CFA Submits Comments on Health Canada Front-of-Pack Labelling Regulations

On April 26th, CFA submitted its comments on the Canada Gazette 1 publication of draft Regulations Amending Certain Regulations Made Under the Food and Drugs Act (Nutrition Symbols, Other Labelling Provisions, Partially Hydrogenated Oils and Vitamin D).

The proposed regulations lay out the framework for proposed Front-of-Pack labels that would require all food products sold in Canada, unless otherwise exempted, from placing labels on the front of their packages to indicate if they exceed thresholds in saturated fat, sugar, or sodium. The consultation on these draft regulations ran concurrently to a separate consultation on proposed symbols for front-of-pack labels, in which CFA did not participate because the consultation format not allow respondents to comment on underlying principles or provide unbiased input on the available options. The consultation directed participants to support Health Canada’s proposed labelling approach and for this reason, CFA chose to provide its feedback through its submission to Canada Gazette I.

Based on a series of clearly articulated concerns, the CFA’s submission made a series of recommendations, including:

  1. A comprehensive and transparent review of the evidence base to determine whether there is support for FOP labels focused on three nutrients of concern;
  2. Additional analysis of existing mandatory FOP labelling regimes, particularly the model in Chile, to determine whether there is sufficient evidence of efficacy and improved health outcomes to adopt such an approach; and
  3. Development of a comprehensive cost-benefit analysis within the RIAS that is grounded in evidence and provides comparable analysis of both costs and benefits associated with the proposed regulation.

For more information on this submission or front-of-pack labelling, please contact Scott Ross.