Volume 11, Number 8 - August 2010

Hello from Food Label News. As the summer hits full swing, kick back, relax and enjoy this issue of Food Label News. You'll learn about the differences in food label requirements between U.S. and Canada and be introduced to a new series for FDA food label requirements. Happy August!

In this issue you'll find:

Food Labels in U.S. & Canada:
The same and different
5 Must-Haves for FDA Food Labels: Instructional Series Part 1 of 5
Reader Q&A: Insoluble fiber and calories
Helpful links to keep you current

Karen C. Duester, President

"Thank you for getting back to us so fast. This is the second time we have used your services. Your follow-up and customized service perfectly meet our expectations. Thank you."

– Mathieu Senard,
Alter Eco Americas

Food Labels in U.S. & Canada:
The same and different

The U.S. and Canada have a long history of harmonizing food label requirements. Yet, today it is not possible to have a food label that satisfies the requirements in both countries. Can we simply add French to a U.S. label and expect the product to effortlessly pass through Canadian customs?

The answer is a resounding NO. Each country has different requirements for formatting the Nutrition Facts ("Panels" in the U.S., "Tables" in Canada – ah, the differences begin). A sampling of other differences include:

Rounding rules: e.g., Canada has tighter reporting requirements for trans fat
Nutrient units: e.g., International Units (IU) are used for Vitamin A in the U.S.; Canada uses Retinol Equivalents (RE)
Daily Value for some nutrients: e.g., Calcium and Iron
Ingredient/allergen declarations: e.g., baking powder requires a parenthetical listing of sub-ingredients in the U.S. but not in Canada
Net quantity of contents statements: e.g., NET WT 4 oz (113g) note no space before the "g" in the U.S., whereas it appears simply as 113 g with a space in Canada
Nutrition/health claims: e.g. Canada defines "source of" as 5% or more of Daily Value; in the U.S. this is an undefined claim that cannot be used unless the "good source" requirement of 10% or more is met

Labeler beware! The differences extend beyond labeling to formulation. For example, not every ingredient allowable in the U.S. is also allowable in Canada and vice versa; food colors can also be an issue.

Be aware. Don’t let your products be the ones detained at the border.

Keeping You Current

New federal requirement for restaurant menu labeling: FDA issues a news release and federal register notice seeking comment, in advance of proposed rule to be issued by March 23, 2011

FDA constituent update and federal register notice specifies terms and conditions for voluntary participation in federal menu labeling program

Concise overview of the law that establishes new federal requirement for menu labeling in May 2010 Food Label News

Press reports indicate more restaurants are now promoting healthy menu options and making more nutrition/health claims

CDC report includes findings that 90% of U.S. adults consume too much sodium

Health Canada issues a news release about the Sodium Working Group's report titled "Sodium Reduction Strategy for Canada"

Petition asks IOM to re-examine DRI's for EPA & DHA omega-3 fatty acids

FTC news release and federal register notice about probiotic health claim advertising

CSPI news release on lawsuit for health promotion claims on vitaminwater labeling


	Understanding the nuances between U.S. and Canadian labeling and formulation requirements can be tricky. Access a side-by-side comparison of nutrition/health claims for the U.S. and Canada here.

5 Must-Haves for FDA Food Labels:
Instructional Series Part 1 of 5

There are five required components for every FDA-regulated food label. These requirements are divided into the Principle Display Panel (PDP, front of the package) and the Information Panel (IP, right side/back of the package). PDP requirements include the statement of identity and the net quantity of contents; IP requirements include the nutrition facts panel, ingredient/allergen statement and signature line. In the next several issues of Food Label News, we will overview each requirement and what you need to know.

Product Identity

Naming a product can be challenging. As food companies, we must give consumers a full description of what's in the package beyond the brand name. Notice that while Cheerios is generally understood to be a breakfast cereal, General Mills is required to state Cheerios are "toasted oat cereal" on the package's principle display panel to meet FDA regulations.

In addition, naming a product must also meet any existing Standards Of Identity (SOI) requirements. Ice cream, for example, must have a specified set of ingredients and amount of milkfat and nonfat milk solids to be labeled as "ice cream" - otherwise the acceptable product identity would be "frozen dessert" with other relevant descriptive terms.


	Once you determine the correct product identity, it must be placed in bold prominent lettering (at least half the largest type size, to be conservative), generally parallel to the base of the container on the principle display panel. This typically accompanies a brand name but a brand name is not required.

Reader Q&A

Find answers to our readers' questions or send us your question for an upcoming issue.

Q.	Our ingredient supplier insists that insoluble fiber does not need to be included in total calories, however this would not make sense in context of the 4-4-9 formula. Is it allowable to have insoluble fiber listed as part of carbohydrates on the Nutritional Facts Panel but not included in the calorie consideration? − C.A., Established Food Company, Massachusetts
A.	In the U.S., your ingredient supplier's approach is allowed according to FDA regulations. In Canada however, this approach is not allowed. Read more.

At Your Service

Food Consulting Company, founded in 1993, provides nutrition analysis, food labeling and regulatory support to ensure 100% compliance with FDA regulations. With over 1,000 clients worldwide, Food Consulting Company's services are ideal for start-up and established food manufacturers, distributors, food importers, brokers, and restaurateurs. Contact Us for more information about your food labeling needs.

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