Labelling requirements for dairy products

On this page

• Overview
• Exemptions
• Common name
  • Modified standardized common names for dairy products
  • Common names for lactose-free dairy products
• Additional terms
  • Percentage of skim milk and whey powder
  • Firmness, ripening and other descriptions for consumer prepackaged cheese
• List of ingredients
  • MicroGARD ingredient
• Net quantity
• Name and principal place of business
• Country of origin
• Percent (%) milk fat and moisture declarations
  • Milk fat
  • Moisture
  • Table: Percent (%) milk fat and moisture declarations
• Date markings and storage instructions
• Nutrition labelling
  • Serving size
• Grade name
• Lot code
• Voluntary claims and statements
  • Highlighting dairy ingredients in other foods
  • Use of the term "milk"
  • "100% Canadian milk", "made with 100% Canadian milk" and "100% Canadian dairy" claims
  • Probiotic claims
  • Comparative claims
  • "Made from raw or unpasteurized milk" labelling on cheese
• Additional information
  • Guidelines
  • Information letters and policy updates
  • Records of decision
• Definitions
  • Consumer prepackaged
  • Dairy product
  • Foreign state
  • Milk
  • Milk product
  • Milk solids
  • Person
  • Prepackaged

Overview

Dairy products are foods produced from the milk of mammals and include those covered by a food standard in the Safe Food for Canadians Regulations (SFCR) or the Food and Drug Regulations (FDR). Examples of dairy products include milk, butter, ice cream and cheese.

This section summarizes the labelling requirements that apply to imported dairy products, as well as those that are manufactured, processed, treated, preserved, graded, packaged or labelled in Canada for interprovincial trade and for export. In some cases, the labelling requirements would also apply when these are intraprovincially traded.

Dairy products are subject to the provisions of the:

• Safe Food for Canadians Act (SFCA)
• Safe Food for Canadians Regulations (SFCR)
• Food and Drugs Act (FDA)
• Food and Drug Regulations (FDR)

When sold intraprovincially, dairy products are subject to the labelling requirements under the FDA and FDR, as well as specific requirements of the SFCA and SFCR that apply to prepackaged foods sold in Canada, regardless of the level of trade. Provincial regulations may also have labelling requirements that apply when these products are sold within that province.

The labelling requirements detailed in the following section are specific to dairy products. Refer to the Industry Labelling Tool for additional core labelling and voluntary claims and statements requirements that apply to all prepackaged foods.

Exemptions

Individual portions of consumer prepackaged dairy products that are for sale from automatic vending machines or mobile canteens, or that are served by a restaurant or other commercial enterprise with meals or snacks, are exempt from the labelling requirements prescribed in sections 246, 248 and 250 of the SFCR [251, SFCR]. For example, these products could include small cartons of milk or single-serve butter cups. The requirements of these sections include, for example, descriptive terms for certain prepackaged dairy products, the declaration of "Product of" with the country of origin for imported dairy products, and the declaration of percentage of moisture and percentage of milk fat. These products are also exempt from net quantity declaration [241.2(1)(a) and (c), SFCR].

Common name

The common name must be declared on the principal display panel of prepackaged food, including dairy products [B.01.006(1), FDR; 218(1)(a), SFCR]. For more details, refer to Common name.

Milk, unless otherwise designated, refers to cow's milk [B.08.003, FDR]. The standards for milk set out in sections B.08.003 to B.08.028 of the FDR do not apply to milk from any animal other than a cow [B.08.002.1, FDR]. Dairy products made with milk from an animal other than a cow must clearly indicate the animal source of the milk [B.08.028.1, FDR]. In the case of consumer prepackaged dairy products, this must be indicated on the principal display panel unless indicated in the common name [248(c), SFCR].

Common names for standardized dairy products are shown in bold-faced type in Division 8 of the FDR or in the Canadian Standards of Identity, Volume 1 – Dairy Products document which is incorporated by reference into the SFCR. As with all foods with a standard of identity, only those foods that meet all the provisions set out in the standard can use the prescribed common name [201, SFCR]. For dairy products that do not fall under a standard, the appropriate common name is the name by which the food is generally known.

Modified standardized common names for dairy products

A dairy product that deviates from a prescribed standard may not use the common name associated with that standard unless the standardized common name is modified to indicate how the food differs in every respect from the food described by the standard. For more information, see Modified standardized common names.

Some cheeses/varieties are allowed to contain more than the maximum percentage of moisture and less than the minimum percentage of milk fat set out in the standard, provided the flavour and texture are maintained and the common name is modified with descriptive terminology that meets FDR requirements for claims and statements [30, Canadian Standards of Identity, Volume 1 – Dairy Products; B.08.033, FDR].

Common names for lactose-free dairy products

The food enzyme lactase is added to some dairy products to eliminate the presence of lactose. Some dairy product standards allow for the addition of lactase as a food additive, whereas others do not. See Health Canada's List of permitted food enzymes for more information on permitted uses of lactase.

Dairy products with a standard that does not allow the addition of lactase

The addition of lactase to these products will cause the food to deviate from the standard. If this is done, the common name must reflect the deviation. For example, the standard for milk does not allow for the addition of lactase. Therefore, if lactase is added to milk, the common name must be modified to indicate how the milk does not meet the "milk" standard, such as "lactose-free milk".

Dairy products with a standard that allows the addition of lactase

The addition of lactase to these products is within the provisions of the standard. Therefore, in this case, the common name can either be the standardized common name, or additional information can be added to reflect the addition. For example, the standard for ice cream mixes allows for the addition of lactase to the milk used in ice cream mixes. Therefore, if lactase is added to the milk used for an ice cream mix, the final product can either be called "ice cream" or "lactose-free ice cream".

For more information on lactose-free claims, refer to Negative claims pertaining to the absence or non-addition of a substance.

Additional terms

In some cases there are additional terms that must be included on the principal display panel (PDP) of prepackaged dairy products when traded interprovincially, imported, or exported [242, 246(a), 247(a), 247(c), 247(d), SFCR].

Percentage of skim milk and whey powder

The principal display panel must also include the percentage of each powder in the case of a combination of prepackaged skim milk powder and whey powder [246(b), SFCR].

Firmness, ripening and other descriptions for consumer prepackaged cheese

The principal display panel of consumer prepackaged cheese must bear:

• the relative firmness of the cheese
• the principal ripening characteristic, except for soft white cheese, and
• in the case of a mixture of grated or shredded cheese, the varieties in descending order of their proportion in the cheese [249(1), SFCR]

This information is not required for standardized cheeses, inclusive of varieties listed in the table to section B.08.033 of the FDR [249(2), SFCR].

Relative firmness

The relative firmness of cheese must be identified by the expressions in Table 1 of the Descriptive Words, Expressions and Identification Names for Specific Foods document, according to the moisture content on a fat-free basis [249(3), SFCR].

Principal ripening characteristics

The principal ripening characteristic of cheese must be identified by the words or expressions in Table 2 of the Descriptive Words, Expressions and Identification Names for Specific Foods based on the ripening process it has undergone [249(4), SFCR].

List of ingredients

The same list of ingredients requirements and exemptions that apply to all foods also apply to dairy products. For example, prepackaged individual portions of dairy products that are intended solely to be served by a restaurant or other commercial enterprise with meals or snacks (for example, single portions of butter) are exempt from the ingredient list requirement [B.01.008(2)(b), FDR]. See Prepackaged products that do not require a list of ingredients for more details.

Ingredients must be declared by an appropriate common name in the list of ingredients [B.01.010(2), FDR]. Dairy ingredient common names include the appropriate standardized or unstandardized common names, as well as the class/collective names "milk ingredients" or "modified milk ingredients" [Table 2, Common Names for Ingredients and Components document; B.01.010(3)(b), FDR]. Refer to Class/collective names for ingredients and components under Common names in the List of ingredients page for more information.

MicroGARD ingredient

MicroGARD is an ingredient produced from the fermentation of either dextrose or skim milk with a standard dairy culture. When MicroGARD is added as an ingredient to a food, the common names "cultured skim milk", "fermented skim milk", "cultured dextrose" or "fermented dextrose", as applicable, must be declared in the list of ingredients of the final food along with the ingredient's components.

Cultured skim milk should not be included in the class/collective name "modified milk ingredients" provided for in Table 2 of the Common Names for Ingredients and Components document. Additionally, cultured dextrose and cultured skim milk are not considered food additives.

Cultured dextrose and cultured skim milk are mixtures of propionic, butyric and lactic acids and peptides that act as shelf extenders or preservatives. Therefore, it is not acceptable to claim that the final food does not contain preservatives or is not preserved.

Net quantity

For most consumer prepackaged dairy products, a net quantity declaration is required on the principal display panel in metric units [221, 232, SFCR].

For prepackaged other than consumer prepackaged dairy products, a net quantity declaration is required on the principal display panel in metric or Canadian units, or both, if a standard is set out for the dairy product in the Canadian Standards of Identity, Volume 1 – Dairy Products. If the net quantity is in both units, they must be grouped together. If no standard is set out for the dairy product in the Canadian Standards of Identity, Volume 1 – Dairy Products, the net quantity must be in metric units [243, 244.1(a), 244.3(a), 244.4(a), SFCR].

The net quantity declaration of prepackaged dairy products must be shown by volume or weight in accordance with the document incorporated by reference, Units of Measurement for the Net Quantity Declaration of Certain Foods [231, 244, SFCR].

When 2 or more individually packaged butter patties, butter reddies or other related dairy products are sold as a one unit consumer prepackaged food of more than 20g, the common name and number of individually packaged food in each class must be shown on the principal display panel, along with either:

• the total net quantity of the individually packaged food in its class, or
• the net quantity of each identical individually packaged food in its class [239, SFCR]

For additional details, refer to Net quantity.

Name and principal place of business

The FDR and SFCR require all prepackaged foods to carry a declaration of the name and principal place of business of the person by or for whom the food was manufactured, prepared, produced, stored, packaged or labelled on the label. For more information, refer to Name and principal place of business.

Country of origin

Imported prepackaged dairy products, as per the definition of dairy product within the SFCR, must declare the words "Product of" / "produit de", followed by the name of the country of origin, on any part of the label other than solely on the bottom of the container [245(2), 245(3), 250(1)(a), SFCR].

In addition, consumer prepackaged cheese that is packaged in Canada from imported bulk cheese for which a standard is set out in the Canadian Standards of Identity, Volume 1 – Dairy Products is required to declare the words "Product of" / "produit de", followed by the name of the country of origin, on the principal display panel [250(1)(b) and (2), SFCR].

For imported prepackaged dairy products other than consumer prepackaged dairy products, the country of origin information mentioned above must be shown in boldface type in characters at least 16 mm in height [253, SFCR].

Note: In the SFCR, country of origin is referred to as foreign state of origin.

Percent (%) milk fat and moisture declarations

Milk fat

The percentage of milk fat followed by the words "milk fat" or the abbreviations "B.F." or "M.F." must be shown on the principal display panel of certain dairy products. The Percent (%) milk fat and moisture declarations table below outlines which dairy products are required to carry the percent milk fat declaration.

Moisture

In addition to percent milk fat, certain dairy products must also declare the percentage of moisture in the food on the principal display panel followed by the words "moisture" or "water" (for example, "31% M.F. and 39% Moisture"). The Percent (%) milk fat and moisture declarations table below outlines which dairy products are required to carry the percent moisture declaration.

Unless otherwise specified, the declarations apply to prepackaged dairy products.

Table: Percent (%) milk fat and moisture declarations

Date markings and storage instructions

Dairy products with a durable life of 90 days or less are subject to the same date marking and storage instructions requirements as other prepackaged foods. For more information including manner of declaring, see the Date markings and storage instructions page.

Nutrition labelling

The same nutrition labelling requirements and exemptions that apply to all foods also apply to dairy products. For example, the following are always exempt from declaring a Nutrition Facts table on the label:

• prepackaged individual portions of dairy products that are solely intended to be served by a restaurant or other commercial enterprise with meals or snacks (for example, portions of butter) [B.01.401(2)(c)(ii), FDR]
• some milk products sold in refillable glass containers [B.01.401(2)(c)(iii), FDR]

See Nutrition labelling exemptions for more details.

Serving size

The serving size is based on the edible portion of the food as sold and is closely aligned with the regulated reference amount. The Table of reference amounts for food provides reference amounts for a variety of categories of food, including "Dairy products and substitutes". It also gives instructions on how to determine and express the serving size in the Nutrition Facts table for multiple-serving prepackaged products.

Examples of serving sizes are explained below:

Wedge or piece of cheese: The reference amount for cheese, including cream cheese and cheese spread, except those listed as a separate item in column 1 of the Table of reference amounts for food, is 30 g. The serving size is expressed by first declaring the household measure [dimensions of the piece of cheese (# cm cube or # cm slice) that is closest in weight in grams to the 30 gram reference amount], followed by the metric measure (which corresponds to the 30 gram reference amount) [for example, "Per 3 cm cube (30 g)" or "Per 1.5 cm slice (30 g)"] [Item D.1, Dairy products and substitutes, Table of reference amounts for food].

Soft spreadable cheese: The reference amount for soft spreadable cheese is also 30 g. The serving size is expressed by first declaring the household measure (number of tablespoons that is closest in weight in grams to the 30 gram reference amount), followed by the metric measure (which corresponds to the 30 gram reference amount) [for example, "Per 2 tbsp (30 g)"] [Item D.1, Dairy products and substitutes, Table of reference amounts for food].

Refer to Serving size for more information.

Grade name

All references to the "Compendium" in this section refer to the Canadian Grade Compendium. The Canadian Grade Compendium, Volume 4 – Dairy Products specifies the grade requirements for dairy products and Volume 9 – Import Grade Requirements specifies import grade requirements.

Dairy products, except for dairy products that are exported, have optional grades. If they are graded and traded interprovincially, or imported, they must meet the requirements set out in the Compendium for the applicable grade and must be labelled accordingly [307(b), SFCR]. For consumer prepackaged dairy products, the grade name must be shown on the principal display panel in characters of at least the minimum height set out in column 2 of Schedule 6 for the area of a principal display surface set out in column 1 [312(b), SFCR].

Licence holders can apply a grade name to, and use one of the following grade names in connection with, a dairy product if it is identified in their licence and if the dairy product has been graded by a licence holder [308(1)(d), SFCR].

Grade name for butter, calorie-reduced butter, dairy spread, light butter or lite butter, whey butter and cheddar cheese:

• Canada 1

[1(1), Compendium, Volume 4 – Dairy products]

Grade names for dry milk products:

• Canada 1
• Canada 2

[1(2), Compendium, Volume 4 – Dairy products]

Imported dairy products that are graded by a licence holder must use the applicable Canadian grade names above, rather than a foreign grade designation [2(2), Compendium, Volume 9 – Import Grade Requirements].

For graded dairy products, the grade name must be displayed as shown [313, SFCR; 2(1), Compendium, Volume 4 – Dairy Products]:

Description for photo - Figure 1

Outline of a maple leaf with the following text written and centered inside: the word CANADA in uppercase, bold text, which is slightly curved, and below that, the number 1. The text CANADA 1 is the bilingual grade name of the dairy product.

Description for photo - Figure 2

Outline of a maple leaf with the following text written and centered inside: the word CANADA in uppercase, bold text, which is slightly curved, and below that, the number 2. The text CANADA 2 is the bilingual grade name of the dairy product.

The figures above may be white or any uniform colour [2(2), Compendium, Volume 4 – Dairy Products].

See Grades for more information.

Lot code

For information on the requirement for a lot code or other unique identifier for traceability purposes, consult Traceability-specific labelling requirements.

Please note that recommendations have been made regarding the use of potentially misleading lot codes. For additional information, please refer to the Lot code section on the Date markings and storage instructions page.

As well, refer to Legibility requirements for other specific labelling topics for information on the legibility requirements that are applicable to lot codes.

Voluntary claims and statements

Highlighting dairy ingredients in other foods

The Highlighted ingredients claims section provides information that also applies to highlighting the presence of a dairy ingredient, either within the common name of a food or as a separate claim.

Care must be exercised in the use of the words "butter" and "cream" in the name of a food or in descriptions relating to that food. For more information on this subject, refer to Descriptions with certain characterizing ingredients, under Highlighted ingredients claims section.

Use of the term "milk"

The term "milk" cannot be used generically to describe all types of fluid milk in all labelling situations.

In order to meet the common name requirement, the term "milk" is a reference only to "milk" as standardized in section B.08.003 of the FDR. For other types of milk, the prescribed common names as shown in bold face type in Division 8 of the FDR or in the Canadian Standards of Identity, Volume 1 – Dairy Products must be used. Likewise, in the list of ingredients, either the prescribed common names must be used, or the term "milk ingredients" may be used as per item 7, Table 2 of the Common Names for Ingredients and Components document [B.01.010(3)(b), FDR].

Reference to the term "milk" is considered to mean milk in the generic sense when Regulations refer to formulations designed for mixing with milk, for example, under D.03.002 of the FDR. These formulations may be mixed with any "milk" (for example, skim milk, partly skimmed milk, whole milk, either reconstituted or fresh, etc.).

The directions for use or any other similar references found on labels or in advertisements should state the exact type of milk which is to be used (for example, "made with partly skimmed milk").

Declaration of the percentage milk fat of milk used as an ingredient is considered a non-permitted nutrient content claim. It is only permitted when used in conjunction with a permitted nutrient content claim.

"100% Canadian milk", "made with 100% Canadian milk" and "100% Canadian dairy" claims

The voluntary use of a "100% Canadian milk" claim (or similar) on dairy products must be truthful and not misleading. For more information, see Guidelines for the acceptable use of "100% Canadian milk" claims on dairy products.

Probiotic claims

Some dairy products may have non-strain specific claims stating the nature of probiotics present. See Probiotic claims for more information.

Comparative claims

Cream cheese is not included in the milk products and alternatives group because of its low calcium and high fat content. Therefore, a comparative claim between cream cheese and a milk product is not permitted. Cream cheese falls within the category of "other foods" B.01.500(1)(a) foods that are mostly fats, and may only be compared to similar reference foods or reference foods of the same food group. See Comparative nutrient content claims for more information.

"Made from raw or unpasteurized milk" labelling on cheese

Health Canada has provided Voluntary guidance on improving the safety of soft and semi-soft cheese made from unpasteurized milk. As part of this guidance, it is recommended that manufacturers label their products with the words "made from raw or unpasteurized milk" on the principal display panel of the product and/or declare the raw or unpasteurized milk in the list of ingredients. The purpose of this labelling is to assist consumers in making informed choices about the consumption of products containing unpasteurized milk, particularly for vulnerable populations who may be at greater risk of developing foodborne illness.

Additional information

Guidelines

• Guidelines for the acceptable use of "100% Canadian milk" claims on dairy products

Information letters and policy updates

• Modified milk ingredients as sources of calcium

Records of decision

• Use of partly (partially) skimmed milk from the butter making process in skim milk powder production
• Use of whey cream in butter production

Definitions

Consumer prepackaged

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].

Dairy product

Means milk or a food that is derived from milk, alone or combined with another food, and that contains no oil and no fat other than that of milk [1, SFCR].

Foreign state

Foreign state includes a WTO Member as defined in subsection 2(1) of the World Trade Organization Agreement Implementation Act [1, SFCR].

Milk

"Milk" or "whole milk", as used in the manufacture of dairy products, means the normal lacteal secretion, free from colostrum, obtained from the mammary gland of an animal [1(1), Canadian Standards of Identity, Volume 1 – Dairy Products].

Milk product

Means any of the following:

• (a) partly skimmed milk, skim milk, cream, buttermilk, whey and whey cream
• (b) milk in concentrated, dried, frozen or reconstituted form and any product referred to above in concentrated, dried, frozen or reconstituted form
• (c) butter, butter oil and whey butter
• (d) milk solids
• (e) whey protein concentrate [1(1), Canadian Standards of Identity, Volume 1 – Dairy Products]

Milk solids

When used as an ingredient, means:

• (a) in respect of a dairy product other than cheese, any constituent of milk other than water or casein, alone or combined with other constituents of milk, that has not been altered in its chemical composition
• (b) in respect of cheese, any constituent of milk other than water, alone or combined with other constituents of milk [1(1), Canadian Standards of Identity, Volume 1 – Dairy Products]

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

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, and includes consumer prepackaged [1, SFCR].