Food labelling requirements checklist

The following checklist is a self-assessment tool to help industry understand labelling requirements set out in the Food and Drugs Act (FDA) and Regulations and the Safe Food for Canadians Act (SFCA) and Regulations.

The checklist only covers core labelling requirements applicable to all foods. For more information on voluntary claims or statements and commodity specific labelling requirements, visit the Industry Labelling Tool.

Labelling requirements checklist disclaimer: Adherence to the labelling requirements checklist does not preclude the Canadian Food Inspection Agency from taking regulatory action in cases of non-compliance to regulatory and legislative labelling requirements. This publication is not a legal document. The user is encouraged to consult the official version of the applicable legislation in the FDA and in the SFCA for the purposes of interpreting and applying the law. The labelling requirements checklist was last modified in July 2022.

Labelling requirements

Common name

• is a common name present?
  • if not, is the product exempt from common name?
• is the common name on the principal display panel (PDP)?
• is the common name in letters of 1.6 mm or greater?
  • or, if the area of the principal display surface (PDS) is 10 cm² (1.55 inches²) or less, is the common name shown in characters with a minimum type height of 0.8 mm (1/32 inch)?
• is it an appropriate common name?
  • as printed in bold face type, but not in italics, in the FDR or in the Canadian Standards of Identity documents incorporated by reference (IbR) in the SFCR
  • as prescribed by any other regulation
  • the name by which the food is generally known or a name that is not generic and that describes the food, if the name is not so printed or prescribed, or
  • if the food is likely to be mistaken for another food, the common name must include words that describe the food's true nature with respect to its condition

Refer to the Industry Labelling Tool for further information on common name.

Net quantity declaration

• is a net quantity declaration present?
  • if not, is the product exempt from net quantity?
• is the net quantity declared on the PDP?
• is it in metric units?
  • or, in metric or Canadian units if it is a consumer prepackaged food that is packaged from bulk at retail, other than an individually measured food?
• is the appropriate manner (volume, weight, count) for the product used?
• is it rounded to 3 figures, unless below 100?
• are the correct bilingual symbols used? (for example, ml, mL, mℓ, L, l, ℓ for liquids; g, kg for solids)
  • if not, and the units are written out (for example, kilograms), are the units declared in both languages (unless exempt from bilingual labelling)?
• does the size of the numerical portion meet the minimum type height requirements (based on size of PDS)? Is it in bold face type? Are the units in letters of 1.6 mm or greater (based on lowercase "o")?
• if optional Canadian units are also present, are they declared properly?
• if optional U.S. gallons and quarts are also present, are they identified properly? (fl oz optional)

Refer to the Industry Labelling Tool for further information on Net quantity.

List of ingredients and allergen labelling

• is a list of ingredients present?
  • if not, is the product exempt from declaring a list of ingredients or is the product a single ingredient food?
• are ingredients in descending order of proportion by weight?
• have the ingredients been declared using an appropriate common name?
• have components been properly declared where required?
• have sugars-based ingredients that are required to be grouped after the term "Sugars" been properly declared?
• are priority allergens, gluten and added sulphites declared using the prescribed source name or common names, as required?
  • in the list of ingredients, or
  • in a "food allergen source, gluten source and added sulphites statement", or
  • in a cross-contamination statement?
• is the "food allergen source, gluten source and added sulphites statement" and/or cross contamination statement, if present, at the end of the list of ingredients?
• are the English and French lists of ingredients and allergen declarations the same?

Location

• is the information in the list of ingredients displayed:
  • on a panel other than the bottom? (unless it falls under one of the specific cases)
  • on one continuous surface with no intervening printed, written or graphic material?

Presentation

• is the print, background and/or border in the appropriate colours and contrast?
• is the font and type:
  • sans serif?
  • regular or bold as required?
  • in the correct width, height and use the correct leading?
  • in a manner so that characters do no touch each other?
• do the characters appear in upper case / lower case as required?
• is each entry separated by a comma or bullet point as required?

Refer to the Industry Labelling Tool for further information on list of ingredients and allergens labelling.

Name and principal place of business

• is a name and principal place of business present, to the level of detail required?
  • if not, is the product exempt from declaring name and principal place of business?

Imported product

• Canadian name and principal place of business, grouped with the geographic origin, or preceded by the expressions "Imported by / importé par" or "Imported for / importé pour"?
  • or, foreign name and principal place of business is identified?
• is the information on any label panel except solely on the bottom (except ornamental containers)?
• are type height requirements of 1.6 mm (1/16 inch) or greater are met?
  • or, if the area of the principal display surface (PDS) is 10 cm² (1.55 inches²) or less, is the minimum type height 0.8 mm (1/32 inch)?
• is it in English or French?

Refer to the Industry Labelling Tool for further information on name and principal place of business.

Date markings

"Best before" date

• is a "best before" date required? (durable life of 90 days or less, unless the food is exempt from a "best before" date or is packaged where sold at retail)
  • if so, is it present?
• is the correct wording "best before" / ""meilleur avant" used in English and French (or in one language if exempt from bilingual labelling)?
• is the wording grouped with the date or does it clearly explain the date if located elsewhere on the label?
• is the presentation of the date acceptable (order of info (year, month, day), use of bilingual symbols for months)? - For example, MA 26.
• is the location of the date acceptable (anywhere on the label, including the bottom if a reference is made elsewhere on the label indicating the date is present on the bottom)?

"Packaged on" date

• is a "packaged on" date required? (durable life of 90 days or less and packaged where sold at retail, unless the food is exempt from a "packaged on" date)
  • if so, is it present?
• is the correct wording "packaged on" / ""empaqueté le" used (or in one language if exempt from bilingual labelling)?
• is the wording grouped with the date or does it clearly explain the date if located elsewhere on the label?
• is the presentation correct as described above?
• is location of the date acceptable as described above?

Storage instructions

• are storage instructions required? (required if storage conditions differ from normal room temperature)
  • if so, are they present and complete?

Refer to the Industry Labelling Tool for more information on food-specific labelling requirements.

Expiration date

• is an "expiration date" required? (food for special dietary use and infant formula foods)
  • if so, is it present?
• is the location of the date acceptable (anywhere on the label, including the bottom if a reference is made elsewhere on the label indicating the date is present on the bottom)?

Legibility and availability

• is all of the above information readily discernible?

Refer to the Industry Labelling Tool for further information on date markings.

Nutrition labelling

Nutrition Facts table (NFt)

• is a NFt present?
  • if not, is the product exempt from NFt? (or has a NFt been triggered?)
  • if not, does the label have an available display surface (ADS) of less than 15 cm², therefore being exempt from the need to carry a NFt?
  • if not, does the product qualify for the small package (ADS of less than 100 cm²) exemption? (postal address or toll-free number)

Note: When ADS is less than 100 cm², a small package NFt exemption may apply to products containing added acesulfame-potassium, aspartame, neotame or sucralose that qualify for a "sugar-free" claim provided certain additional requirements are met.

Location/orientation

• is the NFt:
  • on the outer package? (except for alternate methods of presentation)
  • not destroyed when product is opened? (except for single-serving containers)
  • on one continuous surface of the ADS?
  • placed so that product will not leak or be damaged in order to view the NFt?

Format

• is the appropriate format family used?
  • standard format: all foods and certain assortments
  • simplified format: 6 or more of calories and core nutrients = 0
  • simplified format - single-serving prepackaged products
  • dual format: foods requiring preparation/different amounts
  • aggregate format: different kinds/different amounts
  • infants 6 months of age or older but less than 1 year of age
• is an appropriate format version (size) chosen within a "family" of formats?

Contents

• is the serving size aligned with the regulated reference amount (RA)? Is it expressed using a household measure (HM) first, followed by the corresponding metric measure (MM) in parentheses, based on the food as sold?
  • if single-serving container, does the package contains less than 200 % of the RA for that food, or can the quantity of food in the package be reasonably eaten by one person at a single eating occasion?
• are energy and the 12 core nutrients declared, unless conditions for use of simplified format and single-serving simplified format have been satisfied? (Note: Small packages with ADS of less than 100 cm² that have lost their NFt exemption are only required to declare certain nutrients).
  • are any non-permitted nutrients declared?
  • are triggered nutrients declared?
  • have the correct units and % DV (percent Daily Value) been used, when permitted/required?
  • have amounts (absolute amounts and % DV) been rounded as per the rounding rules set out in the Regulations?
  • is the % Daily Value interpretative statement included in the NFt (when required in the applicable NFt figure used)?

Graphical and technical requirements

• colour: is the table background and print in the appropriate colours?
• is the font and type:
  • sans serif?
  • regular or bold as required?
  • upper case / lower case as required?
  • with no crowding of characters?
• is the information in the correct order?
• are the correct indenting and leading used?

Refer to the Industry Labelling Tool for further information on nutrition labelling.

Bilingual requirements

• is all mandatory information referred to in this checklist in English and French, except the responsible person's name and address which may be in either French or English?
  • If not, does a bilingual exemption apply (prepackaged other than consumer prepackaged container destined to a commercial or industrial enterprise, specialty food, local food, test market food)?

Refer to the Industry Labelling Tool for further information on bilingual labelling.

Irradiation

• is the food permitted to be irradiated?
  • If so, is there a written statement such as "irradiated" or "treated with radiation" or "treated by irradiation" and the international symbol?
• is the statement readily discernible?
• is the international symbol on the principal display panel?
• does the international symbol meet the minimum size requirements for the outer diameter?
• are irradiated ingredients that constitute more than 10% of the final food identified in the list of ingredients as "irradiated"?

Refer to the Industry Labelling Tool for further information on irradiated foods.

Sweeteners (in addition to list of ingredients requirements)

• is the sweetener required to be declared on the PDP?
  • if so, is this statement present?
• is the PDP declaration in the minimum type size required?
• does the sweetener used trigger an NFt?
  • If so, is it present with the sweetener content declared?

Note: When ADS is less than 100 cm², a small package NFt exemption may apply to products containing added acesulfame-potassium, aspartame, neotame or sucralose that qualify for a "sugar-free" claim provided certain additional requirements are met. When ADS is less than 15 cm², the product is always exempt.

• does the sweetener used require an amount declaration?
  • if so, is it present, in milligrams per serving of stated size, grouped with the list of ingredients?
• if aspartame is used, does the product make a phenylalanine declaration?

Refer to the Industry Labelling Tool for further information on sweeteners.

Country of origin

• is the product one of the following?
  • wine and brandy
  • dairy products
  • honey
  • fish and fish products
  • fresh fruits or vegetables
  • shell egg and processed egg products
  • meat and poultry products
  • maple products
  • processed fruit or vegetable products
• If so, check the food-specific labelling requirements, as for some imported prepackaged products it is mandatory to state the country of origin. When required use the country of origin declaration "Product of [Name the country of origin]".

Refer to the Industry Labelling Tool for further information on country of origin labelling.

Notes

• all label information provided must be truthful and not misleading.
• additional federal and provincial regulations may apply to the product.
• additional commodity-specific requirements may apply to the product.