General information on simulated meat and simulated poultry products
Simulated meat productsFootnote 1 and simulated poultry productsFootnote 2 are foods that do not contain any meat product, poultry product or fish product and have the appearance of meat or poultry products.
Most prepackaged foods require a common name to be shown on the principal display panel of the food label.
The names for some foods for which prescribed standards exist appear in bold face type in the Food and Drug Regulations (FDR), in the Canadian Standards of Identity document, which is incorporated by reference in the Safe Food for Canadian Regulations (SFCR). These names are the prescribed common names and are the only ones permitted to be used to describe the standardized food.
When there is no prescribed name, the common name is the name which is usually used when individuals, speaking English or French, refer to or describe the product.
For more information on common names for commodity specific foods, visit the food-specific labelling requirements of the Industry Labelling Tool.
Regulatory requirements for simulated meat and simulated poultry products
The FDR (B.01.100(1)) provide the regulatory requirements for simulated meat and simulated poultry products. These products must:
- be clearly represented as simulated
- be clearly labelled as such
- meet specific requirements for composition and fortification
The common name of a simulated meat or simulated poultry product is the common name of the meat or poultry product that is simulated, modified by the word "simulated". These products must carry the declaration "contains no meat" or "contains no poultry" on the label, next to the common name.
The FDR requires that simulated meat and simulated poultry products provide nutritional components similar to those of meat or poultry, because such a product is intended to replace meat or poultry products and/or is represented in the Canadian marketplace as an alternative to these foods.
These products do not contain meat, poultry or fish product, have minimum protein content and rating requirements as well as the specific requirements for fat content. Simulated meat and simulated poultry products are also subject to mandatory specific fortification requirements.
Updating the guidance
The current market of plant-based protein food products continues to grow, and there are several non-meat products in the market, which resemble meat and poultry products. Some of these, such as simulated meat and simulated poultry products have specific regulatory requirements. However, there are several other products coming into market which may or may not meet the regulatory requirements for simulated meat and simulated poultry products.
The existing CFIA Industry Labelling tool guidance describes the regulatory requirements for simulated meat and poultry products, but does not address the other plant-based protein foods. Industry has informed the CFIA of the need for clearer guidance for these plant-based foods which are neither meat nor poultry and not intended to substitute for meat or poultry products.
The proposed changes in the updated guidance
The proposed changes to the CFIA's guidance on simulated meat and simulated poultry products would assist manufacturers or importers of meat and non-meat products position their product as either:
- a meat or poultry product as defined in FDR
- simulated meat or poultry product as defined in FDR, or
- another product that is not a meat or poultry substitute
This approach would allow the CFIA to enforce existing labelling, compositional and fortification requirements depending on how the product is positioned by the manufacturer or retailer. It also aligns with the SFCR provisions for preventative controls, which puts the onus on businesses to have preventive controls and preventive control plans that demonstrate how their products meet any prescribed composition, nutritional and labelling requirements.
The proposed guidelines also specify that the common name and the overall representation of the food must clearly identify its true nature. This will help consumers to make informed food choices that match their personal interest and nutritional needs.
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