ nutrition and health concerns.
227
Health Canada intends to propose amendments to the FDR “to enhance labelling requirements for
priority allergens, gluten sources and sulphite in pre-packaged foods sold in Canada.” Health Canada,
“Food Allergy Factsheets,” <http://www.hc-sc.gc.ca/fn-an/securit/allerg/fs-if/index_e.html> (consulted on
13 October 2006).
page
60
Table 2.
Comparison of food labelling regulations as a function of consumers’ nutrition and
health concerns
Energy
value
information
Codex
Canada
United States
Europe
List of
ingredients
Nutrition facts
table
1
Declaration of
allergenic
ingredients
Nutrition
claims
Health
claims
Mandatory
Mandatory
Permitted
Mandatory
Permitted
Permitted
Equivalent
Superior
Mandatory
Inferior
Equivalent
Equivalent
Equivalent
Superior
Mandatory
Equivalent
Equivalent
Equivalent
Equivalent
Equivalent
Equivalent
Equivalent
Equivalent
2
Permitted
Equivalent
Superior
Mandatory
Equivalent
Equivalent
Equivalent
Legend:
Permitted = labelling is permitted provided that certain standards are respected
1
2
Mandatory, when a nutrition claim is made for a food or its constituents.
A draft regulation on nutrition and health claims in relation to foods was approved by the European Council on 17 October 2006.
3.5.3 Regulation as a function of diverse consumer concerns (health issues, the
environment, and social, cultural, ethical, political issues)
Table 3 covers food labelling regulations in relation to a variety of consumer concerns.
Concerning the provenance of foods and the use of claims such as “fresh,” “natural” et al,
Canadian regulatory measures are in line with those of the United States and with the standards
and guidelines of the Codex Alimentarius Commission. The EU and Australia/New Zealand do
not directly regulate these types of claims.
However, concerning the labelling of organically farmed foods, although Canada does follow the
Codex standards and guidelines, it ranks behind the United States and the European Union.
This is a situation that Canada must soon remedy if it wishes 1) to maintain its market share in
the exporting of organic foods to European countries and 2) ensure that consumers are
adequately informed in this regard.
Concerning the labelling of genetically modified (GM) foods, Canada has adopted the same
position as the United States. To date, it has preferred to maintain a voluntary labelling standard
rather than impose mandatory labelling, as the European Union, Australia and New Zealand
have done. Moreover, Canada and the United States, which are both major producers of GMOs,
are continuing their fierce opposition in Codex meetings to block progress towards the adoption
of an international standard. It’s worth noting that for the last several years numerous public
opinion polls have indicated that Canadians want their governments to adopt mandatory
labelling of GM foods.
As for the labelling of irradiated foods and ingredients, the Canadian government only requires
labelling in cases where the entire food was irradiated or when the irradiated ingredients of a
food not irradiated in its entirety constitute over 10% of said food. The United States requires
labelling for foods that have been totally irradiated, but not for a food’s irradiated ingredients. As
for the Codex standards and guidelines, they recommend the labelling of all irradiated foods
page
61
and ingredients. The authorities in the European Union, Australia and New Zealand have
adopted regulatory provisions along those lines.
Whether one looks at the Codex standards and guidelines or the regulations of the countries
studied, no provisions exist on labelling requirements for foods that respect fair trade principles.
Finally, the United States is alone in offering a form of certification and labelling that enables the
identification, on a case by case basis, of certain foods originating from animals that had the
benefit of being raised under certain conditions.
Canada’s performance, then, does not rank highly when it comes to the disclosure of the
information required by consumers in relation to a variety of concerns, from health issues, to the
environment and other matters of a social, cultural, ethical and political character.
Table 3.
Comparison of food labelling regulations as a function of diverse consumer concerns
(health issues, the environment, and social, cultural, ethical, political issues)
Codex
Canada
United States
Europe
Australia/N. Zealand
Country
of origin
Mandatory
Permitted
N/A
Mandatory
N/A
N/A
Permitted
Equivalent
Equivalent
Permitted
Inferior
N/A
N/A
Equivalent
Inferior
Mandatory
Permitted
Inferior
N/A
Permitted
Inferior
Mandatory
Mandatory
Equivalent
N/A
N/A
Equivalent
2
N/A
N/A
Mandatory
Equivalent
N/A
N/A
N/A
3
Equivalent
1
Genetically
modified foods
Irradiated
foods/
ingredients
Fair trade
foods
Claims on
livestock
techniques
Other logos
and claims
Organically
farmed
foods
(fresh, natural,
etc.)
Legend:
Permitted = labelling is permitted provided that certain standards are respected
N/A = no regulations
1
Labelling of organically farmed foods is regulated in two provinces: Quebec and British Columbia.
Certain member states, including France and the UK, have elaborated their own regulatory framework regarding certain of these
claims.
3
The country of origin must be declared in Australia but not in New Zealand.
2
page
62
4.
OVERVIEW OF INITIATIVES IN SUPPORT OF LABELLING POLICIES
This section presents a brief portrait of the diverse initiatives put forward by the governmental
authorities of the countries studied in support of their labelling policies, particularly those aimed
at properly informing consumers and facilitating the comprehension and use of food labelling.
4.1
Canada
As part of a comprehensive, long term, multisectoral education initiative aimed at effectively
introducing and communicating the new nutrition labelling system to Canadians, Health Canada
has developed an education strategy based on research and the segmentation of the public into
target groups. This initiative, which shall use information exchange and research tracking “to
evaluate progress, monitor efforts and refine approaches,” aims to:
• increase awareness of the new nutrition label and its key features among intermediaries and
consumers,
• build skills in reading the label information, and
• enable consumers to apply label-reading skills to choosing a diet for healthy eating.228
Health Canada’s strategy takes into account the diverse needs, concerns and priorities of
different segments of the population and opts for a targeted approach by breaking down the
population in accordance with “physical, behavioural, demographic and psychographic
factors.”229 There are two main categories of target audiences: sub-groups among the general
public (i.e. consumers) and sub-groups among the intermediaries who deliver nutrition labelling
information to consumers (e.g. professionals in the food and nutrition fields, consumer relations
professionals in supermarkets).
“Channels and materials should be tailored for each target audience segment. The
traditional channels include mass media (radio, television, print, Internet), individuals
(health care system and providers), groups (educational system, worksites, recreation
facilities) and organizations (supermarkets, restaurants, government services).
Combinations of channels, adapted specifically to the nutrition labelling education
initiative, are most likely to be effective.”230
Health Canada has developed ”nutrition labelling toolkits” for use by Canadian Food Inspection
Agency (CFIA) inspectors, manufacturers, importers and distributors of food products,
consultants 231 and educators. The kit aimed at teachers includes multimedia documents, such
as a series of factsheets with talking points “designed to help communicate consistent, accurate
228
Health Canada, “Nutrition Labelling: A Strategic Framework for Public Education,” in Food and
Nutrition, <http://www.hc-sc.gc.ca/fn-an/label-etiquet/nutrition/education/backgrcadre/strat_framework_entire-cadre_strat_entier-exec_e.html> (consulted on 13 November 2006).
229
Ibid.
230
Ibid.
231
“The Nutrition Labelling Toolkit provides guidance on the interpretation of the nutrition labelling
requirements under the Food and Drug Regulations. “ Canadian Food Inspection Agency (CFIA),
Nutrition Labelling Toolkit, <http://www.inspection.gc.ca/english/fssa/labeti/nutrikit/nutrikite.shtml>
page
63
messages to Canadians,” a ready-to-use slide presentation on nutrition labelling, a series of
questions and answers, and a kit evaluation form. 232
As for the general public, it may access certain electronic resources on Health Canada’s
website, including a downloadable tin can bearing a Nutrition Facts Table, 233 a downloadable
supermarket cart full of food items, each with its own Nutrition Facts Table234 (paper versions of
these posters are also available from Health Canada).
In the longer run, Health Canada planned to integrate nutrition information into broader
programs on healthy diets and active living. Furthermore, it intends to evaluate and improve
existing programs and materials, as well as effect a “periodic review of labelling policy”235 to
verify the raison d'être, effectiveness and pertinence of the theory, strategies and tactics
underlying the project (which includes assessing the messages and materials used).
Moreover, Industry Canada’s Office of Consumer Affairs is a participant in Health Canada’s
multisectoral education initiative. It website, the “Canadian Consumer Information Gateway,”
includes certain information intended for consumers on nutrition labelling.236
Certain provincial governments are also doing their part to raise consumer awareness regarding
the changes in nutritional labelling. This is the case for Ontario237 and Quebec which, via the
Office de la protection du consommateur notably, helps young people understand lists of
ingredients238 and manufacturers’ claims. 239
232
Health Canada, “Nutrition Labelling Toolkit for Educators,” in Food and Nutrition, <http://www.hcsc.gc.ca/fn-an/label-etiquet/nutrition/education/nurtri-kit-trousse/toolkit_educ-trousse_educ_e.html>
233
Health Canada, “Consumer Resources - Poster 1 – Can,” in Food and Nutrition,
<http://www.hc-sc.gc.ca/fn-an/label-etiquet/nutrition/education/cons-res/cr_poster_cancr_affiche_conserve_e.html> (consulted on 13 November 2006).
234
Health Canada, “Consumer Resources - Poster 2 – Cart,” in Food and Nutrition,
<http://www.hc-sc.gc.ca/fn-an/label-etiquet/nutrition/education/cons-res/cr_poster_cartcr_affiche_panier_e.html> (consulted on 13 November 2006).
235
Nutrition, <http://www.hc-sc.gc.ca/fn-an/label-etiquet/nutrition/education/backgrcadre/strat_framework_entire-cadre_strat_entier-exec_e.html - 3> (consulted on 13 November 2006).
236
Canadian Consumer Information Gateway, “Food Labelling.”
<http://consumerinformation.ca/app/oca/ccig/consumerChallenge.do;jsessionid=0000eyezK0gl0tDAmekR
K7HbNxV:1?province=1%2C2&province=1%2C3&province=1%2C4&province=1%2C5&province=1%2C6&province
=1%2C8&province=1%2C7&province=1%2C13&topic=CAT4.TOPICS.ROOT&consumerChallengeNo=26
6&text=&language=eng > (consulted on 13 November 2006).
237
HealthyOntario.com, “Decoding the New Nutrition Label” in EatRight Ontario,
<http://www.healthyontario.com/EatRight_Ontario/Healthy_Eating/Decoding_the_New_Nutrition_Label.ht
m> (consulted on 13 November 2006).
238
Office de la protection du consommateur (OPC), “Les étiquettes alimentaires” in Logomanie,
<http://www.opc.gouv.qc.ca/jeunesse/service/affiche.asp?page=logomanie_aliment&section=service>
239
Office de la protection du consommateur (OPC), “Les allégations des fabricants” Logomanie,
http://www.opc.gouv.qc.ca/jeunesse/service/affiche.asp?page=logomanie_fabricants&section=logomanie
> (consulted on 13 November 2006).
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64
4.2
United States
In the U.S., the Center for Food Safety and Applied Nutrition (CFSAN) has put general
information on-line, along with several educational tools, with a view to enabling American
citizens to better understand and utilize nutrition labelling. Their website includes, notably,
information on how to use nutrition labelling to watch one’s weight, a series of questions and
answers, a video presentation, a kit intended for high school teachers, high resolution
downloadable images, information on authorized claims, and a quiz allowing consumers to test
their knowledge on nutrition. 240
Furthermore, consumers wishing to stay up to date on nutrition labelling may subscribe to an
electronic newsletter on the CFSAN website.
4.3
The European Union
There are presently no EU programs to support labelling policies due, notably, to the fact that
EU regulations on nutrition and health claims have not been finalized and also because the
Nutrition Facts Table is optional, except in cases where a nutrition claim is made on a food’s
label.
Clear and pertinent consumer information is nevertheless a priority for the European
Commission, which is presently exploring a variety of possible strategies aimed at effectively
communicating such information to consumers and on making labels easy to understand and
use. 241
4.4
At the present time no education strategy exists in either Australia or New Zealand with the aim
of helping consumers to really understand and properly use the new nutrition labelling regime
introduced in December 2000 by the Australia New Zealand Food Regulation Ministerial
Council.
That said, the Australia New Zealand Food Authority (ANZFA) plans to facilitate and coordinate
the development of programs and educational tools in close collaboration with nongovernmental organizations in order to, notably, determine priorities, strategies and the
resources available for the elaboration of effective programs. These diverse initiatives will aim,
in particular, to reduce the confusion that may reign among consumers following changes made
in regulations and facilitate consumers’ comprehension of nutrition labelling. 242
240
US Food and Drug Administration (USFDA) - Center for Food Safety and Applied Nutrition (CFSAN),
“Food Label Education Tools and General Information” in Food Labelling Nutrition,
<http://www.cfsan.fda.gov/~dms/lab-gen.html> (consulted on 16 November 2006).
241
European Commission - Health and Consumer Protection Directorate-General, “Ten Key Facts about
Nutrition and Obesity,”
<http://ec.europa.eu/health/ph_determinants/life_style/nutrition/documents/10keyfacts_nut_obe.pdf>
242
Food Standards Australia New Zealand, “ANZFA' s Role in Health Promotion” in Education,
<http://www.foodstandards.gov.au/newsroom/publications/anzfasroleinhealthpromotion/executivesummar
y/education.cfm> (consulted on 16 November 2006).
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65
5. SURVEY ON FOOD LABELLING
5.1
Objectives and Methodology
As part of this project, Union des consommateurs elaborated a survey on food labelling in order
to 1) better identify consumers’ needs and consumer trends concerning information on the foods
they purchase and 2) determine consumers’ knowledge and use of the food labelling presently
in use in Canada. Before circulating the survey, we submitted it to Ms. Marie Marquis, a
nutritionist and associate professor at the University of Montreal’s Nutrition Department, for her
comments. Ms. Marquis, who was referred to us by l’Ordre professionnel des diététistes du
Québec, graciously complied with our request. Most of her comments and suggested changes
were integrated into the final version of the survey.
As our survey sought more to open avenues for reflection than to offer a statistical portrait, we
opted, for practical as well as monetary reasons, to conduct an on-line survey with a
convenience sample.
We solicited, via a personalized e-mail,243 the participation of the adult in the household who
usually did the grocery shopping. In cases where this task was shared by more than one adult,
we requested that just one of them answer the survey questionnaire. A total of 3,238
respondents participated in the survey.
Our survey was administered in two stages: first, via invitations sent by Union des
consommateurs and its members, and then, via an invitation made on “L’épicerie,” a French
language program specializing on food issues that is broadcast across Canada on public
television.
This first invitation was made by e-mail to Union des consommateurs’ 10,000 subscribers. In
addition, Union des consommateurs’ member groups 244 were asked to relay this invitation to
their own members and subscribers. A total of 1,179 persons participated in this stage of the
survey between October 25 and November 17, 2006
For purposes of concision, we shall henceforth speak of the “Union survey” when referring to
this initial stage.
In order to diversify its pool of respondents, Union des consommateurs solicited the
collaboration of several groups and organizations we thought might be willing to circulate our
survey. The people in charge of the television program L'épicerie agreed to propose the survey
to their subscribers who number about 17,000 and are from every part of the country. This
second stage of the survey was launched on December 6, 2006. The response was immediate
and massive—the number of respondents rapidly exceeded the total number in the first stage.
243
The letter of invitation sent to the members of the Union des consommateurs’ mailing list has been
enclosed in Appendix 1.
244
Union des consommateurs’ membership includes ten ACEFs (Associations coopératives d’économie
familiale), which are organizations constituted under the provisions of The Cooperatives Act, l’Association
des consommateurs pour la qualité dans la construction (ACQC) as well as individual members.
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66
From the third day on, the response fell rapidly. As a result, this stage of the survey was brought
to a close on December 11, after 2,060 persons had responded.
For purposes of concision, we shall henceforth speak of the “Épicerie survey” when referring to
this second stage of the survey.
The results obtained during the survey’s two stages were integrated for analysis purposes.
Whenever notable differences could be observed between the two groups, these differences
were raised and possible explanations mooted.
The survey questionnaire
Our survey was comprised of 16 questions, including 13 multiple-choice questions and three
open-ended questions (#13, 15 and 16). The multiple-choice questions all appeared in random
order. Two questions offered respondents the opportunity to specify a choice other than the preselected choices (questions 9 and 10).
In addition to the nine (9) survey questions per se another nine questions were included to
establish a respondent’s socio-economic profile.
Our survey was divided into six (6) sections.
The first three sections were each composed of a single question.
The first section sought to determine the relative importance of the different factors influencing a
consumer’s decision whether to buy an unknown product. The 14 possible answers addressed
elements related to price and marketing considerations as well as the concerns related to the
labelling issues examined by our study (e.g. organic or fair trade products, quality and origin of
ingredients, convenience)
The second section sought to determine consumers’ label consulting behaviour when
purchasing an unknown product.
The third section sought to determine how frequently respondents consulted eleven (11)
different elements included in a food label. With two exceptions, the choices proposed were all
mandatory items on food labels in Canada (weight, calories, salt, sugar and fat content, list of
ingredients, nutritional value, best-before date, and place of manufacture). The other choices
concerned directions for use (mandatory according to Codex standards and in the other
countries studied) and statements on the natural origin of ingredients (certain such statements
being restricted in Canada, as well as according to the Codex).
The fourth section, which included four (4) questions, sought to determine the respondents’
degree of awareness around food information issues. Questions 5 and 6 asked respondents
about their perceptions regarding changes in the available food information over the last two
years, i.e. since food labelling had to be in compliance with the 2003 amendments to the FDR.
The first question asked if they considered themselves to be well informed and the fourth
question asked whether food labels were easy to understand.
The fifth section included seven (7) questions on the Nutrition Facts Table, which is mandatory
on the labels of food products. An illustration of a Nutrition Facts Table was included in this
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section. The questions in this section aimed to determine respondents’ perceptions on the
usefulness of such a table, their degree of knowledge and sources of information concerning
such tables and, finally their utilization of same. The first question in this section (#8) aimed to
determine whether respondents really made use of such tables. The last question (#13) asked
respondents for their comments on the Nutrition Facts Table.
The sixth and final section was composed of three questions. The first question (#14) listed 22
elements that could potentially appear on food labels, including the elements examined in our
comparative analysis grids (see Tables 1 to 3, pages 57-59). We asked our respondents
whether they considered it important to be well informed regarding these various elements and
whether they thought they were in fact well informed. The following question was an openended question asking respondents to mention other elements not appearing in our list that they
considered important and for which they desired improved labelling rules. The final question
(#16) asked respondents for their general comments on the subject of food labelling.
The survey questionnaire and the survey results may be found in Appendix 2.
5.2
Profile of respondents
To better interpret the results of the two surveys it is important to describe the socioeconomic
profile of our respondents.
Some respondents did not complete the section where they were asked to provide information
on their socioeconomic status: 18% of the respondents to the Union survey did not provide this
information, as opposed to 10% of the Épicerie survey who failed to do so.
Among those who did provide this information, the majority (69%) were women. 56.4% of
respondents to the Union survey were women compared to 76.3% of their Épicerie
counterparts.
Respondents were between 15 and 82 years of age. The majority in both surveys were between
40 and 60 years of age (21% of respondents were 40 to 49 and 33% were 50 to 59). However,
the proportions of respondents in the other age brackets were not the same in both surveys.
Thus, in the Union survey, less than 10% were under 30, 22% were under 40 and 22% were
older than 60. In contrast, in the Épicerie survey the over 60 bracket was less than 10%, the
under 40 bracket was nearly 40% and the under 30 cohort accounted for 18% of respondents.
Nearly the same proportion of respondents, i.e. 32%, had completed a college diploma as those
with a BA. 53% of respondents to the Épicerie survey had completed a BA or an MA, as
opposed to 38% for the Union survey.
Half of the respondents declared annual incomes between $30,000 and $70,000 (the
percentage of each $10,000 bracket progressively falling from 13% to 11%) and 26% of
respondents declared incomes between $30,000 and $50,000. Only 15% of respondents
declared an annual income under $30,000. 23% of respondents were in the $70,000 to
$100,000 bracket. A noteworthy fact: in both groups 7% more respondents declined to provide
this information than declined to answer the other questions in the socioeconomic section.
28% of respondents declared that a member of their household had to follow a special diet due
to a medical condition.
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5.3
Highlights and analysis of survey results
71.1% of respondents consider themselves quite well informed on nutrition and 19.9% consider
themselves very well informed.
Among the factors apt to influence the decision to purchase an unknown product, 95% of
respondents cited the quality of the ingredients, the product’s nutritional qualities and the
quality/price ratio as the most important factors. Whereas, 52% of respondents who consider
themselves very well informed on nutrition issues consider organic certification to one of the
important factors influencing purchasing decisions, just 31% of not very-informed or uninformed
respondents hold this same opinion.
When it comes to purchasing an unknown product, 89.1% of respondents check the label
(56.2% always do, 32.9% often do). As for the Nutrition Facts Table, 80.5% of respondents
always or often consult it.
When examining the label of any prepackaged food, respondents mainly look for the bestbefore date (often or always: 92%), the amount and types of fat (83%), information on nutritional
value (80%) and the list of ingredients (80%).
Very few respondents, i.e. just 1.7%, stated that they did not know the purpose of the table. The
percentage of those who didn’t know how to use the Nutrition Facts Table was 3.3%. The table
appeared very useful to 78.7% of respondents. However, 28.4% of respondents found the
information contained there not easy to understand.
The open-ended questions elicited a number of comments and criticisms, including: the
absence of uniformity in serving sizes makes it difficult to compare the nutritional value of
different but similar foods; the tolerance of claims on the so-called absence of certain
ingredients; the size of the lettering used in labelling; and the desire, reiterated by some, to
institute mandatory labelling of genetically modified foods.
Although respondents’ information needs regarding the different elements subject to existing
labelling regulations seem, with a few rare exceptions, relatively well served, respondents
expressed the need to obtain clear information on elements pertaining to social concerns.
These latter may be related to the environment or to cultural, ethical and political issues, such
as: the use of antibiotics, hormones, chemical fertilizers or pesticides; GMOs; working
conditions; environmental considerations; animal feed; organic farming; and fair trade.
Moreover, the regulation of nutrition and health claims—and that of health warnings on the
effects of certain ingredients—also fails to satisfy the information needs of respondents.
5.3.1 Influential factors in buying decisions
245
Survey participants answered that the quality of the ingredients, the product’s nutritional
qualities and the price/quality ratio were, by far, the three most important factors likely to
influence the decision on whether to purchase an unknown food product (influential or very
245
Question 1, see Appendix 2 for details on the responses.
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69
influential for about 95% of respondents). Ease of preparation came in fourth among the factors
influencing respondents’ purchasing decisions.
These results may be compared with the results obtained by the National Institute of Nutrition
(NIN) in a survey conducted in 2001, which revealed that “almost nine in ten (88%) Canadians
said nutrition is an important (‘extremely,’ ‘very’ or ‘quite’ important) consideration for choosing
the food they eat.”246 A NIN study conducted in 1999 revealed that “90% view nutrition as
extremely, very or quite important in the selection of foods.”247
One will note that while the first two factors (the quality of the ingredients and the nutritional
quality) are directly linked to consumers’ nutrition and health concerns, the third factor (the
price/quality ratio) would appear mainly related to monetary concerns and the fourth factor
(ease of preparation) has to do with “convenience.” A report prepared by Agri-Food Canada
(AAFC) concluded in 2005 that health and convenience are now the principal factors influencing
consumers’ food purchasing decisions. 248
It would seem that knowledge in nutrition issues has an impact on the importance of organic
certification as a factor in respondents’ decision to buy an unknown food. In effect, although
organic certification is in general relatively unimportant to most respondents, the more
respondents know about nutrition, the more such certification gains in importance. While 52% of
“very well-informed” respondents deem this an important criteria and 40% of “well informed”
respondents agree, only 32% of “not very well” informed and “not informed at all” respondents
cite this as an important element in their purchasing decisions.
The same trend may be observed regarding the importance accorded to the geographical origin
of a food product: the more knowledgeable a respondent is on food issues, the greater the
importance attributed to a product’s origin when it comes to purchasing decisions regarding
unknown products (63% in the case of very well-informed respondents). There is, however, a
discrepancy between the two survey groups: whereas, 42% of very well-informed Union
respondents consider product origin a very important consideration, just 25% of their Épicerie
counterparts concur.
Certain factors might offer clues that could explain these odd results. It’s possible that the
respondents to the Union survey have a more comprehensive view of consumer issues, which
would lead them to pay more attention to the provenance of the food they consume. On the
other had, one could wonder whether the Épicerie respondents aren’t perhaps better informed
regarding the laxness of Canadian regulations on food origin labelling requirements; such
awareness could certainly lead them to attribute less importance to this element of labelling.
Let’s recall that for a product with ingredients produced abroad to be labelled “made in Canada,”
said product need only satisfy two conditions: it underwent substantial processing249 in Canada
246
The primary source of this information was the National Institute of Nutrition’s 2001 survey entitled
Tracking Nutrition Trends. Health Canada, “What Do Canadians Think about Nutrition?” <http://www.hcsc.gc.ca/fn-an/alt_formats/hpfb-dgpsa/pdf/surveill/factsheet_canada_thinksdossier_canada_pense_e.pdf> (consulted on 1 May 2007).
247
National Institute of Nutrition, Nutrition Labelling: Perceptions and Preferences of Canadians (1999),
<http://dsp-psd.communication.gc.ca/Collection/H49-139-1999F.pdf> (consulted on 1 May 2007).
248
Agriculture and Agri-Food Canada (AAFC), “What's Hot and What's Not in the Canadian Food Market
2005,” < http://www4.agr.gc.ca/AAFC-AAC/display-afficher.do?id=1170954034728&lang=e> (consulted
249
A transformation is said to be substantial when the form, appearance or nature of a food product has
been fundamentally modified, such that “the goods existing after the change are new and different goods
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and over 50% of its total direct manufacturing or production costs are Canadian (see section
3.1.3.).
5.3.2
The label
250
90% of respondents say that they often (26%) or always (64%) consult the product label when
deciding whether to buy a food product they don’t know. A tiny 0.5% confess that they never
check the label. As for respondents who state that certain members of their household must
follow a special diet due to a health problem, 71% always check the food label.
When respondents check the label of any prepackaged food, the information they most often
look for are the best-before date (92% of respondents say they often or always look for this
information), fat content and type of fat (83% of respondents), information on nutritional value
(80%) and the list of ingredients (80%). Although one may classify the best-before date as
pertaining to consumers’ “convenience” related concerns, information on fat content and type of
fat, information on nutritional value, as well as, presumably, the list of ingredients all address
nutrition and health concerns.
As for respondents who state that certain members of their household must follow a special diet
due to a health problem, they mainly check the same information as respondents in general.
One does note, however, that regarding the list of ingredients, nutritional value and fat content,
8% more of these respondents check this information than do respondents in general, and 13%
more check the salt/sodium content.
The information that respondents seem least anxious to check is the food’s place of production,
a piece of information that pertains more to the environment and social, cultural and political
issues. Only 44% of respondents say they often or always look for this information even though
58% affirm that the food’s place of origin is a quite important or very important factor when
selecting a food new to them (see question 1). The older the respondent, the more he tends to
verify where the food was produced when examining the label (see the “age effect” on the
answers to question 3 in Appendix 2). More than 50% of respondents over 50 look for this
information, compared to 33% of respondents aged 30 to 39 and a tad less than a quarter (i.e.
24%) of respondents under 30.
5.3.3
Food information
251
A very high proportion of respondents (91%) deem themselves in possession of an appropriate
level of knowledge on food and dietary issues. Whereas, only 8.9% consider themselves not
well informed, 71.1% deem themselves quite well informed and 19.9% very well informed.
According to Health Canada, “in 2001, about three in ten Canadians (28%) considered
themselves to be ‘very’ knowledgeable about food and nutrition compared to their friends and
family.” 252
from those existing before the change.” Competition Bureau, “Guide to ‘Made in Canada’ Claims,”
2006).
250
See question 2 and 3, in Appendix 2, for details on the answers given.
251
See questions 4, 5, 6 and 7, in Appendix 2, for details on the answers given.
252
Health Canada, “What do Canadians know about nutrition?” http://www.hc-sc.gc.ca/fnan/surveill/facts-faits/factsheet_canada_knows-dossier_canada_connait_e.html (consulted on 1 May
2007).
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71
Nearly six of ten respondents (59.4%) say they are more concerned about information on the
food products they buy than they were two years ago. Those respondents who consider
themselves less well informed about nutrition are also the most concerned about information on
the food products they buy. In effect, over 70% of the poorly informed or uninformed
respondents on nutrition issues say they are more concerned than they were two years ago. In
comparison, less than half (i.e. 49.6%) of those who say they are very well informed and 60.8 of
the well informed are more concerned than they were two years ago.
Moreover, 71% of respondents deem the information on food labels generally easy to
understand. One does, however, observe a difference between the Union survey respondents
and their Épicerie counterparts, as 65.8% of the former hold this opinion compared with 73.9%
of the latter. This difference may certainly be attributed to the fact that 23.5% of the Épicerie
respondents say they are very well informed on nutrition compared with 13.5% of Union
respondents who say the same—a 10% gap. Moreover, overall 94% of Épicerie respondents
claim to be either “well” or “very well” informed, compared to only 86% of their Union survey
counterparts.
The respondents who state that certain members of their household must follow a special diet
due to a health problem are more concerned than average (62%) and are less likely (68%) to
deem this information easy to understand.
Let’s note that 64.2% of respondents believe that they have more information on food products
than they did two years ago.
5.3.4
The Nutrition Facts Table
253
More than eight of every ten respondents (80.5%) often or always look at the Nutrition Facts
Table when deciding whether to buy a food product they don’t know. Of this number, over half
(52%) say they always consult this table. The percentage climbs to 58% in households where
someone follows a special diet for health reasons. Only 1% of respondents admit that they
never check the Nutrition Facts Table.
In its 1999 study, the National Institute of Nutrition reported that 70% state that they consult
often or occasionally the Nutrition Facts Table, 254 as opposed to 12% who stated that they never
consult it. Incidentally, our survey, more precisely, asked how often respondents consulted it
when buying an unknown product.
Over half of the respondents (56%) affirmed that they learned by themselves the purpose of the
Nutrition Facts Table. Just 10.5% stated that they learned this through Health Canada—almost
the same proportion (10.3%) who learned it through an educational institution. Nearly a quarter
of respondents (23.7%) learned what the table’s purpose was from a health or nutrition
professional. Very few respondents (i.e. only 1.7%) admitted to not knowing the table’s purpose
As for using the Nutrition Facts Table, over half of the respondents (54.7%) reported that they
learned how to use the table by themselves. Another 9.4% learned how to use it through an
educational institution, while just 8.1% learned this through Health Canada. Nearly a quarter of
respondents (24.8%) learned how to use the table with the assistance of a health or nutrition
253
254
See questions 8 to 13 in Appendix 2 for the answers in detail.
Op.cit. 250.
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professional. A small proportion of respondents, i.e. 3.3%, affirmed that they didn’t know how to
use the Nutrition Facts Table. One should note, however, that this is twice the proportion of
respondents who were unaware of the table’s purpose.
Given the rather small number of respondents who affirm that they learned the purpose of the
Nutrition Facts Table and how to use it through Health Canada, a superficial analysis could
suggest that Health Canada’s education strategy in nutrition labelling leaves much to be
desired. One needs to consider, however, that this strategy—which aims 1) to increase
consumer awareness of the new nutrition label and its key features, and 2) enable consumers to
use the information on labels—does not concentrate exclusively on direct information to the
consumer. This strategy in fact also uses a variety of channels to communicate its educational
materials (the media, health and nutrition professionals, education systems, government
departments, etc.). 255 It is therefore difficult to assess on the basis of our survey’s results the
number of respondents reached, directly or indirectly, by Health Canada’s strategy, as a large
proportion may well have been informed by these very third parties towards which part of Health
Canada’s promotional efforts are directed.
Over three quarters of respondents (78.7%) see the Table as very useful (this rises to 83% in
households where a special diet is followed due to health issues) and more than seven in ten
respondents (71.6%) consider the information in the Table generally easy to understand. While
these results may tend to explain how such a large proportion of respondents taught themselves
how to use the Nutrition Facts Table, they nonetheless reveal that a significant fraction, i.e.
28.4%, consider the Table generally difficult to understand.
Let’s note that, in its 1999 survey, the National Institute of Nutrition reported that 83% affirmed
that they understood quite well the information provided by that era’s version of the Nutrition
Facts Table, including 43% who deemed that they understood it very well. 256 The same report
found that “Canadians with diabetes express a lower level of understanding of the label
information than the general population, but higher levels of interest in nutrition and use of the
nutrition information panel.” It added, furthermore, that “Canadians with heart disease react in a
similar manner as the general population, but perceive themselves to have lower levels of
understanding of the panel information.” The respondents to our survey who stated that a
member of their household had to follow a special diet for health reasons did not, however,
indicate any significant difference on this issue compared to respondents as a whole in that 70%
of them deemed the Table’s information easy to understand.
Additional comments from respondents
We asked respondents if they had any additional comments regarding the Nutrition Facts Table.
Several of the some 300 comments offered addressed the absence of uniform serving sizes,
which makes it difficult for them to compare the nutritional value of similar foods. Already in
1999, the respondents to the National Institute of Nutrition stated that the “lack of use and
understanding of serving size information emerges as a barrier to the correct usage of panel
information.”257.
255
Health Canada, Nutrition Labelling: A Strategic Framework for Public Education, in Food and Nutrition,
<http://www.hc-sc.gc.ca/fn-an/label-etiquet/nutrition/education/backgr-cadre/strat_framework_entirecadre_strat_entier-exec_e.html - 3> (consulted on 13 November 2006).
256
Op.cit. 250.
257
Ibid.
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Others deplored the excessive “administrative tolerance” regarding certain nutrients for which it
is permitted to make claims such as “does not contain” when in reality the product does contain
the nutrient in question. This “tolerance” gives a false impression and may present “a danger
when several servings are consumed.”
Respondents also questioned the use of percentages regarding the daily-recommended intake
of nutrients. Several would prefer that this information be given in terms of quantities, i.e. in
grams or in millilitres, along with the recommended daily limit. Furthermore, certain respondents
mentioned that the utilization of the percentage of daily recommended intake does not have the
same meaning for them when applied to a nutrient desirable for good health and which
represents an objective to attain (e.g. dietary fibre or vitamins) as opposed to when applied to
nutrients which one must avoid consuming beyond a certain limit (e.g. sodium or saturated and
trans fats). Several respondents, moreover, expressed their wish to see a distinction made
between nutrients and ingredients that are good for health and those that are harmful (for
example good vs. bad fats). To this end, some suggested the adoption of a colour code, others
the presence of two distinct columns or health warnings on harmful nutrients and ingredients.
Several respondents reiterated their desire to see the explicit labelling of genetically modified
foods.
Moreover, a significant number of respondents mention their lack of confidence in labelling as it
presently exists, asserting that it was deliberately designed to confuse consumers and that it
served more as a marketing vehicle to increase the profits of agri-food companies than as a tool
to properly inform consumers.
Finally, certain respondents expressed their unhappiness with the lettering used in the Nutrition
Facts Table and the list of ingredients, which they consider too small.
The ideal label
258
According to respondents, the information easiest to find and understand on the labels of
prepackaged foods is the sugar, fat and salt content (more than 90% of the respondents
consider it easy or fairly easy). In contrast, respondents deem that the hardest information to
find and understand concerns: livestock production conditions (94,4%), working conditions
(93,5%), food irradiation (86,3%), use of antibiotics or hormones (93,2%), chemical fertilizers or
pesticides (91,4%), and whether or not genetically modified organisms GMOs are present
(84,2%).
Over 75% of respondents consider it very important to be informed regarding: the presence of
allergenic ingredients; the presence or absence of certain types of fat; sugar, fat and salt
content; health warnings on the effects of certain ingredients; and the use of chemical fertilizers,
pesticides, antibiotics or hormones.
All of the issues listed in question 14 are, for the majority of respondents, considered elements
about which it is very important to be well informed, with the exception of the “Guarantee that
the product distinguishes itself on an ecological point of view’” and the ” Controlled origin
labels.” The majority of respondents considered it moderately important to be well informed
about these latter two elements. Nevertheless, by combining the answers very important and
moderately important, one observes that the total proportion of respondents rises to 82% and
83%, respectively. Moreover, six other elements obtain comparable combined scores between
80% and 85%.
258
See question 14, in Appendix 2, for detailed answers.
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5.4
The fit between information needs and presently available information
The final closed-ended question in our survey (#14) sought to determine 1) how “easy” it is for
consumers to find and understand the available information on a certain number of elements at
the present time and 2) whether, ideally, it would be important for them to be well informed on
these questions.
An initial finding: concerning the 22 elements presented in question 14, over 50% of
respondents deemed it very important to be informed regarding 15 of them and every element
was considered important by at least 80% of the respondents.
In order to determine the “fit” between what respondents find on the labels of prepackaged
foods sold in Canada and what they tell us it would be important to find on said labels, we
measured the gap between respondents’ answers to the question re the “ease of finding and
understanding” the different elements of information and their answers re the question
concerning the “importance of being well informed” regarding these same elements. We then
ranked these elements according to the size of the gap between information availability and its
importance—the goal being to obtain a picture of respondents’ real information needs as
compared with what is presently available on food labels. In our view, if respondents deem
information on a specific element important but do not find it easy to find or understand such
information, then an information gap (and need) exists that is worth pointing out.
Table 4 presents the gap that may exist between the importance of having access to a type of
information and the ease of finding and/or understanding it. The elements at the top of the list
represent respondents’ most important unfulfilled information needs. In determining the
importance attributed to being well informed re a specific element, we retained the answers
moderately important and very important. Similarly, in determining the ease of finding and
understanding information we retained the answers fairly easy and very easy (or difficult).
For example, on line 19 we see that 98% of the survey’s respondents consider it important to be
well informed on the salt content of foods and 91% of them find it easy to find and understand
the presently available information on salt content. The gap between the importance attributed
to finding this information and the possibility of doing so being quite small, we see no pressing
information needs around this element under the present labelling system—in a word the ability
to find this information is deemed as basically equivalent to the importance of finding it. As a
result, in our Table on the gap between the importance of certain elements of information and
their ease of availability, salt content is ranked near the bottom, 19th place in a list of 22
elements.
In contrast, whereas 96% of respondents consider it important to be well informed on the
utilization (or not) of chemical fertilizers and pesticides (line 2), only 7% consider such
information easy to find and understand, at the present time. Consequently, this element
occupies second place on our Table. The major gap between the importance of such
information and its availability indicates the existence of an unfulfilled information need.
.
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Table 4.
Gap between the importance of certain elements of information and their ease of
availability
Ranking
1.
2.
3.
4.
4.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
Elements of information
Utilization (or not) of antibiotics or hormones
Use (or not) of chemical fertilizers or pesticides
Breeding conditions of animals
Irradiation
Presence or absence of genetically modified
organisms (GMOs)
Treatment of the workers who contributed to
production
Warnings on health hazards of certain ingredients
Guarantee that the product distinguishes itself on
an ecological point of view
Information on the food given to bred animals
Respect for organic agriculture principles
Presence of the required characteristics to be «fairtrade» certified
Health claims
Presence of natural ingredients
Controlled origin labels
Presence or absence of certain types of fat
Presence or absence of artificial products
Presence (or absence) of allergenic ingredients
Country of origin of the product
Salt content
Logos indicating that the product is beneficial to
health
Sugar content
Fat content
Importance
96%
96%
85%
83%
259
260
Ease
5%
7%
4%
4%
Gap
91%
89%
81%
79%
92%
13%
79%
80%
4%
76%
97%
25%
72%
84%
20%
64%
94%
83%
36%
35%
58%
48%
82%
35%
47%
89%
46%
43%
91%
83%
97%
97%
95%
84%
98%
62%
58%
77%
78%
81%
71%
91%
29%
25%
20%
19%
14%
13%
7%
85%
80%
5%
97%
96%
93%
93%
4%
3%
5.4.1 Satisfaction of needs and concerns regarding nutrition and health issues
An analysis of the rankings in Table 4 shows that as far as the elements pertaining to our
respondents’ nutrition and health concerns are concerned their information needs generally
seems seems satisfied. In effect, whereas 10 of the 22 elements in table (the unshaded areas)
are directly related to nutrition and health issues, eight of them are in the bottom ten positions of
the Table and characterized by gaps under 30%. The regulatory framework presently in force in
Canada seems successful in that the provision of information around these specific issues is
relatively well aligned with respondents’ wishes.
However, two information issues related to nutrition and health present a less positive picture.
Notwithstanding Canadian regulatory requirements on this issue, a gap exists between the
importance that respondents accord nutrition and health claims and how easy it is to find and
understand information on such claims. Thus, while 89% of respondents consider such
information important, only 46% consider such information easy to find and understand. This
gap seems to suggest there is a problem.
259
“Importance" = the percentage of individuals who consider it “very important” or “moderately
important” to be informed about the elements of information included in this list.
260
“Ease” = the percentage of individuals who consider it “easy” or “moderately easy” to find and
understand, at the present time, the elements of information included in this list.
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The gravity of this consumer concern was underlined by a survey done by the National Institute
of Nutrition, which found that “93% of adult Canadians said that they believed that certain foods
have health benefits beyond basic nutrition, including enhancing health and reducing the risk of
disease.”261 Clearly, many consumers well be influenced by the health claims appearing on food
products.
Moreover, the question of information related to health warnings on the effects of certain
ingredients raises questions that are even more serious. Despite the importance attributed to
information on this issue—97% of respondents judging it important—only 25% of respondents
consider this information easy to find and understand. Let’s then underline the fact that of all the
elements of information related to nutrition and health considerations, health warnings on the
effects of certain ingredients is the only one that is not subject to specific regulations. That fact
only lends greater credence to the hypothesis that a positive link exists between the satisfaction
of consumer’s desire for information in food labelling and the actual application of regulations.
5.4.2 The satisfaction of needs and concerns related to the environment, society, culture,
ethics and politics
As for most of the types of information related to environmental questions or social cultural,
ethical and political issues (the shaded areas in Table 4), the survey’s respondents seemed of
the opinion that the information presently available on food labels does not adequately address
their concerns. In effect, the ranking established in Table 4 shows that out of the twelve
elements of information pertaining to these types of issues, ten occupy the first eleven positions
in the Table—that, in a word, indicates major unsatisfied information needs under the present
labelling system.
The only two elements of information dealing with such issues found in the bottom half of the
Table are also the only ones presently subject to labelling regulations, i.e. information on the
country of origin and information on reserved designation of origin. 262
Here again, one must underline the existence of a link between food labelling regulations and
the satisfaction of consumers’ information needs. In effect, with the exception of food irradiation,
which requires mandatory labelling (see section 3.1.1.6.), none of the elements of information
related to environmental issues or to the social, cultural, ethical or political issues mentioned in
our questionnaire are subject to any specific regulations in Canada. 263 The level of
dissatisfaction among respondents who have major information needs and concerns related to
the environment, society, culture, ethics and political issues appears to be directly attributable to
the absence of labelling regulations in these areas.
261
The primary source of this information was the National Institute of Nutrition’s 2001 survey entitled
Tracking Nutrition Trends. Health Canada, “What Do Canadians Think about Nutrition?” <http://www.hcsc.gc.ca/fn-an/alt_formats/hpfb-dgpsa/pdf/surveill/factsheet_canada_thinksdossier_canada_pense_e.pdf> (consulted on 1 May 2007). Op.cit. 248.
262
Quebec is the only province that regulates Reserved Designations of Origin (see section 3.1.3.).
263
Genetically modified (GM) foods are subject to a voluntary labelling standard (see section 3.1.8.).
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5.5
Respondents’ additional comments
Finally, our survey asked respondents two open-ended questions (15 and 16): first, whether
other food characteristics seemed important and, consequently, required improvements in
labelling rules; and second, whether they had any other general comments regarding food
labelling.
In total, 640 persons added comments on food characteristics they judged important and which
should, in their view, be subject to improvements in labelling rules. The following is a summary
of the most commonly expressed wishes:
• A more detailed list of ingredients (for example, a label should specify the spices, rather
than simply say “spices”), or even each ingredient’s proportion.
• More details on the packaging of meat products, for example, a meat product’s provenance
and the type of feed given to the animal.
• Restrictions on the use of different names to designate the same ingredient.
• Clear identification of a product’s geographic origin, i.e. not in a misleading fashion;
• Clear identification of local products.
• Clear and easy indication of the packing/harvesting date, the best-before date and the shelf
life.
• Clear identification of the different ingredients associated with sugars or fats.
• Information on GMOs, meat-and-bone meal, antibiotics, pesticides and hormones, as well
as on chemical additives, food colouring or preservatives.
• Additions to the list of allergens that must be declared.
• Information on the environmental impact of packaging.
• Bilingual labels, with correct French.
• Indication, concerning seafood, whether given products are wild species or from fish farms.
A total of 966 persons added one or more general comments on labelling. The following is a
summary of the most commonly made points, not mentioned in the previous questions:
• General scepticism with respect to the agri-food industry and their lack of confidence in the
information on labels, which, according to several respondents is intended more to market
the product than to inform the consumer
• Labelling information is written in lettering that is too small, which makes it hard to read.
• Overall, labelling information is hard to understand and would like to see the mandatory use
of standardized and easy to spot symbols or pictograms to, for example, differentiate
healthy foods from unhealthy foods.
• Information on the true origin of products can be misleading - respondents would like stricter
traceability rules.
• The multiplication of health related claims, labels and certifications, which insufficiently
regulated, may lead to abuses, deceptions and, possibly, greater confusion.
• Since there is insufficient space on labels to include all desirable information; respondents
suggested approaches to facilitate the quest for complementary information, e.g.
standardized product factsheets available in stores or on the Internet.
• Existing rules seem to allow industry to mislead consumers, for example by fiddling with
serving sizes and tolerance levels or by either combining different ingredients from the same
family or listing them separately.
• No trust claims such as “organic,” “fair trade,” “natural,” “fat-free,” etc.
• Lack of available information on certain categories of products, such as meat, fish, fresh
fruits and vegetables.
• Too much information might end up creating even more confusion among consumers.
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5.6
Squaring present awareness and education strategies with survey results
Making use of a broad network and a vast range of means of communication, Health Canada
has developed a comprehensive, multisectoral education and sensitization strategy aimed in
particular at introducing and communicating the new nutrition labelling system and its key
features to Canadian consumers, as well as building skills in reading label information. 264
The results of the survey conducted by Union des consommateurs would suggest that Health
Canada’s strategy has enjoyed some degree of success, particularly in sensitizing consumers to
the new labelling system—64.2% of respondents have in effect noted that more information is
available on food labels than two years ago. Nearly nine out of ten respondents (89.1%) say
that they often or always check a food’s label. More than eight out of ten respondents (80.5%)
say they often or always check the Nutrition Facts Table—a distinctive new feature of nutrition
labelling—when considering the purchase of a food they don’t know. More than seven of ten
respondents deem the information on labels (including the information contained in the Nutrition
Facts Table) generally easy to understand, which tends to suggest that labels are legible, and
that respondents have a certain level of education.
However, regarding the other component of Health Canada’s strategy—consumer education—
our survey’s methodology does not enable us to measure this initiative’s effectiveness with
precision. In effect, our results show that while only 9.1% say that they learned what the
Nutrition Facts Table is for and how to use it directly from Health Canada, another 9.4% learned
this at an educational institution, nearly a quarter (24.8%) learned via a health or nutrition
professional, and 41.9% say they learned through the media. As it happens, these latter three
sources of information are integrated into this Health Canada initiative, which, notably, bases its
education strategy on target audience segmentation (health professionals, teachers, etc.), as
well as recourse to multiple means of communication. The survey indicates nonetheless that
1.7% of respondents don’t know what the Table is for, 3.3% don’t how to use it and that over
half of the respondents (55.3%) say they taught themselves the ins and outs of the Table.
264
Nutrition, <http://www.hc-sc.gc.ca/fn-an/label-etiquet/nutrition/education/backgrcadre/strat_framework_entire-cadre_strat_entier-exec_e.html - 3> (consulted on 13 November 2006).
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5.7
The study’s limitations
The vehicle chosen (an on-line survey) and the use of a convenience sample had certain
consequences worth pointing out.
The two groups invited to participate were comprised of individuals who voluntarily joined
electronic mailing lists. The first group belonged to the mailing list of Union des consommateurs,
a consumer advocacy group, and the second was on the mailing list of L’épicerie, a television
program on food and nutrition. One could suppose that the persons in both groups are likely to
be more sensitized to consumer and/or food and dietary issues than the average population.
In fact, a very large proportion of the respondents (90%) consider their level of knowledge on
food issues appropriate, 19,9% declaring that they are very well informed. The fact that every
respondent had signed up to join a mailing list, and had therefore requested information related
to consumer issues, could perhaps have produced a sample in which our respondents, taken as
a whole, consider themselves better informed than average. The data published by Health
Canada indicating that 28% of Canadians consider themselves very well informed265 on food
issues seems quite striking in contrast.
The two groups invited to participate in the survey do, however, have distinct characteristics. A
priori, one may presume that those on the Épicerie mailing list have a particular interest in
dietary and health issues. Such an interest would explain why nearly 25% of this group say they
are very well informed on nutrition issues, compared to just 10% of their counterparts in the
Union group.
Whereas, one could presume that individuals on the Union des consommateurs’ mailing list
have a marked interest in consumer issues in general, it’s worth noting that Union des
consommateurs attracts new subscribers above all when it intervenes in class action suits.
Union des consommateurs’ intervention in two class actions concerning anti-inflammatory
medication prescribed for arthritis generated marked interest in the general public. This probably
explains the higher average age of the respondents contacted via its electronic mailing list.
The majority of respondents were women. This phenomenon may be explained in a number of
ways. The National Institute of Nutrition’s 2002 survey reported that 59% of women as opposed
to 47% of men affirmed that nutrition was “very” or “extremely” important in their choice of which
foods to consume. This greater concern on the part of women may explain the greater
proportion of women interested in our survey, which solicited answers from “adult which, in your
household, normally buys the food..”
The form and the grammatical structure of question 14 may have confused some respondents.
10% of the respondents skipped that question. Moreover, the construction problem of the
question made it quite difficult to correctly interpret the results: i.e. the fact that this question was
in fact two questions (“...find AND understand...”) makes it impossible to separate respondents
who found the information but didn’t understand it and vice versa.
265
Op.cit. 256.
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CONCLUSIONS
According to the studies mentionned in the present report, consumers are expressing new
concerns and initiating new trends in consumption. This is leading them to expand their
traditional food selection criteria beyond health and convenience to include environmental,
social, cultural, ethical and political considerations. Moreover, consumers are increasingly
turning to organic foods, food produced without genetically modified organisms (GMOs), locally
produced foods and fair trade foods.
With these new consumer concerns come new information needs. However, the information
presently available on food labels is not always sufficient to meet consumers’ requirements.
Moreover, the Canadian Agri-Food Research Council (CARC) recognizes that satisfying these
requirements will constitute one of the main challenges facing the Canadian agri-food sector.
Although the regulatory framework presently in force in Canada appears to have imposed a
labelling system that answers consumers’ nutrition and health concerns relatively successfully,
it’s another story if we consider the information needs revealed by our survey, i.e. consumers’
wish for information related to environmental, social, cultural, ethical and political issues.
The capacity of consumers to ensure that the products they buy meet their needs and satisfy
their new requirements depends, in effect, on proper product identification. According to
Consumers International, consumers can’t really trust the different “ecolabels” affixed to food
packaging since, in reality, a large number of labels and logos were vague, lacked
transparency, were not based on any defined standard and/or were subject to little or no third
party verification.
Without a strict regulatory framework and in the absence of a rigorous certification and
verification process, such labelling is apt to become an exercise in marketing for the benefit of
companies. This could, as a result, mislead consumers, undermine their trust and slow the
progress of a transformation towards responsible and sustainable food production and
consumption.
If one compares regulatory requirements on food labelling in Canada with requirements in other
countries and with the standards and guidelines of the Codex Alimentarius, one finds that
Canada ranks about average when it comes to consumers’ “convenience” related concerns
(product name, list of ingredients, best-before date, net content, etc.) As for the labelling
requirements bearing on nutrition and health considerations (energy value, list of ingredients,
Nutrition Facts Table, nutrition claims, etc.), Canadian regulations are by and large in line with
the standards and guidelines of the Codex Alimentarius, as well as consumers’ expectations.
Unfortunately, when it comes to examining this country’s food labelling regulations with respect
to overlapping concerns encompassing health, the environment, and social, cultural, ethical and
political issues (country of origin, organically farmed foods, genetically modified foods, irradiated
foods, fair trade foods, claims on livestock production methods, and other logos and claims,
such as “fresh,” “100% pure,” “natural,” “authentic,” home-made,” etc.), one must admit that
Canada’s performance is not quite so impressive.
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Our study identified certain weaknesses in the Canadian regulatory framework that must be
eliminated if our labelling rules are to match the best practices observed in other countries and
provide consumers with the most exact information possible. Rules concerning the geographic
origin of products, for example, would benefit from greater transparency. Moreover, such efforts
to favour local food production would also answer consumers’ health, social and environmental
concerns... as well as pocketbook considerations.
After having modified its rules on nutrition labelling, Health Canada elaborated a
comprehensive, long term, multisectoral strategy aimed at effectively introducing and
communicating the new nutrition labelling system and its key features to consumers, as well as
building their skills in reading label information. This initiative, which takes into account the
diverse needs, concerns and priorities of different segments of the population, plans to integrate
nutrition information into broader programs on healthy diets and active living so as to enable
consumers to use food label information to choose healthy foods.
Union des consommateurs’ survey was able to confirm that respondents’ nutrition and health
concerns remain the most influential factors when deciding whether to buy an unfamiliar
product. The survey also found that a very strong majority of respondents affirm that they often
or always check the label when considering an unfamiliar food product. In addition, the majority
says they are more concerned about information on the food they purchase than they were two
years ago. Moreover, a majority of respondents have noted that more information is available on
food products than two years ago and seven out of ten respondents deem the information on
food labels generally easy to understand.
Health Canada’s sensitization and education strategy, which compares favourably with the
strategies in other countries, seems to have achieved a degree of success, particularly
regarding respondents’ awareness of the new labelling system. In effect, a majority of
respondents sees the Nutrition Facts Table as very useful and considers the information
contained there generally easy to understand. That said, it should not be forgotten that a
significant fraction, close to a third of respondents, consider the Table generally difficult to
understand. This finding is all the more worrisome given that a substantial majority of
respondents consider themselves quite well informed or very well informed on food and dietary
issues.
Let’s underline the fact that the Canadian government’s initiatives in support of its labelling
policies include plans for periodic evaluation and, if so required, rectification of the programs
and materials utilized. It is of utmost importance that Health Canada continue—and assess—its
consumer education and sensitization strategy on nutrition labelling. However, it should also
adequately support education initiatives on nutrition since information seems to reassure
consumers when it comes to food. In effect, according to the results of our survey, whereas,
over 70% of the respondents claiming to be not very informed or uninformed state that they are
more concerned about information on food products than they were two years ago, less than
half (49.6%) of those claiming to be very well informed feel the same way.
Although, the results of our survey confirm that the present food labelling regime works
relatively well in satisfying respondents’ needs and concerns regarding nutrition and health
information, this is not, however, the case regarding their information needs and concerns
bearing on environmental, social, cultural, ethical and political issues. The gap between the
desire for such information and its availability indicates that a direct link exists between the
satisfaction of consumers’ needs and the existence of a regulatory framework. In other words,
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82
the smallest gaps between the desire for information and its availability almost always exist
where specific elements of information are subject to regulation.
Health Canada reports that:
“In the 2001 Tracking Nutrition Trends Survey, Canadians were asked about the degree to
which several product claims may influence their choice of food. Statements about added
vitamins and/or minerals were cited as influential ("very" or "somewhat") for nearly two
thirds of consumers (65%). Claims regarding sugar-free and light products were
considered influential to almost six in ten (58%) Canadians, especially women and
primary grocery shoppers. Products labelled as organic and source of omega 3 claims
tend to appeal to consumers aged 35 to 64 years of age.”266
Given the importance that these labelling claims represent for Canadians—which, when
they are regulated, are not always regulated in a sufficiently clear fashion to ensure that the
consumer is in a position to make truly informed choices—it’s important to tighten these
regulations to bar any claim or representation that might be misleading.
Thus, if Health Canada, whose role consists of “helping Canadians maintain and improve their
health, while respecting individual choices and circumstances,”267 wishes to comprehensively
fulfil its mission, it should satisfy the labelling needs engendered by consumers’ emerging
concerns and consider the pertinence of broadening its regulatory framework, such that
labelling rules go beyond the nutrition and health characteristics of foods to also encompass
characteristics bearing on environmental, social, cultural, ethical and political issues.
266
Health Canada, “What do Canadians do about nutrition?” <http://www.hc-sc.gc.ca/fn-an/surveill/factsfaits/factsheet_canada_does-dossier_canada_fait_e.html> (consulted on 1 May 2007).
267
Health Canada, “About Health Canada,” <http://www.hc-sc.gc.ca/ahc-asc/index_e.html> (consulted
on 21 December 2006).
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83
RECOMMENDATIONS
-
-
-
•
•
•
Whereas consumers, long restricted their concerns to the issues of price and food safety,
these have widened greatly and now include, in addition to health and convenience,
concerns of an environmental, social, cultural, ethical and political character;
Whereas Agriculture and Agri-Food Canada (AAFC), has identified several factors that will
influence consumers’ food choices in the coming years, including globalization relatedissues, environmental awareness, the share of income allocated to food expenditures,
consumer confidence re the production of “safe” foods, food spoilage, food-related illnesses,
additives and contaminants, food traceability, the ethical treatment of animals, and the
country of origin;
Whereas the information presently available on food labels does not always permit
consumers to satisfy their information needs, notably regarding production methods,
processing processes and the provenance of food products;
Whereas the responses gathered by our survey indicate a need for additional information on
food labels in order to more adequately respond to concerns related to environmental,
social, cultural, ethical or political issues;
Whereas an American opinion poll revealed that the vast majority of consumers desire the
clear identification of foods produced with pesticides or plant hormones;
Whereas the vast majority of our survey’s respondents affirmed the great importance of
being well informed regarding the presence or absence of allergenic ingredients in foods,
the health effects of certain ingredients, and the utilization of chemical fertilizers, pesticides,
antibiotics or hormones;
Whereas our survey’s respondents raised the difficulties in finding and understanding
information, notably as regards livestock production conditions, working conditions, food
irradiation, the utilization of antibiotics, hormones, chemical fertilizers or pesticides, respect
for organic farming principles, and this despite the importance they accord to said issues;
Union des consommateurs recommends that Health Canada and the AAFC evaluate and
review on a continuous basis the regulatory frameworks bearing on food labelling to ensure
that such labelling achieves its objectives and in order to periodically integrate new labelling
elements apt to respond to evolving consumer trends and needs, notably as regards the
flaws pointed out in this study;
Union des consommateurs recommends that, with a view to enabling this continuous
review, the federal government, in collaboration with the competent provincial authorities,
set up a standing commission which should include the participation of consumer groups
and public health experts;
Union des consommateurs recommends moreover that the not-for-profit organizations
called on to participate in the work of said commission benefit from sufficient funding to
enable proper participation in the review and elaboration processes that the present
recommendations shall demand.
Regarding organic farming
Whereas consumers are expressing growing concern over the presence of genetically
modified organisms (GMOs) in food products, growth hormones and antibiotics in livestock,
herbicides, pesticides or chemical fertilizers in crops, etc.;
Whereas only organic foods can, at the present time, offer the consumer whose grocery
shopping reflects these types of concerns a reasonable degree of assurance that the foods
he consumes are free of said substances;
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84
-




Whereas certification is important in that it guarantees that the foods designated as
organically farmed do in fact respect the necessary criteria;
Whereas a significant fraction of our survey’s respondents consider the certification of
organic foods an important part of food labelling and, in light of the rapid growth of the
market for organically farmed foods, the number of consumers concerned about such
certification is expected to grow rapidly;
Whereas British Columbia and Quebec are the only provinces in Canada to have set up
regulated organic certification regimes;
Whereas the Codex Alimentarius Commission has issued guidelines on the production,
processing, labelling and marketing of organically farmed foods;
Whereas Canada is presently developing a standard on the labelling of organically farmed
foods and given that it is important for Canada to possess such a standard to preserve its
share of the organic products export market in the European Union;
Union des consommateurs recommends that the government of Canada pursue, without
delay, initiatives aimed at instituting a framework program on organic foods certification,
based on the recommendations of the Codex Alimentarius and acknowledged criteria
regarding the recognition of organic farming;
Union des consommateurs recommends that the federal government work in collaboration
with the provincial authorities that have instituted a regulatory framework on the certification
of organic foods, with a view to developing a Canadian standard;
Union des consommateurs recommends that consumers’ groups be associated with these
efforts and that they receive sufficient funding to enable them to participate in an adequate
fashion;
Union des consommateurs recommends that the federal and provincial governments
implement as soon as possible a consumer information strategy to publicize the advantages
of organic farming and the importance and advantages of rigorous certification.
Regarding genetically modified organisms (GMOs)
Whereas, according to numerous reports and studies, genetically modified crops threaten
organic farming due to the risks of cross contamination, a phenomenon which renders the
coexistence of these two types of agriculture practically impossible;
Whereas GM crops and the patenting of transgenic seeds are increasing the appropriation
of our genetic patrimony by multinationals and reducing both farmers’ independence and
the country’s food security;
Whereas over 80% of Canadians wish to see Canada impose mandatory labelling on foods
containing GMOs;
Whereas 92% of our survey’s respondents deem information on the presence or absence
of GMOs in foods to be important;
Whereas the right to information enabling Canadians to choose whether or not to consume
genetically engineered foods, and thus address their ethical, political and environmental
concerns, is a right that must be recognized;
Whereas over forty countries have already imposed mandatory labelling of GM foods;
Whereas the European Union requires mandatory labelling of all foods produced using
GMOs, as well as all foods containing GMOs;
Whereas opposition on the part of Canada and the United States constitutes one of the
factors preventing the adoption of a Codex standard on the labelling of genetically modified
organisms;
Whereas in April 2004 Canada adopted a standard on the voluntary labelling of genetically
modified foods;
Whereas this voluntary standard has not enabled consumers to see the appearance of any
such information on the labels of genetically modified foods;
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85
•
•
Union des consommateurs recommends that the Canadian government impose mandatory
labelling of foods containing genetically modified organisms, a measure demanded by a
very strong majority of Canadians, in accordance with the European model;
Union des consommateurs recommends that the Canadian government dissociate itself
from the American position and support the adoption of a rule on the mandatory labelling of
GMO foods within the framework of the Codex Alimentarius.
Regarding the certification of fair trade products
Whereas fair trade contributes notably to the economic development of developing
countries by offering better marketing conditions to marginalized producers and by
strengthening their rights;
Whereas the level of consumer awareness of fair trade has increased substantially in
Canada in recent years, as the sales of certified fair trade products have recorded an
average annual growth rate of 55%;
Whereas our survey reveals that a large majority of our respondents consider it important to
be well informed regarding the characteristics required to enable the certification of a
product as a “fair trade” product;
Whereas Consumers International published a report in July 2004 that concluded that a
large number of ecolabels and logos were vague or without meaning, communicated
messages that lacked transparency, were not based on any defined standard and/or were
subject to little or no third party verification;
Whereas only rigorous certification and verification processes are liable to avert the risks of
consumers being misled, of their trust being undermined and the slowing of progress
towards responsible and sustainable food production and consumption;
Whereas no specific standard exists in Canada aimed at regulating food products regarding
respect for fair trade principles or guaranteeing the truthfulness of claims made by certain
labels in this regard;
• Union des consommateurs recommends that the federal and provincial governments create
a round table that shall include the participation of consumers' groups and free trade
stakeholders and which shall be mandated to evaluate the pertinence and the feasibility of
implementing a regulatory framework on the designations “equitable” and “fair trade” in
relation to food products and the pertinence of making said designations protected
designations in the food industry;
• Union des consommateurs recommends that the civil society actors associated with this
work benefit from sufficient funding to enable their proper participation.
Regarding the geographic origin of foods
Whereas a food may bear the phrase “product of Canada,” provided it has undergone
substantial processing in Canada—even if the food is entirely composed of ingredients from
outside of Canada;
Whereas a food bearing the phrase “made in Canada” or “product of Canada” on its label—
without any other details on the geographic origin of its components—is liable to mislead
the consumer who would like to buy local products by suggesting that the food and its
ingredients come exclusively from Canada or were entirely manufactured in the country;
Whereas there are advantages to promoting local food production, which, in addition to
enabling consumers to consume fresh products from their own region, lessens the need for
preservatives, favours the reduction of greenhouse gas emissions, and stimulates rural
development and the regional economy;
Whereas the promotion of local food production shall only be possible to the extent that the
consumer disposes of the information required to make informed choices in this regard;
page
86
•
•
Union des consommateurs recommends that the federal government tighten the labelling
regulations on the geographic origin of foods, such that consumers may determine as
accurately as possible the place of origin of most of the constituents of a food product and
make informed choices;
Based on the new rules to be adopted, Union des consommateurs recommends that
governments encourage and support campaigns promoting the consumption of local foods,
as well as information campaigns on the advantages to buying locally produced foods.
Regarding health claims and lax labelling rules
Whereas the Food and Drug Regulations regulate a certain number of claims pertaining to
nutritional content and health;
Whereas health claims should be based on sufficient scientific and objective data to justify
them, should provide truthful and non-misleading information to help consumers choose
good dietary practices, and should be supported by specific consumer education efforts;
Whereas it is deemed misleading to unduly emphasize the importance, presence or
absence of an ingredient or substance due to its desirable or undesirable qualities or for
any other reason, and whereas any highlighting of an ingredient, constituent or substance
should be accompanied by a declaration of its quantity in the list of ingredients;
Whereas, furthermore, a food label should not highlight the presence of nutrients or
substances contained in the food as trace quantity or in tiny quantities;
Whereas the contents of labelling should not contain any elements apt to deceive or
mislead the consumer;
Whereas due to the degree of tolerance authorized under existing regulations, it is possible
to announce on a product’s label that it does not a contain a given ingredient when in fact it
does contain said ingredient (for example: ”zero calories” if a food contains less than 5
calories per reference amount and per serving of stated size; “100% fat-free” when a food
contains less than 0.5 grams of fat per 100 grams, less than 0.5 grams of fat per reference
amount and serving of stated size, and does not contain any added fat; “0 trans fat” when a
food does contain a certain percentage of trans fatty acids; “no cholesterol” when a food
does contain a certain percentage of saturated fatty acids and trans fatty acids; “no salt”
when a food does contain a certain percentage of sodium; “zero sugar” when a food does
contain a certain percentage of sugar);
Whereas laxness in this regulatory framework leads to claims on food labels that
contravene the general principles prohibiting misleading claims;
Whereas consumers have a right to accurate information;
• Union des consommateurs recommends that food labelling regulations require that the
quantity or proportion of any highlighted ingredient be stated accurately and precisely on the
label;
• Union des consommateurs recommends that food labelling regulations formally prohibit the
vaunting of the presence of any ingredient which is only found in the food as a trace quantity
or in tiny quantities;
• Union des consommateurs recommends that food labelling regulations formally prohibit any
statement on the label to the effect that the product does not contain a given ingredient
when it does in fact contain said ingredient.
Regarding exemptions in relation to certain potentially allergenic additives
Whereas the Codex standards and guidelines require the declaration of all ingredients and
foods, including additives known to be allergens;
Whereas Canadian regulations permit certain exemptions regarding the declaration of
ingredients and constituents in the list of ingredients (i.e. flavouring, seasoning, spices,
etc.);
page
87
•
Union des consommateurs recommends that food labelling regulations be amended to
eliminate this exemption.
Regarding food irradiation
Whereas the Codex standards and guidelines require the labelling of all irradiated foods
and ingredients, regardless of their percentage in the food’s composition;
Whereas Canadian legislation allows the identification of irradiated ingredients in the list of
ingredients to include only those which constitute 10% or more of the food;
Whereas the vast majority of our survey’s respondents deem it important that information
on food irradiation be disclosed;
• Union des consommateurs recommends that Health Canada adopt labelling rules for
irradiated foods that are consistent with Codex standards.
Regarding stated serving sizes
Whereas the information appearing in the Nutrition Facts Table is indicated in terms of the
food’s stated serving size;
Whereas manufacturers have wide latitude in specifying the serving sizes of their products
used as a baseline when providing nutrition information on labels (with ratios varying from 1
to 4 for certain products);
Whereas it may therefore be quite difficult for a consumer to cross-compare the nutritional
value of similar products not using a standardized serving size;
• Union des consommateurs recommends that Health Canada conduct a review of its
labelling rules with a view to imposing a standardization of serving sizes for different types of
foods.
Regarding information policy
Whereas although the majority of our survey’s respondents see the Nutrition Facts Table as
very useful, nearly 30% consider the information contained in it generally difficult to
understand;
Whereas it is important for governmental authorities to support educational initiatives on
nutritional issues;
Whereas it is of utmost importance that Health Canada continue, as well as assess, its
consumer education and sensitization strategy on nutrition labelling, as well as adequately
support other education initiatives on nutrition;
• Union des consommateurs recommends that Health Canada continue its evaluation of
different education and information strategies regarding labelling and nutrition issues, with a
view to improving its programs, and that, to this end, it collaborate with consumers’ groups
and the concerned health and nutrition experts;
• Union des consommateurs recommends that the civil society actors associated with this
work benefit from sufficient funding to enable their proper participation.
page
88
MEDIAGRAPHY
Agricultural Marketing Service (AMS)
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Facts in The National Organic Program
http://www.ams.usda.gov/nop/Consumers/brochure.html
United States Department of agriculture (USDA), NOP Background information in The
National Organic Program
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Agriculture and Agri-Food Canada (AAFC)
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http://www4.agr.gc.ca/AAFC-AAC/display-afficher.do?id=1170954034728&lang=e
Canadian Consumers
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Canadian Food Trends to 2020
Rome Declaration on World Food Security
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What's Hot and What's Not in the Canadian Food Market 2005
Australasian Legal Information Institute, Trade Practices Act 1974 in Commonwealth of
Australia Consolidated Acts
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About Buy BC
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Qualifying Products
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British Columbia Society for the Prevention of Cruelty to Animals (BCSPCA)
SPCA Certified Standards
http://www.spca.bc.ca/farm/standards.asp
Humane Labelling Programs in Other Countries
http://www.spca.bc.ca/farminfo/world.asp
page
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Canadian Agri-Food Research Council (CARC), Canada's National Strategy for Agri-Food
Research and Technology Transfer -1997 – 2002
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&province=1%2C8&province=1%2C7&province=1%2C13&topic=CAT4.TOPICS.ROOT&consu
merChallengeNo=266&text=&language=eng
Canadian Food Inspection Agency (CFIA)
Consumer Resources - Poster 1 – Can, in Food and Nutrition
http://www.hc-sc.gc.ca/fn-an/label-etiquet/nutrition/education/cons-res/cr_poster_cancr_affiche_conserve_e.html
Consumer Resources - Poster 2 – Cart, in Food and Nutrition
http://www.hc-sc.gc.ca/fn-an/label-etiquet/nutrition/education/cons-res/cr_poster_cartcr_affiche_panier_e.html
Guide to Food Labelling and Advertising 2003, Chapter 1 – 1.4 Purpose of Food Labelling
http://www.inspection.gc.ca/english/fssa/labeti/guide/ch1e.shtml - 1.4
Guide to Food Labelling and Advertising 2003, Chapter 2 – 2.4 Bilingual Requirements
[B.01.012, B.01.054; 6,CPLR]
Guide to Food Labelling and Advertising 2003, Chapter 2 – 2.11 Durable Life Date
[B.01.007]
http://www.inspection.gc.ca/english/fssa/labeti/guide/ch2ae.shtml - 2.11
Guide to Food Labelling and Advertising 2003, Chapter 2 – 2.7 Name and Address
[B.01.007; 10, CPLA; 31, CPLR]
Guide to Food Labelling and Advertising 2003 in Chapter 2 – 2.8 List of Ingredients
[B.01.008, B.01.010]
Guide to Food Labelling and Advertising 2003, exemption
http://www.inspection.gc.ca/english/fssa/labeti/guide/ch2-1e.shtml
Guide to Food Labelling and Advertising 2003, Appendix 2-1
http://www.inspection.gc.ca/english/fssa/labeti/guide/ch2-1e.shtml
Guide to Food Labelling and Advertising 2003, Chapter 7 – 7.25 - Vitamin and Mineral
Nutrient Claims
http://www.inspection.gc.ca/english/fssa/labeti/guide/ch7be.shtml - 7.25
Guide to Food Labelling and Advertising 2003, Chapter 4 – 4.6 Homemade
Guide to Food Labelling and Advertising 2003, Chapter 4 – 4.7 Nature, Natural
Guide to Food Labelling and Advertising 2003, Chapter 4 – 4.12 True, Real, Genuine.
Guide to Food Labelling and Advertising 2003, Chapter 4 – 4.19 Imported, Product of
Canada, Made in Canada, Country of Origin
Guide to Food Labelling and Advertising 2003, Chapter 5 – 5.1 Purpose of the New Nutrition
page
90
Labelling Regulations
Guide to Food Labelling and Advertising 2003, Chapter 6 – 6.2.1 Reference Amounts,
http://www.inspection.gc.ca/english/fssa/labeti/guide/ch6e.shtml - 6.2.1
Guide to Food Labelling and Advertising 2003, Chapter 7 – 7.1 Introduction
Guide to Food Labelling and Advertising 2003, Chapter 7 – 7.25 Vitamin and Mineral
Nutrient Claims
http://www.inspection.gc.ca/english/fssa/labeti/guide/ch7be.shtml - 7.25
Guide to Food Labelling and Advertising 2003, Chapter 7 – 7.9 Comparative Claims
Guide to Food Labelling and Advertising 2003, Chapter 8 – 8.4 Diet-Related Health Claims
Guide to Food Labelling and Advertising 2003, Chapter 8 – 8.5 Biological Role Claims
Guide to Food Labelling and Advertising 2003, Annex 8-2, Policy Respecting the Use of
Heart Symbols and Heart Health Claims on Food Labels and in Food Advertisements
http://www.inspection.gc.ca/english/fssa/labeti/guide/ch8-1e.shtml - 2
Guide to Food Labelling and Advertising 2003, Chapter 8 – 8.11: Third-Party Endorsements,
Logos and Seals of Approval
Guide to Food Labelling and Advertising 2003, Section VII: Health-Related Claims,
Appendix II: Policy on the Use of Third-Party Endorsements, Logos and Seals of Approval
(amended, 31 January 1997)
http://www.inspection.gc.ca/english/bureau/labeti/guide/7-0-7e.shtml
Labelling of Genetically Engineered Foods in Canada
http://www.inspection.gc.ca/english/sci/biotech/labeti/response.shtml
Nutrition Labelling Toolkit
http://www.inspection.gc.ca/english/fssa/labeti/nutrikit/nutrikite.shtml
Nutrition Labelling: A Strategic Framework for Public Education, in Food and Nutrition
http://www.hc-sc.gc.ca/fn-an/label-etiquet/nutrition/education/backgrcadre/strat_framework_entire-cadre_strat_entier-exec_e.html - 3
Nutrition Labelling Toolkit for Educators, in Food and Nutrition
http://www.hc-sc.gc.ca/fn-an/label-etiquet/nutrition/education/nurtri-kit-trousse/toolkit_eductrousse_educ_e.html
Reference Amounts Table
http://www.inspection.gc.ca/english/fssa/labeti/guide/ch6e.shtml - tab6-3
Canadian General Standards Board
Organic Production Systems General Principles and Management Standards - CAN/CGSB32.310-2006
http://www.tpsgc.gc.ca/cgsb/on_the_net/organic/scopes-e.html - 32_310
http://www.tpsgc.gc.ca/cgsb/on_the_net/organic/032_0310_2006-e.pdf
Organic Production Systems: Permitted Substances Lists
page
91
Voluntary Labelling and Advertising of Foods that Are and Are not Products of Genetic
Engineering - CAN/CGSB-32.315-2004
http://www.tpsgc.gc.ca/cgsb/on_the_net/032_0315/032_0315_1995-e.pdf
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of Health and Human Services (DHHS) – Food and Drug Administration (FDA). Statement of
Policy: Foods Derived From New Plant Variety; Notice, 29 May 1992.
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Genetically Engineered Foods
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Certified Organic Associations of British Columbia (COABC), COABC – Certification
http://www.CertifiedOrganic.bc.ca/cb/certification.htm
Codex Alimentarius
Code of Ethics for International Trade in Food, (CAC/RCP 20-1979)
http://www.codexalimentarius.net/download/standards/1/CXP_020e.pdf
Codex Alimentarius Guidelines on Nutrition Labelling
http://www.codexalimentarius.net/download/standards/34/CXG_002e.pdf
Codex General Guidelines on Claims, (CAC/GL 1-1979)
Codex General Standard for the Labelling of Food Additives when Sold as Such.
http://www.codexalimentarius.net/download/standards/2/CXS_107e.pdf
General Principles for the Addition of Essential Nutrients to Foods, (CAC/GL 09-1987),
http://www.codexalimentarius.net/download/standards/299/CXG_009e.pdf (
General Standard for the Labelling of Prepackaged Foods
http://www.codexalimentarius.net/download/standards/32/CXS_001e.pdf
Guidelines for Food Import Control Systems, (CAC/GL 47-2003)
Guidelines for the Production, Processing, Labelling and Marketing of Organically Produced
Foods, (GL 32-1999)
Guidelines for the Use of Nutrition and Health Claims
http://www.codexalimentarius.net/download/standards/351/CXG_023f.pdf
Welcome
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Codex Alimentarius Commission
Food Standards Programme – Food Labelling - Complete Texts
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Commerce Commission, False or misleading representations about goods or services
http://www.comcom.govt.nz/FairTrading/TradePracticesCoveredbytheFairTradingAct/falseormisl
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Competition Bureau
Guide to ‘Made in Canada’ Claims
http://www.competitionbureau.gc.ca/internet/index.cfm?itemID=1231&lg=e
Conseil des appellations agroalimentaire du Québec (CAAQ)
Qu’est-ce qu’un produit bio ?
http://www.caaq.org/appellation-biologique/espace-consommateurs/produit-bio.asp
FAQ – Consommation
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Quebec Organic Reference Standard
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Consumers International (CI)
Green Food Claims - A Comparative Survey
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Consumer Packaging and Labelling Act (R.S., 1985, c. C-38)
http://lois.justice.gc.ca/en/showtdm/cs/c-38/index.html
Food and Drugs Act (R.S., 1985, c. F-27). Part1 – Food, Drugs, Cosmetics and Devices,
General
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Food and Drug Regulations (C.R.C., c. 870)
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Europa
Agricultural products and foodstuffs as traditional specialities guaranteed
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Fair trade
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Foodstuffs treated with ionising radiation
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GM Food and Feed
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Labelling, presentation and advertising of foodstuffs
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Nutrition and health claims in consumer information
Nutrition labelling
Protection of geographical indications and designations of origin
Traceability and labelling of genetically modified organisms (GMOs)
Unfair commercial practices
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Development Cooperation, Bulletin EU 7/8-2006
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Recherche européenne – l’info
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Health Canada
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Allergen Labelling in Food and Nutrition
http://www.hc-sc.gc.ca/fn-an/label-etiquet/allergen/index_e.html
Food Allergy Factsheets
http://www.hc-sc.gc.ca/fn-an/securit/allerg/fs-if/index_e.html
Nutrition Labelling: A Strategic Framework for Public Education, in Food and Nutrition
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What do Canadians know about nutrition?
http://www.hc-sc.gc.ca/fn-an/surveill/facts-faits/factsheet_canada_knowsdossier_canada_connait_e.html
What Do Canadians Think about Nutrition?
http://www.hc-sc.gc.ca/fn-an/alt_formats/hpfb-dgpsa/pdf/surveill/factsheet_canada_thinksdossier_canada_pense_e.pdf
HealthyOntario.com, Decoding the New Nutrition Label in EatRight Ontario
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Inter-American Institute for Cooperation on Agriculture (IICA)
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International Fair Trade Association (IFAT), General Info, Facts & Figures, Speeches,
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pour mettre fin à la faim chronique et promouvoir le développement rural
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Ministère de l’agriculture, des pêcheries et de l’alimentation du Québec (MAPAQ)
Page du MAPAQ
http://www.mapaq.gouv.qc.ca/NR/rdonlyres/AC9976BB-03FF-4249-B0DF55F62B23EE94/0/42069_MAPAQTCN_0405.pdf#search=%22place%20aux%20appellation
s%20r%C3%A9serv%C3%A9es%20et%20aux%20termes%20valorisants%22
Le ministre Yvon Vallières annonce l’adoption de la Loi sur les appellations réservées et les
termes valorisants, Press release, 13 April 2006
http://www.mapaq.gouv.qc.ca/Fr/Centre_Presse/Communiques/2006/06127.htm
National Institute of Nutrition, Nutrition Labelling: Perceptions and Preferences of Canadians
(1999)
http://dsp-psd.communication.gc.ca/Collection/H49-139-1999F.pdf
Oberholtzer, L. et al, Price Premiums Hold on as U.S. Organic Produce Market Expands
(United States Department of Agriculture: May 2005)
http://www.ers.usda.gov/publications/vgs/may05/VGS30801/VGS30801.pdf
page
97
Office de la protection du consommateur (OPC)
Alimentation in OPC Jeunesse – Libre service
http://www.opc.gouv.qc.ca/jeunesse/service/affiche.asp?page=savaistu_aliment&section=sa
vaistu
Les allégations des fabricants in Logomanie
http://www.opc.gouv.qc.ca/jeunesse/service/affiche.asp?page=logomanie_fabricants&sectio
n=logomanie
Les étiquettes alimentaires in Logomanie
http://www.opc.gouv.qc.ca/jeunesse/service/affiche.asp?page=logomanie_aliment&section=
service
OGM dangers
http://www.ogmdangers.org/enjeu/politique/sondage.htm
Radio-Canada, Enquête: les boissons énergisantes, L’épicerie television program, broadcast
on 28 February 2003)
http://radio-canada.ca/actualite/lepicerie/docArchives/2003/02/28/enquete.html
Senate of Canada - Report of the Standing Committee on Agriculture and Forestry, ValueAdded Agriculture in Canada, December, 2004
http://www.parl.gc.ca/38/1/parlbus/commbus/senate/Com-e/agri-e/rep-e/rep02dec04-e.htm
Serecon Management Consulting Inc., Canadian Food Trends to 2020: A Long Range
Consumer Outlook, Prepared for Agriculture and Agri-Food Canada (Edmonton: Serecon
Management Consulting Inc., July 2005)
Soucy, M. A.
Marchés publics: bien plus que des commerces ! , La terre de chez nous, Vol. 77, No 21
(June 2006)
Consommation solidaire : Campagne de sensibilisation à l’achat local, La terre de chez
nous, Vol. 77, No 21 (June 2006)
The Orator Network, To amend the Federal Food, Drug, and Cosmetic Act relating to
freshness dates on food [H.R. 3570], 109th Congress - 1st Session
http://www.theorator.com/bills109/hr3570.html
TransFair, Questions and Answers about Fair Trade
http://www.transfair.ca/en/faq/
United States Government Printing Office (GPO)
National Archives and Records Administration, Codes of Federal Regulations, Title 21 Food
and Drugs, Chapter 1 – Food and Drug Administration (FDA) and Department of Health and
Human Services (DHHS), Part 101- Food Labeling
http://www.access.gpo.gov/nara/cfr/waisidx_06/21cfr101_06.html
United States Government Printing Office (GPO)
National Archives and Records Administration, Codes of Federal Regulations, Title 9
Animals and Animal Products, Chapter 3 – Food Safety and Inspection Service (FSIS) and
United States Department of agriculture (USDA), False or misleading labelling or practices
generally; specific prohibitions and requirements for labels and containers
http://a257.g.akamaitech.net/7/257/2422/01jan20061500/edocket.access.gpo.gov/cfr_2006/j
anqtr/pdf/9cfr317.8.pdf
page
98
Human Services (DHHS), Nutrient content claims – general principles
http://a257.g.akamaitech.net/7/257/2422/10apr20061500/edocket.access.gpo.gov/cfr_2006/
aprqtr/pdf/21cfr101.13.pdf
Human Services (DHHS), Food Labelling
http://www.access.gpo.gov/nara/cfr/waisidx_06/21cfr101_06.html
Human Services (DHHS), Health claims: general requirements
http://a257.g.akamaitech.net/7/257/2422/10apr20061500/edocket.access.gpo.gov/cfr_2006/
aprqtr/pdf/21cfr101.14.pdf
United States Department of Agriculture (USDA)
Food Safety and Inspection Service (FSIS), Animal Production Claims: Outline of Current
Process
http://www.fsis.usda.gov/OPPDE/larc/Claims/RaisingClaims.pdf
United States Food and Drug Administration (USFDA)
A Food Labelling Guide
http://www.cfsan.fda.gov/~dms/flg-toc.html
A Food Labelling Guide – Appendix C
http://www.cfsan.fda.gov/~dms/flg-6c.html
Agricultural Marketing Service (AMS), Country of origin labelling, in 2002 Farm Bill
Provisions
http://www.ams.usda.gov/COOL/
Center for Food Safety and Applied Nutrition (CFSAN), Food Label Education Tools and
General Information in Food Labelling Nutrition
http://www.cfsan.fda.gov/~dms/lab-gen.html
Center for Food Safety and Applied Nutrition (CFSAN), Is irradiated food safe? How is it
labeled?
http://www.cfsan.fda.gov/~dms/qa-fdb33.html
Claims That Can Be Made for Conventional Foods and Dietary Supplements
http://www.cfsan.fda.gov/~dms/hclaims.html
Federal Food, Drug, and Cosmetic Act
http://www.fda.gov/opacom/laws/fdcact/fdcact4.htm
Food Safety and Inspection Service (FSIS), Fresh, ‘Not Frozen’ and Similar Terms when
Labeling Meat and Poultry Products in Regulations and Policies
http://www.fsis.usda.gov/regulations_&_policies/Labeling_Fresh_Not_Frozen/index.asp
Food Safety and Inspection Service (FSIS), Labeling and Consumer Protection: Natural and
Organic Claims
http://www.fsis.usda.gov/Frame/FrameRedirect.asp?main=http://www.fsis.usda.gov/OPPDE/
larc/Claims/Organic_Claims.htm
Guidance for Industry: Voluntary Labeling Indicating Whether Foods Have or Have Not
Been Developed Using Bioengineering
http://www.cfsan.fda.gov/~dms/biolabgu.html
page
99
Vallée, P. La table de ‘chez nous’ : Les grandes surfaces affichent les produits locaux, Le
Devoir, September 21, 2005, p. D4
Voluntary Standard for Labelling of Genetically Engineered Foods Becomes National
Standard, Press Release, Ottawa, 15 April 2004
http://www.inspection.gc.ca/english/corpaffr/newcom/2004/20040415e.shtml
World Health Organisation and Food and Agriculture Organisation of the United
Nations, Understanding the Codex Alimentarius, Preface
http://www.fao.org/docrep/008/y7867e/y7867e00.htm
Wikipedia.
Animal welfare
http://en.wikipedia.org/wiki/Animal_welfare
Commerce équitable
http://fr.wikipedia.org/wiki/Commerce_%C3%A9quitable
Révolution verte
http://fr.wikipedia.org/wiki/R%C3%A9volution_verte
Willer H. and M. Yussefi, The World of Organic Agriculture – Statistics and Emerging Trends –
2004 (International Federation of Organic Agriculture Movements: 2004)Allemagne
http://orgprints.org/2555/
page
100
APPENDIX 1
Lettre d’invitation
Madame,
Monsieur,
L'Union des consommateurs sollicite votre collaboration dans le cadre d'un projet de recherche
sur l'étiquetage des aliments.
Nous vous invitons à participer à un sondage web sur cette question. Nous vous assurons de
préserver la confidentialité de vos réponses. Il ne vous faudra que quelques minutes pour
répondre.
Pour participer immédiatement au sondage, cliquez le lien suivant:
https://www.surveymonkey.com/s.asp?u=764932737042&c=20202
En répondant au sondage, vous aiderez l'Union des consommateurs à mieux faire connaître les
besoins et les attentes des consommateurs en matière d'étiquetage des aliments.
Pour toute question sur ce projet de recherche, n'hésitez pas à nous contacter:
[email protected]
Nous vous remercions sincèrement de votre précieuse collaboration.
Charles Tanguay
Dir.-adjoint - Responsable des communications
L'Union des consommateurs
Tél.: (514) 521-6820
Télécopies: 521-0736
[email protected]
NOUVELLE ADRESSE
6226, rue Saint-Hubert
Montréal (Qué.) H2S 2M2
Site web: http://www.consommateur.qc.ca/union
page
101
APPENDIX 2
page
102
Sondage sur l'étiquetage des aliments (Merged)
1. En général, quelle est l’influence des facteurs suivants sur votre décision d’acheter un produit alimentaire que vous ne
connaissez pas?
pas
important
peu
important
assez
important
très
important
ne sais
pas / ne
s'applique
pas
13.1%
(419)
40.0%
(1282)
36.8%
(1178)
9.7% (311)
0.5% (15)
2.44
3205
Le rapport qualité-prix
0.9% (28)
3.8% (123)
36.7%
(1174)
57.4%
(1840)
1.2% (38)
3.54
3203
Le fait que ce produit soit offert à prix
réduit
5.4% (173)
26.0%
(835)
43.0%
(1380)
24.9%
(799)
0.8% (25)
2.90
3212
Le fait d’avoir vu une publicité sur ce
produit
19.3%
(617)
48.0%
(1534)
27.7%
(885)
4.5% (144)
0.5% (16)
2.19
3196
5.8% (186)
26.0%
(834)
51.1%
(1638)
16.8%
(537)
0.3% (9)
2.80
3204
19.6%
(626)
44.4%
(1421)
29.7%
(949)
5.7% (182)
0.7% (22)
2.24
3200
La qualité des ingrédients
0.4% (12)
1.7% (56)
19.8%
(633)
76.6%
(2452)
1.5% (49)
3.77
3202
La facilité de préparation du produit
6.2% (198)
21.8%
(699)
45.2%
(1447)
25.8%
(825)
1.0% (31)
2.94
3200
Les qualités nutritionnelles du
produit
0.7% (23)
3.0% (97)
23.6%
(759)
71.3%
(2294)
1.4% (44)
3.70
3217
L’idée que ce produit pourrait plaire
aux enfants
23.0%
(737)
20.4%
(654)
26.0%
(832)
12.8%
(410)
17.7%
(568)
2.82
3201
Le fait d’y goûter en magasin
18.0%
(575)
36.1%
(1157)
30.6%
(980)
14.3%
(458)
1.0% (32)
2.44
3202
Le fait qu’il soit certifié «biologique»
18.3%
(586)
38.6%
(1235)
28.7%
(919)
13.0%
(417)
1.3% (41)
2.40
3198
Le fait qu’il soit certifié «équitable»
11.8%
(379)
34.1%
(1091)
35.3%
(1129)
16.9%
(540)
1.9% (62)
2.63
3201
Le pays d’origine du produit
10.5%
(335)
30.0%
(960)
33.2%
(1063)
25.1%
(804)
1.1% (35)
2.76
3197
answered question
3236
skipped question
3
La marque de commerce
Le fait d’avoir entendu parler du
produit
L’attrait de l’emballage
Rating
Average
Response
Count
Page 1
2. En général, lorsque vous décidez d’acheter un produit alimentaire préemballé que vous ne connaissez pas, consultez-vous
l’étiquette de ce produit?
Response
Percent
Response
Count
jamais
0.5%
16
rarement
2.1%
68
à l’occasion
8.3%
265
souvent
25.9%
833
toujours
63.2%
2032
answered question
3214
skipped question
25
3. En général, lorsque vous consultez l’étiquette d’un produit alimentaire préemballé, quels renseignements recherchez-vous?
jamais
rarement
à
l'occasion
souvent
toujours
ne sais
pas / ne
s'applique
Rating
Average
Response
Count
pas
Le poids ou le volume du contenu
de l’emballage
7.2%
(230)
17.6%
(560)
25.2%
(800)
29.7%
(944)
19.9%
(632)
0.4% (12)
3.39
3178
Le lieu de production
8.4%
(267)
19.5%
(618)
29.5%
(936)
25.4%
(807)
16.8%
(532)
0.4% (13)
3.24
3173
La liste des ingrédients
0.7%
(21)
2.4%
(76)
11.7%
(372)
32.5%
(1034)
52.5%
(1670)
0.2% (6)
4.34
3179
Le mode de préparation, s’il s’agit
d’un aliment à préparer
2.3%
(73)
8.9%
(281)
22.0%
(697)
35.6%
(1131)
30.1%
(956)
1.2% (37)
3.86
3175
Les renseignements qui ont trait à
la valeur nutritionnelle
1.1%
(36)
3.6%
(115)
14.3%
(454)
32.5%
(1031)
48.3%
(1536)
0.2% (5)
4.24
3177
La mention que des ingrédients
sont d’origine naturelle
4.8%
(152)
14.7%
(466)
26.8%
(850)
32.4%
(1029)
20.8%
(659)
0.5% (16)
3.51
3172
La teneur en gras ou le type de gras
1.3%
(42)
3.9%
(125)
11.4%
(363)
29.8%
(949)
53.4%
(1701)
0.2% (5)
4.31
3185
La teneur en sucre
2.3%
(74)
7.0%
(224)
16.1%
(512)
29.6%
(940)
44.8%
(1424)
0.2% (5)
4.08
3179
La teneur en sel
4.2%
(133)
12.5%
(397)
20.1%
(639)
27.6%
(878)
35.6%
(1132)
0.1% (4)
3.78
3183
Le nombre de calories par portion
4.5%
(142)
10.6%
(337)
20.7%
(659)
30.0%
(952)
34.1%
(1082)
0.1% (4)
3.79
3176
Page 2
La date de péremption (meilleur
avant le…)
0.4%
(13)
1.8%
(57)
5.2%
(166)
17.3%
(550)
74.8%
(2386)
0.5% (16)
4.66
3188
answered question
3201
skipped question
38
Response
Percent
Response
Count
Très bien renseigné(e)
19.9%
633
Assez bien renseigné(e)
71.1%
2268
Peu renseigné(e)
8.9%
284
Pas du tout renseigné(e)
0.1%
3
answered question
3188
skipped question
51
4. Dans quelle mesure considérez-vous être bien renseigné(e) sur la nutrition?
5. Comment qualifieriez-vous votre attitude, comparativement à celle d’il y a deux ans, concernant l’information sur les produits
alimentaires que vous achetez?
Response
Percent
Response
Count
2.7%
85
36.4%
1160
Je me sens plus préoccupé(e)
qu’il y a deux ans
59.4%
1895
Ne sais pas / sans opinion
1.6%
50
answered question
3190
skipped question
49
Je me sens moins préoccupé(e)
qu’il y a deux ans
Je me sens tout aussi préoccupé
(e) qu’il y a deux ans
Page 3
6. Que pensez-vous de l’information disponible sur les produits alimentaires que vous achetez, comparativement à celle qui
était disponible il y a deux ans?
Response
Percent
Response
Count
Il semble y avoir moins
d’information sur les étiquettes
1.9%
59
Il semble y avoir la même
information sur les étiquettes
30.5%
972
Il semble y avoir plus d’information
sur les étiquettes
64.2%
2046
3.5%
112
answered question
3189
skipped question
50
7. À votre avis, l’information sur les étiquettes des produits alimentaires est-elle facile à comprendre?
Response
Percent
Response
Count
Généralement difficile à
comprendre
27.7%
880
Généralement facile à comprendre
71.0%
2259
1.4%
43
answered question
3182
skipped question
57
Page 4
8. Lorsque vous décidez d’acheter un produit alimentaire que vous ne connaissez pas, consultez-vous le Tableau de valeur
nutritive?
Response
Percent
Response
Count
jamais
1.3%
42
rarement
4.2%
132
à l’occasion
13.9%
440
souvent
28.5%
903
toujours
52.0%
1650
ne sais pas
0.1%
4
answered question
3171
skipped question
68
Response
Percent
Response
Count
100.0%
53
answered question
53
skipped question
3186
9. Comment avez-vous appris à quoi sert le Tableau de valeur nutritive?
(Vous pouvez cocher plus d'une réponse)
Je ne sais pas à quoi sert le
Tableau de valeur nutritive
Page 5
Response
Percent
Response
Count
Par moi-même
56.0%
1749
Par un parent ou un proche
11.8%
370
Par les médias
44.9%
1402
Par une institution d’enseignement
10.3%
322
Par un professionnel de la santé ou
de la nutrition
23.7%
740
Par Santé Canada
10.5%
327
Autre (svp spécifier)
8.7%
271
answered question
3124
skipped question
115
Response
Percent
Response
Count
100.0%
106
answered question
106
skipped question
3133
10. Qui vous a appris comment utiliser le Tableau de valeur nutritive?
(Vous pouvez cocher plus d'une réponse)
Je ne sais pas comment utiliser le
Tableau de valeur nutritive
Page 6
Response
Percent
Response
Count
Moi-même
54.7%
1683
Un parent ou un proche
12.8%
395
Les médias
38.9%
1198
Une institution d’enseignement
9.4%
290
Un professionnel de la santé ou de
la nutrition
24.8%
763
Santé Canada
8.1%
249
Autre (svp spécifier)
7.3%
224
answered question
3077
skipped question
162
Response
Percent
Response
Count
Peu utile
1.4%
43
Moyennement utile
19.0%
602
Très utile
78.7%
2490
Ne sais pas/sans opinion
1.0%
30
answered question
3165
skipped question
74
11. Quelle est votre perception de l’utilité générale du Tableau de valeur nutritive?
12. À votre avis, les renseignements qui apparaissent au Tableau de valeur nutritive sont-ils faciles à comprendre?
Response
Percent
Response
Count
Oui
71.6%
2261
Non
26.2%
828
Ne sais pas/sans opinion
2.2%
68
answered question
3157
skipped question
82
Page 7
13. Avez-vous des commentaires à formuler à propos du Tableau de valeur nutritive?
Response
Count
1220
answered question
1220
skipped question
2019
14.À votre avis, est-il facile de trouver et de comprendre actuellement les informations sur les éléments suivants et,
idéalement, serait-il important d’être bien informés sur ces questions:
Facile de
savoir
Moyennement
facile de
savoir
Difficile de
savoir
Impossible
de savoir
Sans opinion
La teneur en gras
57.2% (1640)
36.0% (1032)
5.9% (169)
0.5% (14)
0.5% (13)
2868
La présence ou l’absence de
certains types de gras
28.8% (826)
47.8% (1371)
19.9% (570)
2.7% (77)
0.9% (27)
2871
La teneur en sucre
62.3% (1788)
31.5% (904)
5.4% (156)
0.5% (15)
0.3% (9)
2872
La teneur en sel
59.2% (1702)
32.4% (933)
7.4% (212)
0.5% (15)
0.5% (15)
2877
Les allégations sur la santé (ex.:
réduit le risque de maladies
cardiaques)
11.8% (337)
34.2% (980)
38.9% (1113)
12.3% (351)
2.9% (83)
2864
Les logos attestant des effets
positifs sur la santé (ex.: Choix
santé, Menu Bleu)
46.3% (1326)
33.9% (971)
13.2% (379)
3.0% (86)
3.6% (102)
2864
Les mises en garde sur les effets
de certains ingrédients sur la santé
4.5% (129)
19.9% (571)
46.1% (1320)
27.8% (797)
1.6% (46)
2863
La présence d’ingrédients naturels
15.9% (457)
46.0% (1319)
32.0% (918)
3.4% (97)
2.8% (79)
2870
La présence ou l’absence
d’ingrédients allergènes (ex. noix)
36.8% (1056)
44.3% (1272)
15.2% (437)
0.9% (25)
2.8% (79)
2869
2.0% (57)
11.4% (326)
42.7% (1222)
41.5% (1189)
2.5% (71)
2865
produits artificiels (saveurs, agents
de conservation)
29.6% (848)
47.9% (1373)
19.9% (570)
2.0% (56)
0.6% (18)
2865
27.4% (786)
43.6% (1253)
23.4% (673)
3.0% (85)
2.6% (76)
2873
Le respect des principes de
l’agriculture biologique
9.5% (271)
25.9% (742)
39.5% (1132)
19.8% (568)
5.3% (153)
2866
d’organismes génétiquement
modifiés (OGM)
Response
Count
Page 8
Les renseignements sur la
nourriture de l’élevage (ex.: poulet
6.7% (191)
29.2% (835)
40.9% (1168)
21.5% (614)
1.8% (51)
2859
L’utilisation (ou non) d’antibiotiques
ou d’hormones
0.9% (25)
4.0% (114)
31.2% (893)
62.0% (1775)
1.9% (55)
2862
L’utilisation (ou non) d’engrais
chimiques ou de pesticides
1.3% (36)
6.1% (174)
36.3% (1038)
55.1% (1576)
1.3% (37)
2861
Le traitement par irradiation
1.1% (32)
3.5% (100)
29.5% (845)
58.8% (1683)
7.0% (201)
2861
9.9% (282)
25.3% (724)
43.9% (1256)
14.6% (416)
6.3% (181)
2859
L’assurance que le produit se
distingue sur le plan écologique
3.5% (99)
17.4% (498)
45.6% (1302)
28.7% (820)
4.8% (137)
2856
Les conditions d’élevage des
animaux
0.6% (16)
3.0% (87)
27.3% (781)
67.1% (1917)
2.0% (57)
2858
Le traitement réservé aux
travailleurs qui ont participé à la
production
0.6% (17)
2.7% (76)
20.4% (584)
73.1% (2094)
3.2% (93)
2864
17.8% (509)
40.2% (1152)
31.9% (913)
6.1% (175)
4.1% (117)
2866
de grain, farine animale)
Présence des caratéristiques
requises pour être certifié
«équitable»
Les appellations d’origine contrôlée
(ex.: produit du terroir, artisanal)
Response
Count
Très important
Moy. important
Peu important
Sans opinion
La teneur en gras
85.7% (2324)
10.1% (273)
1.8% (49)
2.5% (67)
2713
certains types de gras
86.5% (2358)
11.2% (305)
1.3% (35)
1.1% (29)
2727
La teneur en sucre
84.4% (2301)
13.1% (356)
1.5% (40)
1.1% (29)
2726
La teneur en sel
82.1% (2237)
15.7% (427)
1.7% (45)
0.6% (16)
2725
Les allégations sur la santé (ex.:
réduit le risque de maladies
cardiaques)
59.5% (1625)
30.1% (822)
8.4% (230)
2.0% (55)
2732
Les logos attestant des effets
positifs sur la santé (ex.: Choix
santé, Menu Bleu)
52.5% (1432)
32.2% (877)
12.3% (336)
3.0% (81)
2726
Les mises en garde sur les effets
de certains ingrédients sur la santé
78.8% (2151)
17.5% (479)
2.1% (58)
1.6% (43)
2731
La présence d’ingrédients naturels
56.3% (1533)
35.1% (956)
6.3% (171)
2.3% (62)
2722
d’ingrédients allergènes (ex. noix)
89.1% (2424)
6.3% (172)
2.6% (70)
2.0% (55)
2721
Page 9
d’organismes génétiquement
modifiés (OGM)
67.0% (1832)
25.0% (685)
6.1% (166)
1.9% (53)
2736
produits artificiels (saveurs, agents
de conservation)
67.7% (1845)
28.7% (783)
2.5% (68)
1.1% (30)
2726
43.3% (1180)
41.4% (1127)
13.0% (355)
2.3% (62)
2724
Le respect des principes de
l’agriculture biologique
44.1% (1202)
39.1% (1066)
11.7% (320)
5.1% (138)
2726
Les renseignements sur la
nourriture de l’élevage (ex.: poulet
de grain, farine animale)
59.5% (1625)
33.7% (919)
4.9% (134)
1.9% (52)
2730
L’utilisation (ou non) d’antibiotiques
ou d’hormones
76.5% (2092)
18.8% (514)
2.8% (77)
1.9% (51)
2734
L’utilisation (ou non) d’engrais
chimiques ou de pesticides
76.7% (2099)
19.4% (532)
2.7% (73)
1.2% (34)
2738
Le traitement par irradiation
58.9% (1607)
24.2% (661)
7.2% (196)
9.6% (263)
2727
Présence des caratéristiques
requises pour être certifié
«équitable»
40.2% (1094)
42.1% (1145)
11.9% (324)
5.8% (159)
2722
L’assurance que le produit se
distingue sur le plan écologique
43.1% (1176)
40.9% (1116)
11.0% (299)
5.0% (136)
2727
Les conditions d’élevage des
animaux
47.4% (1293)
37.6% (1024)
11.4% (311)
3.6% (97)
2725
Le traitement réservé aux
travailleurs qui ont participé à la
production
40.6% (1108)
38.5% (1050)
14.1% (385)
6.7% (183)
2726
Les appellations d’origine contrôlée
(ex.: produit du terroir, artisanal)
35.6% (968)
46.9% (1277)
13.3% (362)
4.2% (114)
2721
answered question
2938
skipped question
301
15. Y a-t-il d’autres caractéristiques d’un aliment qui vous apparaissent importantes et pour lesquelles vous souhaiteriez voir
les règles d’étiquetage améliorées?
Response
Count
957
answered question
957
skipped question
2282
Page 10
16. Avez-vous des commentaires à formuler au sujet de l’étiquetage des aliments?
Response
Count
1104
answered question
1104
skipped question
2135
Si vous souhaitez recevoir par courriel nos résultats ou vous abonner à notre liste d'envoi, veuillez inscrire ici votre adresse de
courriel:
Response
Count
2093
answered question
2093
skipped question
1146
Response
Percent
Response
Count
Liste d'envoi
58.0%
1271
Résultats seulement
79.8%
1748
answered question
2190
skipped question
1049
Indiquez votre choix:
Inscrire ici le chiffre qui correspond à votre âge (ex.: 36 si vous avez 36 ans):
Response
Count
2813
answered question
2813
skipped question
426
Page 11
Quel est votre sexe?
Response
Percent
Response
Count
Féminin
69.5%
1981
Masculin
30.5%
871
answered question
2852
skipped question
387
Inscrire ici la première partie de votre code postal (ex.: H2A)
Response
Count
2865
answered question
2865
skipped question
374
Indiquez le nombre d'adulte(s) et d'enfant(s) qui composent votre ménage (inscrire un chiffre seulement; ne rien inscrire s'il n'y
en a aucun):
Response
Percent
Response
Count
Adulte(s)
99.9%
2857
Enfants(s)
53.6%
1534
answered question
2860
skipped question
379
Page 12
Quel est le niveau de scolarité le plus élevé que vous avez complété?
Response
Percent
Response
Count
Élémentaire
0.7%
20
Secondaire
19.6%
564
Collégial
32.6%
940
Universitaire - 1er cycle
33.5%
965
Universitaire - 2e ou 3e cycle
13.7%
394
answered question
2883
skipped question
356
Response
Percent
Response
Count
0 - 9 999$
2.5%
65
10 000 - 19 999$
4.6%
121
20 000 - 29 999$
8.5%
221
30 000 - 39 999$
12.9%
336
40 000 - 49 999$
13.0%
338
50 000 - 59 999$
11.8%
308
60 000 - 69 999$
10.8%
282
70 000 - 79 999$
8.7%
227
80 000 - 89 999$
7.6%
198
90 000 - 99 999$
6.4%
167
100 000$ et plus
13.2%
345
answered question
2608
skipped question
631
Dans quelle tranche se situe le revenu annuel de votre ménage?
Page 13
Y a-t-il des personnes dans votre ménage qui doivent suivre un régime alimentaire particulier à cause de problème de santé?
Response
Percent
Response
Count
Oui
32.9%
946
Non
67.1%
1931
answered question
2877
skipped question
362
À la maison, quel est le temps moyen (en minutes) consacré à la préparation d’un repas du soir? (ne pas compter le temps
passé à table)
Response
Count
2877
answered question
2877
skipped question
362
En excluant les repas du midi, quel est le nombre moyen de repas pris ou commandé au restaurant par semaine?
Response
Count
2867
answered question
2867
skipped question
372
Page 14

New Trends in Consumption and Food Information

Transcription

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