Health Canada is contemplating mandatory front-of-package (FOP) labelling for prepackaged foods high in “nutrients of public concern”, namely sugars, sodium and saturated fat. This is one of the key initiatives put forward by Health Canada as part of its Health Eating Strategy, announced on October 24, 2016. A public consultation was launched on November 14, 2016 to gather comments from all interested Canadians, including consumers, industry and health professionals, on the proposed FOP labelling.


As the incidence of diet-related chronic diseases and obesity continues to rise amongst Canadians, Health Canada strives to help Canadians make more informed food choices by presenting key nutritional information in a simplified and visible way.

At the moment, the content of sugars, sodium and saturated fats in Canadian food products only needs to be disclosed in the nutrition facts table (NFT).  According to Health Canada, identification of these nutrients can be complex for some consumers to understand and is either on the back or side of packages. Nutrient content claims and health claims that focus on positive attributes of food products may also come up short as they do not otherwise signal the presence of “nutrients of public concern”.

Several countries have already implemented FOP labelling systems in the past decade, such as Chile, the United Kingdom, Australia, New Zealand, the Netherlands, Finland, Norway, Sweden and Denmark. Evidence suggests that they do help consumers identify healthier food products.

Proposed Approach

The main elements of Health Canada’s proposed FOP labelling scheme, and the issues on which input is sought, are as follows.

1.  FOP labelling for foods high in sugar, sodium and saturated fat

The main element of Health Canada’s proposal is the introduction of a mandatory FOP nutrition symbol on prepackaged foods that exceed certain amounts of sugars, sodium and saturated fats.

In addition to facilitating Canadians’ ability to make healthier choices, Health Canada hopes that this measure will encourage industry to provide more food products that are lower in the “nutrients of concern” through reformulation, in order to avoid FOP labelling.

2.  Thresholds for FOP labelling

FOP labelling would be required for foods that have more than 15% of the daily value of sugar, sodium or saturated fat, i.e., equal to / more than:

  • 15 g of sugars;
  • 345 mg of sodium; or
  • 3 g of saturated fat.

Other thresholds would apply to foods intended solely for children of one to three years of age to account for differences in nutritional needs. For foods with small reference amounts (i.e. foods that are typically consumed in small quantities, such as condiments), Health Canada is proposing that the threshold be based on 50 grams (or 50 millilitres for liquids).

Some food products would be exempted from FOP labelling. For example, prepackaged foods that are already exempted from displaying a NFT would also be exempted from FOP labelling. This includes products with very small packages, small individual packages usually served in restaurants, food produced and prepackaged by retailers (such as meat cuts and bakery products) and alcoholic beverages. Health Canada is also proposing to exempt packages of sugar and salt, as it is obvious that these products are high in sugar and salt respectively.

3.  Symbols for FOP labelling

Health Canada is considering various symbols that could be used for FOP labelling. These symbols will eventually be submitted to focus groups to determine which are the most simple and intuitive to understand. Examples under consideration are as follows:

Symbols for FOP labelling


4.  Updates of nutrient content claims and other nutrition-related statements

Nutrient content claims and other nutrition-related statements are also under scrutiny, as Health Canada proposes to introduce new regulated claims and change applicable standards for some currently regulated claims to bring them in line with the proposed FOP approach.

For example, current regulation allows the use of claims like “no added sugars” or “unsweetened” on foods that would be considered “high in sugars” under the proposed FOP labelling system. The conditions of use for these claims would be changed to align the meaning of “added sugars” with the new definition of “sugar-based ingredients”, and to forbid using these claims on fruit juices that meet the threshold for “high in sugars”. The conditions for the use of “free of sugars” would also be modified, and the “low in sugars” and “lightly sweetened” claims would be introduced as regulated claims.

Other changes related to the use of quantitative declaration of “0 g sugars” and “0 g trans fat” outside of the NFT, the use of the “lean” claim, the representation of the amount of alcohol in beverages containing 0-0.5% alcohol and the age limit for foods intended solely for young children are also envisioned.

5.  High-intensity sweetener labelling

Health Canada proposes to eliminate the requirements to declare the presence of high-intensity sweeteners on the front of packages, namely sucralose, acesulfame-potassium and neotame, as well as the quantity of these sweeteners in food products. These changes are meant to eliminate redundancy, as these sweeteners are already identified in the list of ingredients. They would also bring Canada in line with other jurisdictions, such as the United Kingdom, the United States, the European Union and Australia / New Zealand, that do not require FOP declarations for these sweeteners.

With regard to aspartame, Health Canada also considers eliminating the FOP and quantitative declarations, but specifically invites comments on the risks for individuals with a rare condition called phenylketonuria (PKU), who must avoid the consumption of phenylalanine, an amino acid found in aspartame. The requirement to state “contains phenylalanine” near the list of ingredients of aspartame-containing foods would remain untouched. Health Canada will be reaching out to health professionals directly involved in the care of individuals with PKU, and to PKU advocacy groups in regard of this measure.

Relevant documents and further consultations

The consultation is available online (consumer questionnaire link; consultation document link; technical questionnaire link) until January 13, 2017. Health Canada plans to have further consultations in June 2017.

Special thanks to Peggy McGurran for her assistance in drafting this post.