This page outlines guidance for labelling and advertising of plant-based alternatives to egg products. The Canadian Food Inspection Agency provides a transition period and industry must comply with the guidance by January 1, 2030.
On this page
- Overview
- Labelling and advertising elements
- Overall impression
- Examples comparing misleading and non-misleading plant-based alternatives to egg products
Overview
This page outlines guidance for labelling plant-based alternatives to egg products to promote compliance with subsection 5(1) of the Food and Drugs Act (FDA) and subsection 6(1) of the Safe Food for Canadians Act, which prohibit false and misleading labels or advertisements regardless of the level of trade.
This guidance also aims to assist industry to comply with provisions prohibiting the import or interprovincial trade of a food intended for sale, for which a standard is prescribed that is likely to be mistaken for the standardized food unless the food complies with the prescribed standard [6, FDA; 9(2), SFCR].
Plant-based alternatives to egg products do not meet the standards for processed egg products in the Safe Food for Canadians Regulations (SFCR) or the compositional standards for egg products in the Food and Drug Regulations (FDR). The FDR and the SFCR do not provide a definition of plant-based foods. Many plant-based foods could be described as vegetarian or vegan. Consumers would expect plant-based alternatives to egg products to be usable in place of an egg product.
The labelling requirements detailed in the following sections are specific to plant-based alternatives to egg products. Refer to the Industry Labelling Tool for additional core labelling requirements and voluntary claims and statements that apply to all prepackaged foods.
Labelling and advertising elements
All elements on food labels or in advertisements contribute to the overall impression created about a product to determine whether the label or advertisement may be misleading. This section provides product-specific guidance on labelling and advertising elements when assessing the overall impression of labels and advertisements for plant-based alternatives to egg products.
Common name
Plant-based alternatives to egg products must have an appropriate common name on the principal display panel of the label, in letters of 1.6 mm or greater [B.01.006(1), FDR; 210(2), SFCR]. The common name for a food without a prescribed standard is the name by which the food is generally known or a name that is not generic and that describes the food [B.01.001(1), FDR; 1, SFCR].
The common name used for plant-based alternatives to egg products should accurately describe what that food is, not only what it is not. For example, the common name "plant-based omelette" does not accurately and precisely describe what the food is; the common name "soy-based omelette" is more explicit.
The common name must not mislead the consumer about the product's:
- basic nature
- properties
- nutritional content
For example, a prominently displayed common name, "soy-based omelette" may contribute positively to the overall impression created about the food. The common name accurately describes the product and prevents or reduces the risk that a consumer will mistake it for an egg product. Other examples of common names for plant-based alternatives to egg products could be "chickpea protein scramble" and "Adzuki-based breakfast bites with chives."
If terms associated with common names for standardized egg products (for example, liquid yolk) and unstandardized products (for example, "scramble" and "omelette") are used as part of the common name or brand name of plant-based alternatives to egg products, they should be qualified or presented in an appropriate way to avoid being misleading.
For example, when the standardized term "liquid egg product" is used, it must be used with a qualifier. Appropriate common names could be "soy-based liquid egg product" or "soy-based alternative to liquid egg product". These qualified common names contribute to the overall impression of the food to make it clear it is not a liquid egg product for which there is a standard.
Claims and statements
Comparative nutrient content claims
Plant-based alternatives to egg products may also include claims that compare it to an egg product as long as the claims are:
- permitted
- truthful
- not misleading
These types of claims may contribute to the overall impression created about the food by highlighting differences or similarities to egg product counterparts.
The claim should not create the impression that the plant-based food product is an egg product. Refer to Comparative nutrient content claims for more information.
Negative claims and allergen declarations
Terms normally associated with egg products may be part of a claim or statement as long as they avoid creating a misleading impression. For example, claims such as "contains no eggs" or "egg-free", which are referred to as negative claims, contribute to the overall impression of the food.
Claims must not be misleading regarding the presence of allergens. For example, a "contains no eggs" statement cannot be used if that product contains any egg allergen. For more information on allergen declarations, see the Allergen-free claims section on the Allergen-free, gluten-free and cross-contamination statements page.
Images (pictures, vignettes and logos)
Labels and advertisements may contain images that show or imply that plant-based alternatives to egg products resemble or are comparable to egg product counterparts.
For example, an illustration of an omelette on a liquid plant-based alternative to egg products. This element on its own could be considered misleading by giving the impression that the plant-based food product is an egg product. Care should be taken when using such images. The location and prominence of the image, as well as other elements on the label, are considered to help determine how an image contributes to the overall impression of the product.
Trademarks
This guidance also applies to trademarks and brand-names. Refer to Trademarks on food labels for more information.
Appearance and representation
How plant-based alternatives to egg products appear and are represented at the time of sale may contribute to the overall impression by either resembling or differing from its egg product counterpart, including how it is:
- packaged
- advertised
- marketed
For example, a carton of a liquid plant-based alternative to egg products could resemble a carton of liquid egg product due to its packaging type, consistency and shape. Other elements on the label, such as having a prominently displayed common name that accurately describes the food, contributes to the overall impression that the plant-based alternative is not an egg product. In this case, the overall impression of the product would not be considered misleading.
Overall impression
Certain elements such as words, images and packaging, that are normally associated with egg products, may be used on plant-based alternatives to egg products provided they are not misleading about the true nature of the food [B.01.006.1, FDR].
To avoid being misleading, all elements related to the labelling or to the representation of the plant-based alternative to egg products must provide sufficient information so:
- the consumer understands what the product is
- it is clear the product is not an egg product
When a labelling element viewed alone could be considered misleading, other elements could help prevent a misleading impression of the product. Viewed together, all elements should provide consumers a true impression of what the product is by giving complete and clear information. The list of ingredients, by itself, may not be enough information to prevent a misleading impression. Refer to overall impression created about a product for more details.
The more elements closely associated with egg products (for example a descriptor, like omelette, in the common name), the more likely the label of the plant-based alternative is to be misleading. In this case, the regulated party should consider removing some potentially misleading elements and/or adding further elements to help clarify the true nature of the food. In all cases, representations must be truthful.
Examples comparing misleading and non-misleading plant-based alternatives to egg products
Example 1: Misleading plant-based liquid egg product label
Soy-based liquid egg product in packaging typically used for liquid egg product
Elements on the label:
- the common name "plant-based liquid egg product" with the term "plant-based" presented in very small font above the term "liquid egg product"
- "omelette" statement
- image of a farm
Assessment:
- the term "liquid egg product" is more prominent than "plant-based" which could lead to confusion about the true nature of the food
- the term "plant-based" in the common name is vague and does not provide sufficient information for the consumer to know what the food precisely is
- an "omelette" statement can refer to how the product can be prepared
- the "omelette" statement, along with the common name, does not provide enough information for the consumer to know what the food precisely is
- when viewed along with the common name and the "omelette" statement, the image of the farm could be interpreted as a farm where chickens were raised to produce eggs, a major ingredient of a liquid egg product
All of the elements viewed together give the erroneous impression that the food is a processed egg product, since none of the elements clarify the true nature of the product.
To reduce any likelihood of creating an erroneous impression, select a common name that accurately describes what that food is and display it using the same font size for the entire common name. It would also be helpful to:
- remove potentially misleading elements, such as the image of the farm
- include other elements clarifying the true nature of the product, as suggested in the example below
With an appropriate common name and the use of other labelling elements, the "omelette" statement may not be misleading.
Example 2: Non-misleading plant-based liquid egg product label
Soy-based liquid egg product in packaging typically used for liquid egg product
Elements on the label:
- the common name "soy-based liquid egg product" is prominently displayed, legible and uses the same font size for all the words in the common name
- "contains no egg" claim
- image of an omelette
Assessment:
- the common name "soy-based liquid egg product" accurately describes what the food is and is easily visible and equally prominent
- the claim provides additional information to clarify that the product is not egg-based
- the image provides a visual about how the product could look when prepared
All of the elements viewed together gives a clear impression about the true nature of the product.