What We Heard Report - Consultation on Canada's proposed guidelines for simulated meat and poultry
On this page
- Who we heard from
- What we heard
- Next steps
As Canada's plant-based food industry grows, consumers and industry have expressed a need for more information and guidance about these products. In response to this, the Canadian Food Inspection Agency (CFIA) consulted on its Proposed guidelines for simulated meat and simulated poultry products from November 3 to December 3, 2020.
The proposed guidelines outlined the regulatory requirements for labelling, advertising, composition and fortification. It did this for 3 different categories of foods:
- meat and poultry products (referred to as category 1)
- simulated meat and poultry products (referred to as category 2)
- other similar products but that do not substitute for meat or poultry (referred to as category 3)
These categories and proposed guidelines are intended to help consumers and industry differentiate between these categories, as well as to support compliance with requirements. For example, category 2 foods have specific compositional and labelling requirements, whereas there are fewer such requirements associated with category 3 foods.
It is important for consumers to understand the differences between the categories so they can make informed dietary choices. For industry, it is important for them to be able to position their products in 1 of the categories in order to adhere to rules for that category.
This report summarizes the feedback the CFIA received during this consultation. The participants' views expressed below do not reflect those of the CFIA or the Government of Canada.
Who we heard from
During the official comment period, the CFIA received 2522 completed online surveys and 22 letters. Input received outlined questions and proposed adjustments to the regulatory requirements and guidance.
The survey respondents self–identified as being part of the following groups:
- consumers/general public (67%)
- farmers and producers (15%)
- health professional (5%)
- manufacturers/processors (3%)
- government (3%)
- industry associations (2%)
- non-governmental organization (1%)
- distributor or retailer (1%)
- other (3%)
The consultation captured the interest and participation of meat and poultry consumers, as well as those who seek out plant-based foods. Out of those surveyed:
- 52% purchase meat or poultry products
- 72% purchase simulated meat or poultry products
- 84% purchased plant-based foods that fall under category 3
Of the 22 letters that the CFIA received, 14 represented the interests the meat and poultry sector, 3 represented associations advocating for the production and sale of plant-based foods, and 5 had no clear affiliation with meat or poultry products or plant-based foods.
What we heard
Overall, respondents welcomed the opportunity to provide feedback on the proposed guidelines. Consumer and industry associations expressed their support of CFIA efforts to clarify the existing regulatory requirements.
The following are highlights of what we heard.
- While the majority of respondents (62%) thought that the guidelines were clear, there are areas where guidance could be more clear.
- A large majority of respondents (79%) indicated that they don't find it challenging to determine whether a food is a meat or poultry product or non-meat or poultry product.
- Regarding terminology, 66% indicated that plant-based foods should be allowed to use meat terminology
- Comments from the meat-sector and some consumers expressed concern that using terms long associated with animal-based meat products risks misleading consumers about the true nature, composition and nutritional profile of certain foods.
- There are concerns with the current regulatory framework and requests were made that the simulated meat and poultry regulations be reviewed and updated to fit with Canadians' understanding and expectations of plant-based foods.
- The plant-based and animal-based sector, as well as many consumers, said that plant-based foods should stand on their own merits and should not be compared to meat and poultry products.
- There were some requests to have only 2 categories in the guidelines, 1 for meat and poultry and 1 for non-meat products.
The information below summarizes specific feedback that the CFIA received on various sections of the guidance
According to the Food and Drug Regulations, a simulated meat or poultry product is one that does not contain meat, poultry or fish but that has the appearance of a meat or poultry product.
When asked to specify the information used to distinguish meat and poultry products from simulated meat and poultry products, 10% of respondents said they rely on the appearance of a food. The appearance of the food was always used along with other label information (for example, list of ingredients, nutrition facts table) to tell the difference between category 1 and 2. The majority of responses suggested that a broader interpretation of "appearance of meat or poultry," to include the overall representation of the product, may be warranted.
The appearance of the food is 1 of the factors determining whether a food should be subject to category 2 or 3 requirements. Since it was proposed that both category 2 and 3 products can have visual attributes commonly associated with meat, feedback indicated that further guidance is required to clearly distinguish between these 2 categories of foods.
There were several comments from respondents that indicated they don't consume meat or poultry products and they don't want their food to resemble meat or poultry products. Their comments indicated that by linking the appearance of the food to the fortification requirements, the regulations prevent these consumers from being able to access fortified foods.
When asked to specify the label information used to distinguish meat and poultry products from simulated meat and poultry products, 21% of respondents indicated that they rely on the common name, of which only 3% of respondents indicated that they rely on the common name alone. To tell the difference between category 1 and 2, the common name was most frequently selected, along with the ingredient list.
When asked to assign the 3 food categories to foods bearing certain common names, the percentage of respondents that assigned the foods into the correct category, for each food item to be categorized, ranged from 58% to 94%. This indicates that some products were easier to categorize than others.
The ability to differentiate between category 2 and 3 was compromised when the common name showed that the food included beef or chicken flavouring (for example, chicken flavoured or beef flavoured). The CFIA recognizes that while the survey questions were based on the common name alone, in reality consumers rely on multiple pieces of information to distinguish between the 3 categories of foods.
The Food and Drug Regulations require that food that has the appearance of a meat or poultry product bears the common name for the meat or poultry product that is being simulated and be modified by the word "simulated." The CFIA heard various concerns with this regulatory requirement including these:
- some of the respondents who indicated they don't consume meat or poultry didn't like the requirement for category 2 foods to have the meat cut or name of the species in the common name
- the meat sector voiced strong opposition to allowing simulated meat and poultry products to reference muscle groups in their common name (for example, tenderloin, striploin, and sirloin)
- some respondents indicated that the prescribed common name for simulated meat products do not clearly describe these foods
Some respondents expressed concern with using terms such as "burger," "sausage" or "jerky" to describe plant-based foods. However, the majority (66%) indicated that these terms are no longer exclusive to meat and should continue to be allowed to be used to refer to plant-based foods (that is, category 2 and 3 foods), as long as these foods are clearly labelled and advertised so they will not be mistaken for a meat product.
In addition, comments indicated that terms that are frequently used in the common name, such as "plant-based," are increasingly confusing because the terms are being used on more and more products:
- on meat products (to reflect the addition of vegetable material)
- on the labels of non-meat products that contain animal products (that is, dairy and egg)
- on products that are made exclusively from plants
According to the Food and Drug Regulations, category 1 and 2 foods are subject to specific compositional requirements for protein (minimum protein and rating requirements) and fat (maximum).
Respondents were asked if all plant-based foods that use terminology that has been historically associated with meat or poultry products (for example, burger or sausage) should be subject to fortification and compositional requirements so that they are nutritionally similar to meat or poultry products. When replying, 72% of respondents said no and 28% said yes. Comments suggest that respondents have a clear understanding of the composition of plant-based foods (that is, in that these foods contain no meat) and often refer to the ingredient list or nutrition facts table to assess the composition and nutrition of these foods.
The CFIA notes that the guidelines gave some respondents the impression that meat and poultry products are not subject to any compositional requirements. Comments also indicated that those who read the guidelines were still unclear about the composition of category 2 and 3 foods. Several respondents were left with the impression that fat needs to be added to category 2 foods to make them similar to the meat or poultry products being simulated. In reality, regulatory requirements for both category 1 and 2 foods seek to limit, not increase, the fat content in these foods. In addition, the guidelines gave some the impression that category 3 foods cannot contain dairy or eggs, when in reality there are no restrictions on the use of non-meat or poultry ingredients in these foods.
The CFIA also heard requests to clarify guidance around the use of meat or poultry flavouring in plant-based foods. Some indicated that referring to meat or poultry flavouring in the common name or on the principal display panel is confusing and may be misleading to consumers. Many suggested that it might not be clear to consumers that animal-type flavouring in these foods is extracted from animal products. In addition, some suggested that if a plant-based food is flavoured to taste like a meat product, the food is being formulated in such a way as to simulate a meat or poultry product and should be subject to the category 2 requirements.
Fortification requirements for food are set by Health Canada via the Food and Drug Regulations. The guidelines reflect the Food and Drug Regulations requirement to fortify simulated meat or poultry products, as well as meat or poultry product extenders (products that do not contain meat but are used in meat products). Many indicated that fortification requirements for plant-based foods should be re-evaluated.
While Health Canada's regulatory requirements for fortification were not within the scope of the consultation, some respondents suggested that mandatory fortification should be limited to plant-based foods that claim to be nutritionally comparable to a meat or poultry product. In addition, many indicated that the regulations should allow for plant-based foods (both category 2 and 3) to undergo optional fortification to increase the availability of nutrients that can be harder to obtain when consuming a plant-based diet.
Contains no meat/contains no poultry declaration and other claims
The guidelines reflect the Food and Drug Regulations requirement for simulated meat and poultry products to bear the declaration "contains no meat" or "contains no poultry." Since no such regulatory requirement exists for category 3 foods, the guidelines indicate that this declaration is optional for category 3 foods. Several comments indicated that category 3 foods should also be required to have a "contains no meat" or "contains no poultry" declaration. Some indicated that the guidelines should address other claims found on plant-based foods, such as "plant-based," "vegan," "vegetarian" or "clean meat".
The CFIA also heard requests to require meat and poultry products to bear claims or labels to make consumers aware of the use of pharmaceuticals in animals raised for human consumption.
Nutrition labelling and ingredients lists
While health and nutritional requirements of food labels are set by Health Canada, they are enforced by the CFIA. When asked to specify the label information used to distinguish meat and poultry products from simulated meat and poultry products, only 9% of respondents indicated that they use the nutrition facts table to differentiate between the 3 categories of food. Consultation comments emphasized that consumers rely on this information to guide dietary choices.
The CFIA also heard various opinions on the differing nutritional benefits of eating plant-based versus meat products. Some respondents indicated that plant-based food (regardless of their composition or fortification) and meat and poultry products should not be allowed to make comparative nutritional claims.
The CFIA also noted requests to clarify ingredient list requirements for the 3 categories of food, as well as clarify guidance for products that contain simulated meat products (for example, pasta sauce with textured vegetable protein). In the survey, 24% of respondents indicated that they rely on the ingredient list to distinguish meat and poultry products from simulated meat and poultry products.
Advertising and representations
The Food and Drugs Act and the Safe Food for Canadian Act (and regulations for both) prohibit labelling and advertising food in a manner that is false, misleading or deceptive. The proposed guidance for simulated meat and poultry gave respondents the impression that category 1 foods were subject to less stringent requirements when compared to plant-based foods (category 2 and 3) when, in reality, the prohibition applies to all food.
Industry was unanimous in their request to further strengthen the advertisement and representations section of the guidelines to promote transparency, avoid misleading labels and reduce consumer confusion.
The CFIA heard concerns from industry and other stakeholders regarding the use of advertisements or representations (for example, vignettes or other labelling) to misrepresent all 3 categories of food. Examples provided to the CFIA, with concerns that they could be potentially misleading or misrepresenting food, included the use of labelling, advertisements or vignettes to create an impression about the following:
- the humane treatment of food animals
- sustainability and environmental benefits of producing and consuming particular foods
- nutritional benefits of consuming 1 type of food compared to another (for example, plant-based food is healthier than a meat product or vice versa)
The CFIA heard concerns regarding packaging and advertising of plant-based foods that lead consumers to believe that a product contains no animal products when it reality it may contain dairy and egg ingredients. Some respondents also shared concerns about the use of graphics related to meat or animal source on category 2 products because they are believed to mislead consumers as to the nature, composition and nutrition of these foods.
The CFIA also received many comments requesting clarification for other types of plant-based foods, such as those advertised as alternatives to dairy, egg or fish products. The CFIA recognizes that future plans could include holding more engagement exercises and developing guidance for these other types of plant-based foods.
The CFIA will consider all input to further clarify the proposed guidelines for simulated meat and poultry. The CFIA expects to publish the final guidelines for simulated meat and poultry in the fall of 2021. Before finalizing the guidelines, the CFIA will do the following:
- clarify the appearance section of the guidelines to differentiate between category 2 and 3 foods
- further consider whether the meat and poultry products (category 1) requirements should be included in the guidance
- clarify the compositional requirements for category 3 foods and specify when a common name for category 3 foods can refer to the use of animal flavouring
- assess whether additional clarity can be brought to the advertising and representations section of the guidelines
The CFIA has also updated Health Canada on requests to review the simulated meat and poultry regulations, and will share specific comments related to the regulations set by that Department, including those related to fortification and nutrition labelling.
The CFIA thanks everyone who participated in the consultation process.
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