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Proposed guidelines for simulated meat and simulated poultry products

The consultation closed on December 3, 2020.

Simulated meat productsFootnote 1 and simulated poultry productsFootnote 2 are nonmeat foods that have the appearance of meat or poultry products.

They must meet specific provisions in the Food and Drug Regulations (FDR), which state that these products:

These regulatory provisions require that the product provides 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.

In line with the General principles for labelling and advertising, any information that is provided on the labels or in the advertisements of these foods, must be accurate, truthful and not misleading.

Applying simulated meat product and simulated poultry product regulatory requirements

There are other categories of food which can be mistaken for simulated meat/poultry products. The guidelines in this section will help industry assess which category applies to their food product and which regulatory requirements they must comply with.

Food businesses which are required to have a preventive control plan (PCP) must demonstrate through their PCP how their product meets any prescribed composition, nutritional and labelling requirements. For those businesses not required to have a PCP, measures should be put in place to ensure these requirements are met.

For the purpose of this guidance, the products have been placed into 3 categories.

Category 1: Meat and poultry products

These are meat and poultry products, including extended meat and poultry products.

The standards for these products are specified in Divisions 14 and 22 of the FDR and in the Safe Food for Canadians Regulations (SFCR) incorporated by reference document Canadian Standards of Identity Volume 7 – Meat Products. A meat or a poultry product must meet its applicable standard for composition as well as the prescribed labelling requirements.

Category 2: Simulated meat and simulated poultry products

These are products purposefully formulated to resemble and substitute for a meat or poultry product.

Such a product must meet the minimum protein content and rating, fat content, as well as vitamin and mineral requirements of the meat or poultry product it is intended to substitute. Additionally, it must meet the prescribed labelling and advertisement requirements [see Annex 1] for a simulated meat or simulated poultry product.

Category 3: Other products which do not substitute for meat or poultry products

These products are generally plant-based protein foods and do not contain any meat, poultry or fish. Products under this category have no regulatory standards for composition. They are not required to be fortified, as they are not intended to provide the same nutritional components as meat or poultry. As such, these products are not considered to meet the definition of a simulated meat or a simulated poultry product.

Industry must ensure that consumers do not mistake these products for meat/poultry or simulated meat/poultry products. As such, they must be clearly labelled and/or advertised in a manner that accurately and truthfully describes the product.

Food businesses must determine which of the three categories applies to their product. To ensure consumers are not misled, it is industry's responsibility to position their product in one category and to ensure that the product meets all applicable regulatory requirements for that category. For assistance in placing products in the right category, industry should consult the guidelines in the annex below.

Annex 1: Composition and labelling requirements for meat and poultry products; simulated meat and poultry products; and other products which do not substitute for meat or poultry
Requirements Category 1:
Meat and poultry products
Category 2:
Simulated meat and poultry products
Category 3:
Other products which do not substitute for meat or poultry
Specific regulatory requirements

Divisions 14 and 22, FDR

Canadian Standards of Identity, Volume 7 – Meat Products (incorporated by reference in the SFCR)

No standard of identity prescribed in regulation, but the requirements below are specific to these foods:

B.01.001(1), FDR
B.01.100, FDR
B.14.085 to B.14.090, FDR
B.22.029, FDR
D.03.002, FDR

Same regulatory requirements as unstandardized food products, there are no requirements specific to these foods.

Appearance

There are no regulatory restrictions related to the appearance of these products.

The product is purposefully formulated to resemble a meat or poultry product, for example, a nonmeat product which is formulated to have the appearance of a beef burger, by adding components to simulate bleeding or to simulate a marbling of fat effect.

While such products may have a colour or texture similar to that of a meat or poultry product, they have characteristically identifiable nonmeat ingredients and are not aiming to be like a meat product.

For example, a soy burger may have discrete nonmeat ingredients such as corn, seeds, entire lentils, or other cereals and legumes.

Common name

Refer to Common name-meat and poultry products

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". For example, "Simulated (Naming the meat product or poultry product)" [B.01.100(1), FDR].

Examples:

Simulated "naming the species (of animal)": simulated beef, simulated veal, simulated pork, simulated chicken.

Simulated "naming the standardized meat cut": simulated sirloin, simulated tenderloin, simulated steak.

The word "simulated" in the common name must be shown in letters of at least the same size and prominence as those used in the remainder of the common name.

Note: Abbreviations, initials, symbols and phonetic renderings of meat terminology could be used on some labels. Although the FDR and the SFCR do not permit the use of abbreviations to provide mandatory labelling information except where specified, the use of names such as these on product labels and/or advertising would be considered representation as a simulated meat product.

"Simulated" in the common name:

The use of the common name "Simulated Bacon Bits" implies that the product simulates bacon and must meet the requirements for simulated meat products.

The common name must indicate the true nature of the product and accurately and truthfully describe the product. The major ingredient could form part of the common name, which may include terms such as "burger", "loaf", "patty", "jerky", which are not restrictive to meat products.

Examples: veggie burger, tofu burger, Portobello mushroom burger, lentil loaf, soy patty.

Use of the term "flavoured" in the common name: If the common name is accurate and truthful, and the product is not being represented as a substitute for meat or poultry, a claim which describes that product as flavoured like a meat or poultry product (for example, chicken flavoured veggie burger) will be acceptable.

Composition

Refer to the Canadian Standards of Identity Volume 7 – Meat Products

These products:

  • Do not contain meat, poultry or fish product [B.01.001(1), FDR].
  • Must meet the minimum protein content and rating requirements [B.14.085-B.14.090; B.22.029, FDR].
  • Must meet the specified requirements for fat content [B.14.085-B.14.090; B.22.029, FDR].
  • May contain food additives. For a list of additives permitted for foods, refer to Health Canada's list of permitted food additives.

These are:

  • Unstandardized products, which do not contain meat, poultry or fish products.
  • Generally contain plant-based proteins (cereals, legumes, seeds, vegetables). Some may be made of eggs and dairy products.
  • May contain food additives. For a list of additives permitted for foods, refer to Health Canada's list of permitted food additives.
Contains no meat/Contains no poultry declaration

N/A

Simulated meat and poultry products must carry the declaration "contains no meat" or "contains no poultry" on the principal display panel of the label, in close proximity to the common name and in letters of at least the same size and prominence as those shown in the product's common name [B.01.100(4), FDR].

When used as an ingredient:

When simulated meat is used as an ingredient of another food, such as a soup, the declaration "contains no meat" is not required on the label. Additionally, any pictures or vignettes on the packaging of the final food must not suggest that meat is present.

The declaration "contains no meat" or "contains no poultry" is not required on the label, but may be applied.

Fortification

Fortification is mandatory for meat product extenders and poultry product extenders [D.03.002 (1), FDR].

Refer to item 8 of the table of Foods to which vitamins, mineral nutrients and amino acids may or must be added.

Simulated meat and simulated poultry products are subject to mandatory specific fortification requirements [B.14.085-B.14.090; B.22.029; D.03.002(1), FDR]. Refer to item 8 of the table of Foods to which vitamins, mineral nutrients and amino acids may or must be added.

Fortification of these products is prohibited.

Mandatory or voluntary fortification is permitted only for the foods found in the table Foods to which vitamins, mineral nutrients and amino acids may or must be added.

Nutrition labelling

Unless otherwise exempted, these products are usually required to declare a Nutrition Facts table on their labels[B.01.401, FDR].

Reference amounts are the same for simulated meat products as for regular versions of these products as stated in the Table of reference amounts for food.

Simulated meat and simulated poultry products are always required to declare a Nutrition Facts table on their labels[B.01.40, FDR].

Added vitamins and minerals must be declared in absolute amounts and as a percent daily value per serving of stated size in the Nutrition Facts table [B.01.402(6); table to B.01.40, items 13 and 15; table to B.01.402, items 19-24, 26, 30-31, 33, FDR].

Unless otherwise exempted, these products are usually required to declare a Nutrition Facts table on their labels[B.01.40, FDR].

Advertisement and representations

Voluntary claims are permitted provided they are truthful and not misleading.

Amino acids may be declared outside the Nutrition Facts table when certain conditions are met.

Labels and/or advertising often include claims that compare the product to or represent the product as a substitute for meat or poultry products. For example, "meat alternative", "use in the place of (named meat)", "has the texture of meat", "vegetarian (naming the species of meat)", "plant-based meat".

Graphical representations: The labels and/or advertising may include graphical representation related to meat, animal source or poultry bird (for example, the image of a turkey bird).

Voluntary claims are permitted provided they are truthful and not misleading.

Labels and/or advertising neither compare the product to, nor represent the product as a substitute for meat or poultry products.

Naming the animal species, meat cuts to compare the product to meat on the label and/or advertising is not permitted.

Claims such as "vegetarian", "veggie", "plant-based" can be made, provided they are not used in conjunction with terminology that promotes the product as equivalent to meat.

Specific labelling requirements for non-prepackaged products For labelling requirements for non-prepackaged meat products, refer to Non-prepackaged foods that require a label. When a simulated meat or poultry product is not prepackaged, the common name and the "contains no meat" or "contains no poultry" declaration shall be shown on a sign displayed on or adjacent to the product in letters that are legible and visible.

N/A

Note that the guidance provided in this section mirrors the CodexFootnote 3 definition of substitute food: "A food which resembles a common food in appearance and texture and is intended to be used as a complete replacement or partial replacement for the food it resembles".

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