What We Heard Report – Consultation on the proposed amendments to Canada's beer standards of identity
The Canadian Food Inspection Agency (CFIA) is proceeding to amend the beer standards under the Food and Drug Regulations and has published a Notice of Intent to validate stakeholder's positions, reflect existing industry needs and communicate to stakeholders the most current policy direction. The purpose of the amendment is to better reflect marketplace realities and industry innovation in brewing while maintaining the integrity of beer.
This report summarizes the comments received as a result of the publication in the Canada Gazette Part I of the Notice of Intent to modernize the beer standards of composition. The views expressed herein are those of the participants and do not necessarily reflect those of the CFIA or the Government of Canada.
- The Notice of Intent to amend the beer standards was published on June 17, 2017 in the Canada Gazette, Part I. The end of the comment period was August 15, 2017.
- During the comment period, the CFIA notified its international partners through a World Trade Organization (WTO) notification and reached out to provincial liquor boards, provincial associations of microbrewers, and Beer Canada.
- An economic survey was distributed to hundreds of stakeholders on July 28, 2017, with a response deadline of August 25, 2017.
Who we heard from
A total of 161 submissions were received by e-mails during the comment period, with the following breakdown:
- 74% (119) from consumers, including members of food allergy associations
- 13% (20) from brewers
- 7% (11) from provincial liquor boards and governments, health professionals and beverage industry
- 6% (11) from associations
One comment was received through the WTO notification process.
What we heard
The comments received are summarized below with some general comments added. The answers submitted as part of the economic survey have been analyzed to inform the associated costs and benefits to the beer industry.
Many elements of the proposed revisions to the beer standards of identity received support from the majority of respondents. The rationale respondents provided for this support was that a modernised single standard would remove duplication, provide clarity and simplicity, and would allow industry to be more innovative in product development while maintaining the integrity of beer.
Elements well supported
- Repealing the standard for Ale, Stout, Porter and Malt Liquor
- Removing references to specific additives from the beer standard, since these already appear in the Lists of Permitted Food Additives from Health Canada
- Removing the statement related to the aroma, taste and characteristic associated with beer
- Clarifying the term carbohydrate matter by providing examples, and when such ingredients may be added
- Allowing flavouring preparations if declared as part of the common name
Elements with mixed reactions
- Mandatory "barley or wheat malt" in the definition of beer
- Comments were received stating that the malt portion should not need to include barley or wheat and should be derived from any cereal grain to allow for greater flexibility and innovation for industry; and allow current beer-like products derived from non-gluten containing grains to be included under the beer standard.
- The majority of brewers provided comments that barley be maintained as a mandatory ingredient in beer.
- Adding a 4% limit in weight of sugar
- The majority of respondents supported this new requirement to maintain the integrity of beer.
- Those who were not supportive were concerned that this may exclude some styles of beer, hinder craft beer development and creativity, and may have trade implications.
- Repeal of the exemption for beer from the mandatory labelling of food allergens, gluten source and added sulphites
- The majority of respondents, who were consumers, supported this change to require full labelling of all food allergens, gluten sources and added sulphites.
- Those who were not supportive of the labelling exemption repeal indicated that consumers are already aware that beer is made from barley or wheat malt.
We would like to thank everyone who contributed their time, shared their views and participated in the consultation process. The feedback received will be considered by the CFIA as it works to amend the beer standards.
We anticipate pre-publishing the proposed modernized beer standard, along with Health Canada, in the Canada Gazette Part I, in Spring 2018.
Once the proposed regulations are published in the Canada Gazette Part I, interested parties will again have an opportunity to submit comments.
- Consultation on proposed changes to Canada's beer compositional standards – Notice of Intent
- Notice to Industry – Notice of Intent on proposed changes to Canada's beer compositional standards
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