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Introduction
The Canadian Food Inspection Agency (CFIA) developed proposed guidance on how to label and represent plant-based alternatives to egg products to distinguish them from egg products.
We ran a consultation on labelling plant-based alternatives to egg products from July 29 to October 28, 2024 to receive feedback on this guidance.
This report summarizes the feedback we received and the next steps for finalizing the guidance.
Who we heard from
We received 571 completed surveys and 356 written responses, of which 286 were generated by a write-in campaign.
The survey respondents self-identified as being part of the following groups:
- 72% consumers
- 23% food industry
- 2% government
- 1% health stakeholder
- 2% other
Of the 70 distinct written responses received, 18 were from industry, 41 were from consumers, 5 were from government and 6 were from non-governmental organizations. These explain specific concerns and do not necessarily address all the questions in the consultation nor the survey.
What we heard
Overall, respondents welcomed the opportunity to provide feedback and expressed their support for developing guidance.
Adequacy of the proposed guidance
Most survey respondents said the proposed guidance was adequate or partially adequate.
Some respondents had concerns that the proposed guidance isn't clear enough and could lead to customer confusion about the true nature of plant-based alternatives to egg products. They want clearer distinction between egg products and plant-based alternatives to egg products, and they want to achieve this by not permitting the plant-based alternatives to use terms, images or packaging associated with egg products.
However, it's important to note that there is no legal basis for the CFIA to prohibit the use of terms, images or packaging associated with egg products on plant-based alternatives to egg products. Rather, the Safe food for Canadians Regulations and Act and the Food and Drugs Act requires that such products be labelled in a way that they will not likely be mistaken for their traditional counterparts, such as eggs.
Some respondents commented that guidance was not necessary and was too complex, preferring simpler common names such as "vegan egg," "plant-based egg" or "egg alternative."
The Safe food for Canadians Regulations and the Food and Drug Regulations requires plant-based alternatives to egg products (and all similar foods) to have a common name that is not generic and that describes the food.
Because some respondents commented that the guidance should be more restrictive, while others commented that it be less restrictive, this signals that the guidance achieves a good balance.
Applicability of the proposed guidance to other plant-based foods
Some respondents shared that the CFIA could apply this model of guidance to other plant-based alternatives such as dairy, fish and meat. They requested that the CFIA consult on commodity-specific guidance for these products because they all have unique characteristics that need to be considered. We will take these views into consideration as we consider subsequent consultations for other plant-based alternatives. Note that the we have already updated guidance for Simulated meat and simulated poultry products.
Survey responses on consumer use of labels
Most respondents said they believe checking labels is very important, with the majority of respondents saying they check the entire label. The top 3 aspects of a food label that respondents said they check when deciding to purchase a food product are the list of ingredients, the nutrition facts table and a vegan certification/symbol. Most respondents said they always check the list of ingredients to know what the food is made of when making a purchase.
Nearly all respondents said they find the current labels of plant-based alternatives to egg products clear. When purchasing plant-based alternatives, most respondents said they look for the list of ingredients and/or a plant-based or vegan claim or certification.
Other
We also received comments and responses that were outside the of scope of this consultation. These included comments on labelling of other foods, such as claims on egg labels about poultry raising practices.
Next steps
Given the general support for the proposed guidance on how to label and represent plant-based alternatives to egg products and that nearly all consumers find the current labels of plant-based alternatives to egg products clear, we will move forward with finalizing the guidance and will consider all feedback received during the consultation.
We also note that the U.S. Food and Drug Administration consulted on Draft Guidance for Industry: Labelling of Plant-Based Alternatives to Animal-Derived Foods. The draft guidance broadly aligns with the approach proposed by the CFIA, which requires common names to properly describe what the food is and allows the use of terms associated with eggs on plant-based alternatives to egg products. We will keep abreast of developments in the U.S.
We anticipate publishing updated guidance in the coming months on plant-based alternatives to egg products. We'd like to thank everyone who participated in this consultation process.