Simulated meat and simulated poultry products

The requirements below are specific to these unstandardized foods:

• B.01.001(1), FDR
• B.01.100, FDR
• B.14.085 to B.14.090, FDR
• B.22.029, FDR
• D.03.002, FDR

Same regulatory requirements as any other unstandardized food.

The food resembles a meat or poultry product due to:

• the sensory characteristics of the food (for example, visual appearance, texture, flavour and odour), and/or
• how it is advertised and represented (for example, the food is labelled, advertised or marketed as a food resembling a meat product or poultry product)

For example, a nonmeat food which is manufactured to have the appearance of a beef burger, by adding components to simulate bleeding or to simulate a marbling of fat effect.

Note: specific guidance on advertisements and representations is provided below.

While such foods may have certain visual characteristics (such as colour, texture, shape) similar to that of a meat or poultry product, they are not likely to be mistaken for a meat or poultry product. They are not labelled or advertised as resembling a meat or poultry product.

For example, a tempeh patty (a food brown in colour, made of ingredients that are comminuted and shaped into a disk or ball) does not resemble a meat or poultry product and the product is not advertised or represented as being similar to a meat or poultry product.

Note: specific guidance on advertisements and representations is provided below.

The common name of a simulated meat or simulated poultry product is the common name of the meat or poultry product that is simulated, modified by the word "simulated", that is, "simulated (naming the meat product or poultry product)" [B.01.100(1), FDR].

• Examples:
  • Simulated "naming the species (of animal)": simulated beef, simulated veal, simulated pork, simulated chicken.
  • Simulated "naming the meat cut": simulated sirloin, simulated tenderloin, simulated steak.

The word "simulated" in the common name must be shown in letters of at least the same size and prominence as those used in the remainder of the common name.

Note: abbreviations, initials, symbols and phonetic renderings of meat terminology could be used on some labels, for example, "veggie simulated chick'n tenders". Although the FDR and the Safe food for Canadians Regulations (SFCR) do not permit the use of abbreviations to provide mandatory labelling information except where specified, the use of names such as these on product labels and/or advertising would be considered representation as a simulated meat product.

Non-prepackaged simulated meat or poultry product:

When a simulated meat or poultry product is not prepackaged, the common name shall be shown on a sign displayed on or adjacent to the product in letters that are legible and conspicuous [B.01.100(3), FDR].

The common name of such an unstandardized food is the name by which the food is generally known, or a name that is not generic and that describes the food [B.01.001(1), FDR].

The common name and other expressions on the principal display panel must indicate the true nature of the product and accurately and truthfully describe the product. The main ingredient could form part of the common name along with descriptive terms such as "burger", "loaf", "patty", "jerky", "sausage", provided that the food:

• does not have the appearance of a meat or poultry product, and
• is not likely to be mistaken for a meat or poultry product or simulated meat or simulated poultry product

Examples: veggie burger, tofu burger, Portobello mushroom burger, lentil loaf, soy patty, soy sausage.

Use of the term "flavoured" in the common name:

The term "flavoured" is acceptable in the common name if:

• the common name is accurate and truthful
• the product does not have the appearance of meat or poultry, and
• is not likely to be mistaken for a meat or poultry product or simulated meat or poultry product

Example: chicken flavoured veggie loaf.

These products:

• are unstandardized products that do not contain meat, poultry or fish product [B.01.001(1), FDR]
• must meet the minimum protein content and rating requirements [B.14.085 to B.14.090, B.22.029, FDR]
• must not exceed the maximum requirements for fat content [B.14.085 to B.14.090, B.22.029, FDR]
• are mostly made of plant-based ingredients (cereals, legumes, nuts, seeds, vegetables) but may also contain other ingredients (water, salt, yeast)
• may contain other animal products such as dairy or eggs
• may contain food additives

For a list of additives permitted for foods, refer to Health Canada's Lists of permitted food additives.

These products can be described as follows:

• are unstandardized products that do not contain meat, poultry or fish
• are mostly made of plant-based ingredients (cereals, legumes, seeds, vegetables) but may also contain other ingredients (water, salt, yeast)
• may contain other animal products such as dairy or eggs
• may contain food additives

For a list of additives permitted for foods, refer to Health Canada's Lists of permitted food additives.

Simulated meat and poultry products must carry the declaration "contains no meat" or "contains no poultry" on the principal display panel of the label, in close proximity to the common name and in letters of at least the same size and prominence as those shown in the product's common name [B.01.100(4), FDR].

When used as an ingredient:

When simulated meat is used as an ingredient of another food, such as a soup, the declaration "contains no meat" is not required on the label. Additionally, any pictures or vignettes on the packaging of the final food must not suggest that meat is present, unless otherwise added through another ingredient.

Non-prepackaged simulated meat or poultry product:

When a simulated meat or poultry product is not prepackaged, the "contains no meat" or "contains no poultry" declaration shall be shown on a sign displayed on or adjacent to the product in letters that are legible and conspicuous [B.01.100(3) and (4), FDR].

The declaration "contains no meat" or "contains no poultry" is not required on the label, but may be applied provided that it is not false, deceptive or misleading.

Simulated meat and simulated poultry products are subject to mandatory specific fortification requirements [B.14.085 to B.14.090, B.22.029, D.03.002(1), FDR]. Refer to item 8 of the table of Foods to which vitamins, mineral nutrients and amino acids may or must be added.

Unless otherwise exempted, fortification of these foods is prohibited.

Refer to this page for information on Foods to which vitamins, mineral nutrients and amino acids may or must be added.

Simulated meat and simulated poultry products are always required to declare a Nutrition Facts table (NFt) on their labels [B.01.401, FDR].

Therefore, the label must carry a nutrition symbol if the amount of saturated fat, sugars and/or sodium is equal to or higher than the specified nutrient thresholds [B.01.350, FDR].

Added vitamins and minerals must be declared in absolute amounts and as a percent daily value per serving of stated size in the NFt [B.01.402(6), table to B.01.401, items 13 and 15, table to B.01.402, items 19 to 24, 26, 30, 31, 33, FDR].

Unless otherwise exempted, these products are usually required to declare a Nutrition Facts table (NFt) on their labels [B.01.401, FDR].

When required to declare an NFt, the label must carry a nutrition symbol if the amount of saturated fat, sugars and/or sodium is equal to or higher than the specified nutrient thresholds [B.01.350, FDR].

Claims are permitted provided they are truthful and not misleading and not otherwise prohibited.

Labels and/or advertising may include claims that compare the food to meat or poultry or represent it as a substitute for meat or poultry products.

Additional information may be used on labels and/or advertising, provided they are not false, deceptive or misleading and are compliant with all other requirements. In all cases, all mandatory requirements must be met and core information, such as common name clearly indicates that the food is a simulated meat or poultry product.

Examples of acceptable claims/information may include:

• "meat alternative"
• "use in the place of (named meat)"
• "has the texture of meat"
• "vegetarian (naming the species of meat)"
• "plant-based meat"
• alternative spelling or phonetic renderings associated with meat, an animal species or cuts of meat (for example, chick'n) and brand names that include such terms

Graphical representations: pictures, vignettes, logos, endorsements and trademark contribute to the overall impression created in food labelling and advertising. When used, they must not be deceptive, misleading or misrepresent the product.

The labels and/or advertising may include graphical representation related to meat, animal source or poultry bird the product simulates. For example, the image of a turkey bird on a simulated turkey product label.

Claims are permitted provided they are truthful and not misleading and not otherwise prohibited.

Labels and/or advertising neither compare the product to meat or poultry, nor represent it as a food similar to or comparable to meat or poultry products. For example, naming the animal species or meat cuts on the label and/or advertising of a product that has been shaped or formulated to look like a meat product or meat cut would not be considered compliant.

Claims such as "vegetarian", "veggie", "plant-based" can be made, provided they are not used in conjunction with terminology that promotes the product as equivalent to meat. For example, the name "vegetarian chicken nugget" or "plant-based drumstick" would not be considered compliant as it implies that the food has appearance or that it resembles a meat or poultry product.

Graphical representations: pictures, vignettes, logos, endorsements and trademark contribute to the overall impression created in food labelling and advertising. When used, they must not be deceptive, misleading or misrepresent the product.

The use of images must not imply that the food has the appearance of, or is likely to be mistaken for, a meat or poultry product. For example, having a picture of a chicken on a "chicken flavoured soy nugget" that looks like a chicken nugget would not be compliant as the overall impression of the food would imply that the food resembles a chicken nugget and would therefore be likely to be mistaken with a simulated poultry product.