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Simulated meat and simulated poultry products

Simulated meat products and simulated poultry products are defined under the Food and Drug Regulations (FDR). They are foods that do not contain meat, poultry or fish products, and that have the appearance of meat products or poultry products. These foods are made mostly of plant-based ingredients and may contain other animal products (such as milk and eggs).

Appearance of these foods includes:

  • the sensory characteristics of the food (for example, visual appearance, texture, flavour and odour), and/or
  • how the food is being advertised and represented (for example, the food is labelled, advertised or marketed as a food similar to or comparable to a meat product or poultry product)

These simulated meat and poultry products and their labels must meet specific provisions in the FDR, which require that they:

  • be identified by a common name that includes the word "simulated"
  • be identified by the words "contains no meat" or "contains no poultry" (as applicable), and
  • meet specific requirements for composition and fortification

Refer to table 1 for more information on the requirements applicable to foods captured by the regulatory definition for simulated meat and poultry.

Foods that do not meet the definition of a simulated meat or poultry product

Foods that contain no meat, poultry or fish and that do not have the appearance of meat or poultry do not satisfy the definition of a simulated meat or a simulated poultry product.

These foods:

  • are generally made of mostly plant-based ingredients
  • may contain other animal products (such as milk and eggs)
  • are not labelled and/or advertised with words or images that present or imply that they resemble or that they are comparable to meat or poultry products

While these foods may have some visual characteristics that are similar to meat or poultry products, they are not subject to the simulated meat and poultry requirements or prohibitions provided that they do not resemble them (that is, do not have the appearance of meat or poultry products). In addition, these foods must not be likely to be mistaken for meat or poultry products. To determine this, the overall impression of the product is assessed. All information on food labels or in advertisements, such as the common name, claims and statements, images (pictures, vignettes and logos) and the appearance of the product (for example, whether components have been added to the product to simulate bleeding, marbling of fat, or visual appearance of meat cuts or parts) will contribute to the overall impression created about the product.

Refer to table 1 for more information on the regulatory requirements that are applicable to these foods.

Table 1: Specific regulatory requirements of simulated meat and simulated poultry products and other foods that do not meet the definition of a simulated meat or poultry product

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Simulated meat and simulated poultry products

Foods that do not meet the definition of a simulated meat or poultry product

Specific regulatory requirements

The requirements below are specific to these unstandardized 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 any other unstandardized food.

Appearance

The food resembles a meat or poultry product due to:

  • the sensory characteristics of the food (for example, visual appearance, texture, flavour and odour), and/or
  • how it is advertised and represented (for example, the food is labelled, advertised or marketed as a food resembling a meat product or poultry product)

For example, a nonmeat food which is manufactured to have the appearance of a beef burger, by adding components to simulate bleeding or to simulate a marbling of fat effect.

Note: specific guidance on advertisements and representations is provided below.

While such foods may have certain visual characteristics (such as colour, texture, shape) similar to that of a meat or poultry product, they are not likely to be mistaken for a meat or poultry product. They are not labelled or advertised as resembling a meat or poultry product.

For example, a tempeh patty (a food brown in colour, made of ingredients that are comminuted and shaped into a disk or ball) does not resemble a meat or poultry product and the product is not advertised or represented as being similar to a meat or poultry product.

Note: specific guidance on advertisements and representations is provided below.

Common name

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", that is, "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 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, for example, "veggie simulated chick'n tenders". Although the FDR and the Safe food for Canadians Regulations (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.

Non-prepackaged simulated meat or poultry product:

When a simulated meat or poultry product is not prepackaged, the common name shall be shown on a sign displayed on or adjacent to the product in letters that are legible and conspicuous [B.01.100(3), FDR].

The common name of such an unstandardized food is the name by which the food is generally known, or a name that is not generic and that describes the food [B.01.001(1), FDR].

The common name and other expressions on the principal display panel must indicate the true nature of the product and accurately and truthfully describe the product. The main ingredient could form part of the common name along with descriptive terms such as "burger", "loaf", "patty", "jerky", "sausage", provided that the food:

  • does not have the appearance of a meat or poultry product, and
  • is not likely to be mistaken for a meat or poultry product or simulated meat or simulated poultry product

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

Use of the term "flavoured" in the common name:

The term "flavoured" is acceptable in the common name if:

  • the common name is accurate and truthful
  • the product does not have the appearance of meat or poultry, and
  • is not likely to be mistaken for a meat or poultry product or simulated meat or poultry product

Example: chicken flavoured veggie loaf.

Composition

These products:

  • are unstandardized products that 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 to B.14.090, B.22.029, FDR]
  • must not exceed the maximum requirements for fat content [B.14.085 to B.14.090, B.22.029, FDR]
  • are mostly made of plant-based ingredients (cereals, legumes, nuts, seeds, vegetables) but may also contain other ingredients (water, salt, yeast)
  • may contain other animal products such as dairy or eggs
  • may contain food additives

For a list of additives permitted for foods, refer to Health Canada's Lists of permitted food additives.

These products can be described as follows:

  • are unstandardized products that do not contain meat, poultry or fish
  • are mostly made of plant-based ingredients (cereals, legumes, seeds, vegetables) but may also contain other ingredients (water, salt, yeast)
  • may contain other animal products such as dairy or eggs
  • may contain food additives

For a list of additives permitted for foods, refer to Health Canada's Lists of permitted food additives.

"Contains no meat" / "contains no poultry" declaration

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, unless otherwise added through another ingredient.

Non-prepackaged simulated meat or poultry product:

When a simulated meat or poultry product is not prepackaged, 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 conspicuous [B.01.100(3) and (4), FDR].

The declaration "contains no meat" or "contains no poultry" is not required on the label, but may be applied provided that it is not false, deceptive or misleading.

Fortification

Simulated meat and simulated poultry products are subject to mandatory specific fortification requirements [B.14.085 to 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.

Unless otherwise exempted, fortification of these foods is prohibited.

Refer to this page for information on Foods to which vitamins, mineral nutrients and amino acids may or must be added.

Nutrition labelling

Simulated meat and simulated poultry products are always required to declare a Nutrition Facts table (NFt) on their labels [B.01.401, FDR].

Therefore, the label must carry a nutrition symbol if the amount of saturated fat, sugars and/or sodium is equal to or higher than the specified nutrient thresholds [B.01.350, FDR].

Added vitamins and minerals must be declared in absolute amounts and as a percent daily value per serving of stated size in the NFt [B.01.402(6), table to B.01.401, items 13 and 15, table to B.01.402, items 19 to 24, 26, 30, 31, 33, FDR].

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

When required to declare an NFt, the label must carry a nutrition symbol if the amount of saturated fat, sugars and/or sodium is equal to or higher than the specified nutrient thresholds [B.01.350, FDR].

Claims, advertisements and representations

Claims are permitted provided they are truthful and not misleading and not otherwise prohibited.

Labels and/or advertising may include claims that compare the food to meat or poultry or represent it as a substitute for meat or poultry products.

Additional information may be used on labels and/or advertising, provided they are not false, deceptive or misleading and are compliant with all other requirements. In all cases, all mandatory requirements must be met and core information, such as common name clearly indicates that the food is a simulated meat or poultry product.

Examples of acceptable claims/information may include:

  • "meat alternative"
  • "use in the place of (named meat)"
  • "has the texture of meat"
  • "vegetarian (naming the species of meat)"
  • "plant-based meat"
  • alternative spelling or phonetic renderings associated with meat, an animal species or cuts of meat (for example, chick'n) and brand names that include such terms

Graphical representations: pictures, vignettes, logos, endorsements and trademark contribute to the overall impression created in food labelling and advertising. When used, they must not be deceptive, misleading or misrepresent the product.

The labels and/or advertising may include graphical representation related to meat, animal source or poultry bird the product simulates. For example, the image of a turkey bird on a simulated turkey product label.

Claims are permitted provided they are truthful and not misleading and not otherwise prohibited.

Labels and/or advertising neither compare the product to meat or poultry, nor represent it as a food similar to or comparable to meat or poultry products. For example, naming the animal species or meat cuts on the label and/or advertising of a product that has been shaped or formulated to look like a meat product or meat cut would not be considered compliant.

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. For example, the name "vegetarian chicken nugget" or "plant-based drumstick" would not be considered compliant as it implies that the food has appearance or that it resembles a meat or poultry product.

Graphical representations: pictures, vignettes, logos, endorsements and trademark contribute to the overall impression created in food labelling and advertising. When used, they must not be deceptive, misleading or misrepresent the product.

The use of images must not imply that the food has the appearance of, or is likely to be mistaken for, a meat or poultry product. For example, having a picture of a chicken on a "chicken flavoured soy nugget" that looks like a chicken nugget would not be compliant as the overall impression of the food would imply that the food resembles a chicken nugget and would therefore be likely to be mistaken with a simulated poultry product.

Definitions

Close proximity
In respect of an item of information that is shown on a label, means immediately adjacent to the item of information and without any intervening printed, written or graphic material [B.01.001(1), FDR; 1, SFCR].
Simulated meat product
Any food that does not contain any meat product, poultry product or fish product but that has the appearance of a meat product [B.01.001(1), FDR].
Simulated poultry product
Any food that does not contain any poultry product, meat product or fish product but that has the appearance of a poultry product [B.01.001(1), FDR].
Unstandardized food
Any food for which a standard is not prescribed in Part B of the FDR [B.01.001(1), FDR].