September 10, 1999
To:Board of Health
From:Dr. Sheela V. Basrur, Medical Officer of Health
Subject:Response to 1999 Health Canada's Nutrition Labelling Policy Review
Purpose:
To inform the Board of Health about the benefits of nutrition labelling and to request that the Board urge Health Canada to
make nutrition labelling mandatory on all foods and to allocate resources to the development of a consumer education
campaign to support the new food labelling system.
Source of Funds:
Not applicable.
Recommendations:
It is recommended that:
1. the Board of Health, in response to Health Canada=s Nutrition Labelling Policy Review, urge the Federal Minister of
Health to make nutrition labelling mandatory on all foods in Canada and to allocate resources to the development of a
comprehensive consumer education plan to ensure that Canadians can understand and use nutrition labels to make healthier
food choices;
2. the Board of Health forward this report to other Boards of Health in Ontario, the Ontario Public Health Association and
the Canadian Public Health Association and request them to join in advocating for mandatory nutrition labelling in Canada.
Background:
Diet plays a critical role in preventing diseases of public health significance, such as heart disease, cancers, osteoporosis,
obesity and other illnesses (see Appendix A). Chronic diseases are the leading causes of death in Ontario. The Mandatory
Programs and Services Guidelines (1997) contain the goal of reducing premature mortality and morbidity from preventable
chronic diseases. One of the strategies for the prevention of chronic disease is to promote and support healthy eating.
Mandatory nutrition labelling is a key policy that will promote informed food choice by providing consumers with reliable
and comparable information that reflects current nutrition recommendations. The 1996 national nutrition plan, Nutrition
for Health: An Agenda for Action, identified improving the nutrition labelling system as a priority action to be undertaken
to support healthy eating. Health Canada established the following goals for nutrition labelling: improving the usefulness
of nutrition labelling, increasing its availability, and broadening public education on the use of nutrition labelling.
Not only was this policy review supported by the national nutrition plan, but the Canada/U.S. Free Trade Agreement
(article 708) stated that we will Awork toward equivalent requirements for food standards including labelling.@ (New
nutrition labelling regulations came into effect in the U.S. in 1994).
Health Canada launched its nutrition labelling policy review in February 1998 and provided a consultation period for
interested stakeholders. Whether nutrition labelling should be mandatory or voluntary is the most critical aspect of the
consultation. Four aspects of nutrition labelling were covered in the consultation: content, format, availability and
education. Toronto Public Health staff developed a detailed response to the consultation and submitted comments to Health
Canada to meet the July 31, 1999 deadline.
Discussion:
(A) NUTRITION LABELLING
Food consumption decisions play a major role in all consumers= daily lives, and these decisions are complex and not
completely understood. With only 10% of families having a stay-at-home spouse and 18% of children under 10 years of
age living in lone parent families, meal preparation has changed dramatically over the past twenty years. A hectic lifestyle
and a limited income are major barriers to healthy eating(1). A 1998 study of consumer attitudes identified lack of time as
the main reason Canadians do not cook more often and found that only 32% of Canadians prepared their last dinner at
home completely from scratch(2).
Ninety percent of Canadians recently surveyed reported that nutrition is quite/very or extremely important to them in their
food purchase decisions(3). While consumers differ with respect to their understanding of the diet-health relationship, their
knowledge of nutrition information and their propensity to read and understand food labels, 74% of Canadians are of the
opinion that nutrition labelling should be provided on all foods(3).
Food labelling in Canada is regulated primarily under the authority of the Food and Drugs Act. Regulations under this Act
require that food labels contain, among other things, the following basic information: common name, list of ingredients,
name and address of the manufacturer or other responsible party, durable life information on products with a shelf life of
up to 90 days, and other product specific information (such as percentage milk fat in certain dairy products). In addition,
there are guidelines controlling nutrition and marketing claims.
The term "nutrition labelling" refers to the nutrition information panel on a food label. It consists of a heading "Nutrition
Information" followed by a statement of serving size and the nutrients declared on a per serving basis. Nutrition labelling
in Canada is largely voluntary at the current time. Only when a nutrient content claim is made on a food label, (e.g. "low
calorie") is the nutrient content declaration per serving of stated size required to appear on the label. When the nutrition
labelling format is used (see Appendix B) the "core list" of nutrients must be included; this consists of energy (in both
calories and kilojoules), protein, fat and carbohydrate (in grams).
The United States Food and Drug Administration (FDA) regulations pertaining to nutrition labelling came into effect in
1994 making nutrition labelling mandatory on about 90% of processed foods. Exemptions include plain coffee and tea,
some spices, flavourings and other foods that contain no significant amount of nutrients, ready-to-eat food prepared
primarily on site such as deli and bakery items, restaurant foods, bulk food that is not resold, and food produced by small
businesses (defined by established criteria). Nutrition information is not required on raw foods such as fruits, vegetables,
fish, meat and poultry, but there are strong incentives for retailers to participate in the voluntary nutrition labelling program
(guidelines state that if compliance is found to be insufficient, the programs may become mandatory).
Mandatory nutrition labelling is a healthy public policy that has the potential to give consumers more control over their
health by providing them with the tools they need to make healthy food choices. Toronto Public Health believes that
consumers will benefit when they know what is in the food they are buying. A result of increased access to nutrition
information is that consumers can change their food purchase habits to improve their diet and reduce their risk of heart
disease, cancer, osteoporosis and other illnesses. In response, producers will experience some pressure to reformulate
existing products and introduce new, more healthy products.
Given the complexity in motivating behavioural change and the limited history of nutrition labelling, it is not surprising
that minimal evidence has thus far been accrued about the impact of nutrition labelling on public health. A study on the
potential health benefits associated with expected changes in food consumption resulting from the changes in nutrition
labelling in the U.S., found that relatively small changes in nutrient intakes may generate large public health benefits, in
terms of life-years gained from the reduction of heart disease and cancer.(6) A just published U.S. study(4) found that the
use of food labels was associated with decreased fat intake. This study provides support for the usefulness of nutrient
information on food labels in reinforcing positive dietary behaviour among individuals who are concerned about nutrition
and health.
Nutrition labelling should be mandatory on all foods in Canada, not just on foods about which manufacturers choose to
make a marketing claim that triggers disclosure requirements, as is the current practice. The current system provides little
information for consumers who are generally concerned about their diet, but it is especially frustrating for people who have
been advised by their health care providers to modify their diet to reduce their risk of disease.
In order for this policy to be a success, Health Canada must provide leadership by developing and providing adequate
resources to support a comprehensive consumer education plan to help Canadians understand the new nutrition labelling
system. While it is expected that Public Health will play a key role in consumer education, a comprehensive plan is
required to ensure that consumers receive consistent messages in easy-to-understand language.
Toronto Public Health has played a role in labelling education in the past. Public Health Nutritionists developed a resource,
"Skills for Food Shopping", for English as a Second Language (ESL) teachers to help students understand Canada's Food
Guide to Healthy Eating and develop label-reading skills. In addition, public health staff incorporate healthy eating
messages and label reading into a number of on-going nutrition programs. In the future, it is expected that public health
programs will be developed to assist consumers to understand the new nutrition labels and make healthier food choices.
(B) RELATED FOOD LABELLING POLICY OPTIONS
Simultaneous to this nutrition labelling policy review, Health Canada has been reviewing the policy on generic health
claims and nutrient content claims. In the U.S. there is a solid link between health claims and nutrition labelling, and
between nutrient content claims and nutrition labelling. Claims focus on an aspect of food that the manufacturer elects to
highlight, but consumers need information about the whole product if they are to make an informed choice. Therefore,
nutrition labelling is essential if nutrient and health claims are to be permitted in Canada.
(i) Nutrient Claims:
Nutrient content claims describe the level of a nutrient in a food, for example "fat free", "cholesterol free", "source of
fibre". Health Canada has completed their review of nutrient content claims.
(ii) Health Claims
Health Canada has established a policy regarding health claims. It states that "Structure/function and risk reduction claims
for foods should be permitted, while all other products claiming to cure, treat, mitigate or prevent illness should continue to
be regulated as drugs.". In the U.S. health claims have been defined as "any claim on a label ... of a food... that
characterizes the relationship of any substance to a disease or health-related condition.". Increasingly, U.S. food processors
are marketing functional foods, i.e., foods that claim to provide health benefits to consumers normally beyond the
nutritional benefits offered by the food itself. These include foods that claim to reduce cholesterol or improve
concentration; the foods range from breakfast cereal with psyllium to snack bars with amino acids.
These foods present regulatory challenges since it is important that scientifically valid health information be communicated
effectively. The scientific evidence to support health claims is still evolving, and the introduction of a policy which
inadequately regulates these claims may result in a marketplace flooded with exaggerated claims and products of dubious
benefit. Consumer groups have expressed concern regarding the approaches taken with respect to the regulation of health
claims by the governments of Japan, the United States and the United Kingdom for failing to protect consumers from
"dubious health claims and poorly tested ingredients"(5).
Health Canada has developed a three-pronged approach to implementing the policy option for health claims which
includes: 1) seeking advice from stakeholders on an implementation strategy for adopting U.S. generic health claims; 2)
developing a regulatory framework to allow for new health claims, and; 3) developing standards of evidence for
submissions of new generic health claims. Toronto Public Health staff are developing a detailed response to the
stakeholder consultation on the implementation strategy for health claims to submit to Health Canada for the September
deadline.
(iii) Genetically Engineered Foods
One of the most controversial and complex food labelling policy options relates to the labelling of novel foods derived
through genetic engineering. Canada and 143 other member states of the joint international food standard setting
organization, the Codex Alimentarius Commission, an agency of the United Nations World Health Organization and Food
and Agriculture Organization, are evaluating questions regarding appropriate labelling requirements of novel foods derived
from genetic engineering.
Novel foods are: i) foods that have not previously been used as food, ii) foods from a process not previously used for food
in Canada, or iii) foods modified such that: a) the food results from genetic manipulation and exhibits one or more
characteristics that were not previously identified in that food, or the food results from production by a genetically
manipulated organism exhibiting such new characteristics, b) the food contains microorganisms not previously used as
food or to process food, or c) the food is modified from the traditional product or produced by a process that has been
modified from the traditional practice ("Novel Food Guidelines", September 1994).
At the current time, a blanket statement on the label of novel foods derived through genetic engineering is not required in
Canada. Foods produced through biotechnology that have undergone nutritional or compositional changes or that present a
health risk, such as allergenicity, that could be mitigated through labelling, are all subject to mandatory labelling. Other
foods developed through genetic engineering can be labelled voluntarily by food companies under Canadian law as long as
the labelling message is truthful and not misleading.
The European Union has instituted regulations requiring labelling on all genetically engineered food. Canadian consumer
and environmentalist groups are campaigning for mandatory labelling of genetically engineered foods. As of June 1999, a
number of genetically engineered crops have been approved for use in Canada, including canola, corn, flax, potato,
soybean, squash and tomato and none of these are currently required to be labelled.
Toronto Public Health is monitoring debates and studies regarding genetically engineered foods, including labelling and
regulation of these products. We will report further to the Board of Health as the need arises.
Conclusion:
Diet plays a critical role in the prevention of diseases of public health significance, such as heart disease, cancer,
osteoporosis and obesity. The Board of Health should urge Health Canada to adopt mandatory nutrition labelling on all
foods in Canada so that consumers can choose a healthier, more nutritious diet. Furthermore, nutrition labelling is essential
if nutrient and health claims are to be permitted in Canada. To support the improved nutrition labelling system, Health
Canada should provide resources to develop and support a comprehensive consumer education plan. Health Canada should
be commended on their decision to undertake a broad consultation among stakeholders on the proposed nutrition labelling
reform and should use a similar format to review other policy options such as the review of labelling of genetically
engineered foods.
Contact Names:
Connie Clement
Director, Public Health Planning and Policy
Public Health
Tel: 392-7463
Fax: 392-0713
cclement@toronto.ca
Mary-Jo Makarchuk
Nutritionist
Public Health
Tel: 395-7685
Fax: 395-7691
lpp-mjm@city.north-york.on.ca
Dr. Sheela V. Basrur
Medical Officer of Health
References:
(1) National Institute of Nutrition. Tracking Nutrition Trends 1989-1994-1997.
(2) Food and Consumer Products Manufacturers of Canada and Readers Digest. A Matter of Taste Catering to the Cultural
Palate. 1998.
(3) National Institute of Nutrition. Nutrition Labelling Consumer Research. 1999.
(4) Neuhouser M, Kristal A, Patterson R. Use of food nutrition labels is associated with lower fat intake. J Am Diet Assoc.
1999;99:45-53.
(5) The International Association of Consumer Food Organizations. Functional Foods Public Health Boon or 21st Century
Quackery? An International Comparison of Regulatory Requirements and Marketing Trends. 1999.
(6) Zarkin G, Dean N, Mauskopf J, Williams R. Potential Health Benefits of Nutrition Label Changes. Am J Public Health.
1993; 83:717-724.
