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Consultation on the development of voluntary guidance for providing food information for foods sold to consumers through e-commerce

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1. Introduction

About this document

Health Canada and the Canadian Food Inspection Agency propose that food information on an e-commerce platform should mirror the information required on a food or beverage product's physical label. They also propose that all foods sold through e-commerce should display their allergen content on the product information page. To inform development of voluntary guidance on the information that should be provided to consumers when they purchase foods through e-commerce, Health Canada and the Canadian Food Inspection Agency are consulting with a wide variety of stakeholders and Canadian consumers. The consultation questions in section 7 seek input on the:

2. Definitions

E-commerce

For this consultation, e-commerce means the sale of foods over computer networks, through web, extranetFootnote 1 or electronic data interchange, by methods specifically designed for the purpose of receiving or placing of orders.

Food information

Food information means the following:

  • core and other food-specific labelling requirements
  • voluntary claims or statements
Product information page

A product information page is the space on any consumer-facing e-commerce platform that provides food information to consumers. It is meant to give consumers information they need to make informed purchases.

Note that in this document, a food or beverage product will be referred to as "food" or "food products."

3. Background

Although the sale of foods through e-commerce has increased over recent years, the information provided to consumers is inconsistent and sometimes inadequate to inform food purchases. Adoption of e-commerce was accelerated during by the COVID-19 pandemic, becoming an increasingly important way for consumers to buy groceries and meals. The sale of foods through e-commerce can also provide convenience, access to a greater variety of foods and is an alternative for people who may have challenges shopping in a physical store, such as people with disabilities.

However, buying foods through e-commerce can present challenges for consumers. For example, without being able to handle a physical product or ask retail staff, consumers must rely on what appears on a product information page to inform their purchasing decisions. With the growing number of businesses selling food through e-commerce, guidance on providing food information should make this information more consistently available and accessible to Canadians.

The Canadian context

E-commerce use and sales in Canada increased in the early stages of the COVID-19 pandemic.

Additionally, recent researchFootnote d from the University of Toronto assessed the availability and quality of nutrition-related information and other key labelling components of foods on leading Canadian grocery websites. The results of this work show that food information is inconsistently available when consumers shop for foods through e-commerce.

The future trends of e-commerce sales are unknown, but regardless of whether a food is offered for sale in a physical store or through e-commerce, consumers should have access to the same food information to help them make informed choices about their food purchases.

International context

Internationally, there is growing recognition of the need to extend consumers' access to food information to foods sold through e-commerce.

The Codex Committee on Food Labelling views this as an increasingly important issue. It has convened a working group to develop guidance for food labelling in an Internet sales/e-commerce environment.

The European Union (Regulation No 1169/2011)Footnote e extends the requirements for mandatory information to distance selling. Distance selling occurs whenever goods or services are sold without any face-to-face contact between the seller and the buyer.

Canadian legislation

Canada's Food and Drug Regulations (FDR) and the Safe Food for Canadians Regulations (SFCR) set out the mandatory information required on the physical label of most prepackaged foods and some non-prepackaged foods.

Mandatory labelling information helps consumers make well-informed and safe food choices. This information helps people manage chronic diseases, food allergies and food intolerances. It also provides basic information that consumers want about food they buy, such as its net quantity.

The Food and Drugs Act (FDA) and Safe Food for Canadians Act (SFCA) have broad prohibitions against false and misleading labelling that apply to food advertised or sold in Canada, including through e-commerce:

Information provided about a food must be accurate and truthful. For example:

The guidance would not negate any regulatory requirement to provide labelling information on the physical food label or in any related advertising material.

4. Proposed approach for developing guidance

The guidance would apply to food products sold in Canada to consumers through e-commerce. To help food retailers and other businesses provide food information to consumers, Health Canada and the Canadian Food Inspection Agency propose to develop the guidance based on the following principles.

4.1 Provide the same food information that is required to appear on any given label of food offered for sale in a physical store. For example, most prepackaged foods (that is, those that are packaged at the time they are offered for sale on the premises of a physical store) are required to be labelled with certain specific food information. The food information should be provided before the e-commerce purchase is concluded. Food information includes:

In addition, foods that are exempt from providing certain labelling information on the physical label due to a lack of available display surfaceFootnote 4 should provide food information because a product information page provides sufficient space to display itFootnote 5.

4.2 Provide allergen information (including precautionary statements) for any foods offered for sale through e-commerce, including those packaged or prepared by the seller (for example take-out food sold by a restaurant, foods sold in bulk and food sold from a deli case). The information should be provided before the purchase is concluded and it should accompany that food upon delivery to the consumer.

4.3 Provide product images of a food to help consumers recognize the product. For example, use the images of the front of the package or the food itself (in the case of fresh foods).

4.4 Food information and product images should be provided on the product information page, before the purchase is concluded. If this is not possible, provide the information using another appropriate means, so long as the consumer is provided with clear direction on where to find the information and the consumer does not incur any additional charge to obtain it.

4.5 Indicate if and how the delivered food may differ from the one being offered for sale, and advise the consumer to verify the label of the delivered food for those differences.

4.6 Provide food information in both official languages (English and French), so that consumers can access and understand the information in their preferred language. E-commerce platforms should support accented characters that are required for proper spelling and reader comprehension (for example, é, à and ç).

4.7 Provide food information in a manner that reflects, as much as possible, the manner in which it is presented on the food's physical label.

4.8 Provide food information in a consistent layout across all product information pages of an e-commerce platform, so that foods can easily be compared.

4.9 Provide food information on a product information page in a manner that is clear, prominent and legible. For example

4.10 Provide food information in a way that is readable by screen readersFootnote 6, whether in text format or as an image.

4.11 Design the structure of an e-commerce platform (regardless of device or screen size) in a manner that helps the user easily navigate and find food information.

5. Monitoring and reporting

Health Canada and the Canadian Food Inspection Agency plan to monitor the availability and accessibility of food information for foods offered for sale through e-commerce.

Examples of indicators that will be used include:

6. Public comments and contact information

Health Canada and the Canadian Food Inspection Agency value input from interested Canadians and stakeholders on developing this guidance. Your feedback will help inform final guidance for selling food through e-commerce.

How to participate

Share your feedback online or respond to the following questions by email at nut.labelling-etiquetage@hc-sc.gc.ca (subject line: Online Food Labelling Consultation).

7. Consultation questions

  1. Please indicate whether you are providing input (select only one answer):
    • As an individual
    • As a representative of a group or organization
    • Prefer not to say
  2. Which of the following stakeholder groups do you represent (select all that apply):
    • Consumers
      • Consumer, general public
      • Association representing consumers
    • Industry
      • Grocery retailer
      • Grocery delivery service
      • General merchandise retailer that sells food
      • Online retailer that permits third-party sales on their e-commerce platform
      • Restaurant or foodservice operator
      • Meal kit company
      • Food manufacturer, processor
      • Food primary producer or farmer
      • Importer
      • Software or web developer
      • Industry association
    • Health
      • Health professional
      • Health association
    • Other
      • Academia, research
      • Consultant (please specify field/area of work)
      • Government (municipal, provincial, territorial or federal)
      • Other (please specify):
      • Prefer not to say
  3. If you are a Canadian consumer:
    1. How frequently do you shop for food online?
      • More than one a week
      • Once a week
      • 2 to 3 times per month
      • Once a month
      • Less than once a month
      • Never
    2. How would you describe your experience in accessing food information (for example, list of ingredients and allergens, nutrition facts table) when shopping for foods online?
    3. What do you think could improve your access to food information when shopping for foods online?
  4. Do you currently offer food for sale to Canada via e-commerce?
    • Yes
    • No
    • Not applicable
  5. Please refer to Section 4: Proposed approach for developing guidance and provide any comments related to providing food information for foods sold through e-commerce. Please begin your response with the Section number to which the comment applies.
  6. If you are a business that sells or is considering selling foods to Canadian consumers through e-commerce, please describe any challenges regarding displaying and maintaining current information on product information pages.
  7. If you have any other comments, please provide them here.

Thank you for providing your feedback.

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