Labelling requirements for fats and oils
Nutrition labelling - Fats and oils
Modified fatty acid content oil
Some oils include a reference to the fatty acid content in the common name, such as "high oleic [naming the source] oil".
Subsection B.01.402(4) of the FDR states that, "If the label of a prepackaged product, or any advertisement for the product that is made or placed by or on the direction of the manufacturer of the product, contains a representation, express or implied, that includes information that is set out in column 1 of the table to this section, that information shall also be in the nutrition facts table."
It is important to pay close attention to the wording of the item in column 1 when determining if additional information is triggered in the Nutrition Facts table (NFt) by subsection B.01.402(4) of the FDR. For example, item 8 of the table following B.01.402 states "amount of monounsaturated fatty acids" in column 1. The term "high" in "high oleic [naming the source] oil" is considered to imply an amount. In addition, information in the list of ingredients is considered a "representation".
Therefore when "high oleic (naming the source) oil" is represented anywhere on the label, including in the list of ingredients, the requirements are as follows:
- the amount of monounsaturated fatty acids is required as additional information in the NFt as per B.01.402(4) of the FDR, as high oleic is an implied representation of the monounsaturated fatty acid content
- declaring the monounsaturated fatty acid content then triggers the declaration of omega-3 and omega-6 polyunsaturates in the NFt as per B.01.402(3) of the FDR
Note: If a product is exempt from carrying a NFt as per subsection B.01.401(2) of the FDR, this exemption would remain as per subparagraph B.01.401(3)(e)(i) of these regulations if there is no reference to the fatty acid content outside of the list of ingredients on the label.
For more information on the common name of these oils, refer to Oils with modified nutritional profiles.
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