Legibility and location of food labelling information
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:
- clearly and prominently shown, and
- readily discernible and legible to the purchaser or consumer under the customary conditions of purchase and use
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].
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].
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]:
- numerical information in the declaration of net quantity
- statement about imitation, artificial or simulated flavours
|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.
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