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Legibility and location of food labelling information

Important Notice

On December 14, 2016, amendments to nutrition labelling, list of ingredients and food colour requirements of the Food and Drug Regulations came into force. Regulated parties have a five (5) year transition period to meet the new labelling requirements.

Consult the Former – Legibility and Location of Labelling Information for information on the former requirements.

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Legibility requirements

General

As per section A.01.016 of the Food and Drugs Regulations (FDR) and section 208 of the Safe Food for Canadians Regulations (SFCR), mandatory information required to appear on a label (definition) of a food must be:

Examples of information on a food label that may not be considered as satisfying the above mentioned legibility requirements include coloured text on a similarly coloured background, and may include impressed or embossed letters on cardboard or plastic where there is no prominence or contrast.

Unless otherwise specified in Regulations, all mandatory information required on consumer prepackaged (definition) foods under the Safe Food for Canadians Act (SFCA) and SFCR must be shown in characters of at least 1.6 mm (1/16 inch) in height. The height of the characters is based on the height of an upper case letter if the words are shown in upper case only, or the height of the lower case letter "o" if the words appear in lower case or in both upper and lower case [210(1) and (2), 211, SFCR].

If a word or expression that appears in quotation marks in the SFCR is required to be shown on a label, it may, unless otherwise provided, be shown in upper or lower case, or both, so long as it meets the legibility and character height requirements. An example of this is the statement "Keep Refrigerated" / "garder réfrigéré" [209, SFCR].

Exception

For very small packages that have a principal display surface (definition) of 10 square centimetres (1.55 square inches) or less, information required by Part 11 of the SFCR, other than the numerical information in the declaration of net quantity, may appear in letter height of at least 0.8 mm (1/32 inch), provided all the information required by Division 2 of Part 11 of the SFCR appears on the principal display panel (definition) [210(3), SFCR].

Specific cases

Type size based on principal display surface

Schedule 6 of the SFCR includes the table below, which outlines the minimum character heights that must be used on the label of consumer prepackaged foods based on the area of the principal display surface (definition) for the following core labelling requirements [229, SFCR]:

Minimum type size requirements based on the area of the principal display surface
Item Area of principal display surface Minimum character height
1 ≤ 32 cm2 (5 inches2) 1.6 mm (1/16 inch)
2 > 32 cm2 (5 inches2) but ≤ 258 cm2 (40 inches2) 3.2 mm (1/8 inch)
3 > 258 cm2 (40 inches2) but ≤ 645 cm2 (100 inches2) 6.4 mm (1/4 inch)
4 > 645 cm2 (100 inches2) but ≤ 2 580 cm2 (400 inches2) 9.5 mm (3/8 inch)
5 > 2 580 cm2 (400 inches2) 12.7 mm (1/2 inch)

Note that in cases where the net quantity declaration or flavouring ingredient information is featured on display cards, "Area of principal display surface" in the table above should be read as "Total area of the surface of the display card visible under customary conditions of sale or use" [229(2), SFCR].

Legibility requirements for specific labelling topics

For the list of ingredients and the food allergen source, gluten source and added sulphites statement, the FDR prescribes specific technical requirements, including type height. Refer to List of ingredients and allergens for more information on these requirements.

For the Nutrition Facts table, the FDR prescribes specific format (graphic) and technical requirements including type height. Refer to Nutrition labelling for more information on these requirements. In addition, the FDR prescribe specific size requirements for certain other nutritional information such as "contains [naming the sweetener(s)]" statements (see Sweeteners).

In the case of some statements or claims regarding a food product, such as Nutrient content claims or Organic claims, the components of these statements or claims may be required to be of the same size and prominence when applied to the label of or in any advertisement for a food. For more information on the legibility requirements for statements or claims regarding a food product, see the conditions of use for the type of claim in the Industry Labelling Tool.

For example, if a manufacturer uses the claim "no sodium added" on the label or advertisement of a food product which meets the requirements for this claim as stated in the table following B.01.513 of the FDR, all of the words in this claim must be of the same size and prominence. It would not be acceptable if the words "no sodium" were bolded and appeared in a larger font size than the word "added". For more information on these requirements, refer to Specific nutrient content claim requirements.

Additional legibility requirements may exist for specific labelling topics. Please refer to the appropriate sections of the Industry Labelling Tool.

Location Requirements

General

The label of a prepackaged food must be applied or attached in such a manner that the label is still applied or attached at the time it is sold. All or part of the label of a consumer prepackaged food must be applied to the principal display surface (definition) [225, 227(1), SFCR].

Generally, commodity-specific information required by Division 3 of Part 11 of the SFCR for prepackaged foods may appear on any part of the label other than solely on the bottom (definition) of the container, unless otherwise specified [245(2) and (3), SFCR].

Specific location information for some core labelling requirements is outlined in the table below. Note that the term "prepackaged (definition)" encompasses both "consumer prepackaged" and "prepackaged other than consumer prepackaged". For more information, refer to Definition of "prepackaged" and "consumer prepackaged".

Requirement Location on label of prepackaged food
Common name

On principal display panel

B.01.006(1), FDR
218(1)(a), SFCR

Net quantity

Consumer prepackaged
On principal display panel

Prepackaged other than consumer prepackaged
On any part of the label other than solely on the bottom of the container. Exceptions apply for processed fruit or vegetable products and some prepackaged fish products [265, 272(1)(a), SFCR].

221, 245(2) and (3), SFCR

List of ingredients

On any part of the label other than solely on the bottom of the container

B.01.005, B.01.008, FDR
218(1)(c), SFCR

Durable life date

On any panel, including the bottom if accompanied by a statement that indicates information is located on the bottom. Exceptions apply.

B.01.005(4), B.01.007, FDR

Name and principal place of business

On any part of the label other than solely on the bottom of the container

B.01.005, FDR
218(1)(b) and (2), SFCR

Nutrition labelling

The Nutrition Facts table must be on one continuous surface of the available display surface (ADS). See nutrition labelling for more information.

B.01.005(5), B.01.451, FDR

It is important to note that additional location requirements may exist for other labelling topics, including those for specific commodities. For more information, refer to the Industry Labelling Tool.

Grouping of mandatory information

Section B.01.008 of the FDR states that all mandatory information required by the FDR must appear grouped together on any part of the label, unless it is information which is required to be shown on the principal display panel or information which is specifically exempted from the grouping provisions stated in B.01.008(1)(a) of the FDR (e.g., the name and principal place of business of the responsible party, the durable life date information, the Nutrition Facts table, and regulated nutrient content claims and health claims). If the product is required to carry a list of ingredients, the information which is required to be grouped together on that product's label must be grouped with the list of ingredients.

Specific cases

Use of display cards as labels

In the case of a consumer prepackaged food whose container is mounted on a display card, the label may be applied to the surface of the display card that is displayed or visible under customary conditions of sale or use [228, SFCR].

Use of hang tags as labels

Generally, mandatory information that is required to be on the principal display panel (PDP) is not permitted to be located on a tag, unless the container does not have a surface that is displayed or visible under customary conditions of sale or use to which a label can be applied (e.g., foil wrapped milk chocolate eggs in a mesh bag). In this case, mandatory information required on the PDP may be included on one side of a tag that is attached to the container, as this is considered to be the principal display surface (definition) [1, SFCR].

Similarly, in the case of a container that is a wrapper or confining band so narrow in relation to the size of the food that it cannot reasonably be considered to have any surface that is displayed or visible under customary conditions of sale or use, mandatory information required to be on the PDP may be located on one side of a hang tag [1, SFCR].

Ornamental containers

In the case of ornamental containers (definition), it is acceptable for mandatory information to be located on the bottom panel [227(2), SFCR].

Reverse side or pull-out portion of label

As a general rule, mandatory information is not considered readily discernible to a purchaser when it is on the reverse side or "outsert" or pull-out portion of the label (a folded or inserted panel under the label of a product), regardless of whether there is an instruction for the consumer such as "peel back here", or "lift this panel for more information" indicating that the consumer needs to peel the label off the container to read the reverse side. It is acceptable, however, to use the pull-out part of the label for information that is not mandatory.

Irregularly shaped packages

Mandatory information may become obscured by applying a label to an irregularly shaped package or product (e.g., a square label which has taken the shape of the spherical object to which it is applied); as such, these packages may not meet the legibility and location requirements of section 208 of the SFCR and section A.01.016 of the FDR.

For containers with no definable bottom, mandatory information may appear on any panel, other than specific mandatory information that is required to be shown on the principal display panel.

Additional location requirements may exist for specific commodities. For more information, refer to the food-specific labelling requirements in the Industry Labelling Tool.

Definitions

Bottom

The bottom is considered to be that part of a food or container which may reasonably be expected to be the surface on which the container rests when displayed for purchase. Some containers have several options as to how they can be displayed. If a food or container is labelled or printed in such a way that it may reasonably rest on any of the sides, then there is no bottom.

For example, as a frozen chicken dinner in a box may be displayed on more than one side, there is no definable bottom. In contrast, one would not reasonably expect a lemon meringue pie to be displayed on its side as it would result in damage to the product, and hence there is a definable bottom.

Consumer prepackaged

In respect of a food, means packaged in a container in the manner in which the food is ordinarily sold to or used or purchased by an individual - or in which the food may reasonably be expected to be obtained by an individual - without being repackaged, to be used for non-commercial purposes [1, SFCR].

Label

As defined in the Safe Food for Canadians Act, label includes a legend, word or mark that is or is to be applied or attached to or included in, or that accompanies or is to accompany, a food commodity or a package [2, SFCA].

As defined in the Food and Drugs Act, label includes any legend, word or mark attached to, included in, belonging to or accompanying any food, drug, cosmetic, device or package [2, FDA].

Ornamental container

An ornamental container means a container that, except on the bottom, does not have any promotional or advertising material thereon, other than a trade mark or common name and that, because of any design appearing on its surface or because of its shape or texture, appears to be a decorative ornament and is sold as both a decorative item and as the container of a food [B.01.001, FDR; 1, SFCR].

Ornamental containers must be substantial enough to be sold on their own merit (i.e., without the food). Ornamental containers are usually made of metal (e.g., cookie tins), plastic or glass (e.g., candy filled figurines). On the other hand, fabric-covered or embossed cardboard boxes for chocolates (e.g., for Valentine's Day) are normally considered decorative rather than ornamental.

Person

Person means an individual or an organization as defined in section 2 of the Criminal Code [2, FDA; 2, SFCA].

A person may therefore be an individual or an organization, and may include a consumer, a manufacturer, a retailer, an importer, a restaurant, any other commercial or industrial enterprise, an institution such as a school or hospital, and anyone else who sells, uses, or buys a food.

Prepackaged

Prepackaged, in respect of a food, means packaged in a container in the manner in which the food is ordinarily sold to or used or purchased by a person (definition), and includes consumer prepackaged (definition) [1, SFCR].

Principal display panel

As defined in the Safe Food for Canadians Regulations, principal display panel means:

As defined in the Food and Drug Regulations, principal display panel means, despite the meaning of principal display panel in section A.01.010,

Principal display surface

The Safe Food for Canadians Regulations define principal display surface in respect of the container of a consumer prepackaged food. It means:

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