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Notice to industry – Flexibility in the declaration of a list of ingredients

November 9, 2021

The Canadian Food Inspection Agency (CFIA) has recently received requests to allow substitution of different ingredients due to shortages caused by supply chain disruptions for certain food additives. In addition, the CFIA is aware that there can be seasonal variation or shortages of certain ingredients for natural or economic reasons. Manufacturers must then substitute, vary or omit ingredients that are normally used. The CFIA would like to take this opportunity to highlight existing rules for ingredient substitution.

When the substitution cannot be planned for, it is the responsibility of the regulated party to evaluate and mitigate any associated or potential risks. For example, measures must be in place to verify if an additive used is permitted in the food or if the substitution will introduce an allergen that is not already declared on the label. If the risk is low, current CFIA inspection framework allows for flexibility to permit the substitution for short periods of time without having to change the label. The regulated party must still have a plan to demonstrate how the supply shortage will be resolved within this period or how the product labels/formulation will be brought into compliance.

When a substitution can be planned, there are provisions in the Food and Drug Regulations (FDR) to allow for this flexibility. The regulations outline how manufacturers can substitute, vary or omit ingredients within a 12-month period, while maintaining a correct list of ingredients for consumers. No objection will be taken if an asterisk appears next to an ingredient to indicate that an explanation regarding an omission, substitution or variation will appear at the end of the list of ingredients. Ingredients that may be omitted or substituted should be grouped with the same class of foods and the class group should appear at the proper place in the list of ingredients [B.01.011(1), FDR; 284(1), SFCR].

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