Pictures, vignettes, logos and trademarks on food labels
Pictures, vignettes and logos
Pictures, vignettes and logos are any types of pictorial representations that appear on food labels and in advertising.
Accuracy in illustrations
Pictures and charts are common types of aids that manufacturers or producers use on labels and in advertising. When they are used, they must not be deceptive, misleading or misrepresent the composition, qualities or value of a product.
In addition, where a picture professes to represent the food offered for sale, the actual product should be shown. For example, if the product must be prepared, then the product prepared according to directions should be shown in the picture.
Consider a juice blend that is made of "apple juice, orange juice, sugar and flavour", but is labelled with the brand name "tropical juice" and images of coconuts, mangos, pineapples, and papaya. The brand name and images on this package give the impression that the product is made wholly out of coconut, mango, pineapple and papaya juices, which is not the case. This label representation is therefore contrary to subsection 6(1) of the Safe Food for Canadians Act (SFCA) and 5(1) of the Food and Drugs Act (FDA). For more information, refer to Composition and quality claims.
Vignettes and artificial flavours
If a vignette or other pictorial representation on a food label shows a natural substance (for example, a picture of an apple) and an artificial flavour that simulates that substance is an ingredient in the food (for example, artificial apple flavour), whether alone or with natural flavouring agents, a statement that the added flavouring ingredient is imitation, artificial or simulated is mandatory [224(1), SFCR].
The statement must be in both English and French in at least the same type height for the net quantity declaration as required for numerals [206(1), 229(1)(b), SFCR]. The location of the statement must be:
- on or in close proximity to the vignette or portion of the vignette, on the principal display panel (PDP) if
- the pictorial representation is on the PDP [224(2)(a), SFCR], or
- the pictorial representation is both on the PDP and another part of the label [224(2)(c), SFCR], or
- on the PDP, in close proximity to the common name, if the vignette is on another part of the label [224(2)(b), SFCR]
This provision applies to consumer prepackaged foods. The words "serving suggestion" do not eliminate the need for an "artificial flavour" statement.
This regulation does not apply when:
- a vignette shows a pictorial representation of a natural substance and an artificial flavour that does not simulate this substance is an ingredient
- Example: a blueberry/apple cookie, made with blueberries and artificial apple flavour, that has a picture of a blueberry but no picture of an apple
- a vignette shows a pictorial representation of a natural substance, and a natural flavour that simulates this substance is an ingredient
- Example: a picture of a cherry when natural almond flavour has been added to simulate cherry flavour. The ingredient list should state either "natural flavour" or "natural almond flavour" but not "natural cherry flavour"
Illustrations of people
Several principles govern the use of illustrations of people in advertisements:
- where pictures purport to represent a known person, the actual person should be portrayed in the advertisement
- representations of professional people, such as illustrations of laboratories or scientific apparatus, should not be used to create "atmosphere" if they have no direct connection with the product
- "before and after" pictures should be avoided
Heart symbols and heart health claims
It is generally not acceptable to use heart symbols and heart healthy claims to describe a food or food choice, whether on labels, menus or in advertising. The combined use may create an erroneous impression that consuming a single food or menu selection will provide heart health or prevent heart disease.
Specifically, it is considered misleading to use heart symbols or the word "heart" to:
- suggest or imply that a particular food is nutritionally superior to or healthier than other foods
- suggest that the consumption of a specific food or menu selection will, by itself, provide health benefits relating to the heart and cardiovascular system
Nutrition information programs that incorporate heart health in restaurants cannot identify menu items with hearts. Menu items may instead be identified using a check mark () to draw attention to good or healthy choices, provided that the information provided satisfies the requirements stated above and the reason for the program is made clear.
Health authorities do agree that a single pattern of healthy eating should be recommended to the public. However, even though a healthy diet may help reduce the risk of cardiovascular disease, it is only one factor in the multiple etiology of the disease.
Exceptions – Acceptable uses of heart symbols or heart health claims
Symbols of affection
No objection will be taken to heart symbols used in a manner traditionally recognized as indicating affection or endearment, such as heart-shaped cinnamon candies, heart-shaped boxes of chocolates, or heart illustrations on food products sold for Valentine's Day.
Health organization logo, name or program
Heart symbols may also be acceptable on food labels or advertisement when they appear in the logo or name of a health organization, or are used in conjunction with that organization's health information program, provided that:
- no impression is given that the food may help prevent, treat or cure heart disease, and
- the appearance of the health organization's name or logo itself satisfies the Third party endorsement policy
Additionally, terms that employ the word "heart" may be acceptable as part of the name of an information program of a health organization provided the program is identified as such.
Heart symbols with acceptable health claims
No objection will be taken to the use of heart symbols in conjunction with the health claim "A healthy diet low in saturated and trans fats may help reduce the risk of heart disease. (Naming the food) is low in saturated and trans fats". However, the use of these symbols must not give the impression that the food itself may have a positive effect on health, or that there is a role beyond the disease risk reduction claim. See Health claims for additional information.
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