Method of production claims on food labels
On this page
- Claim substantiation
- Nature, natural
- Novel foods, including novel foods that are products of genetic modification
- Homemade, artisan made
- Method of production claims for meat, poultry and fish products
- Method of production claims for fresh fruits and vegetables
- Annex 1 – Minimum processes
- Annex 2 – Maximum processes
- Additional information
There are many types of claims that can be used on food labels and in advertisements. This section covers the requirements for method of production claims, which refer to how a product was raised, produced, prepared, and so on.
All aspects of food labels and advertising are considered in the overall impression created about food products. Claims that appear on food labels or in advertisements contribute towards this overall impression. For this reason, method of production claims are subject to the general principles for labelling and advertising.
Claims related to the method of production are also subject to subsection 5(1) of the Food and Drugs Act (FDA) and subsection 6(1) of the Safe Food for Canadians Act (SFCA), which prohibit statements and claims that are false, misleading, deceptive or that create an erroneous impression regarding the product. In the case of the SFCA, this includes the product's method of manufacture or preparation.
While most method of production claims are not mandatory, in some cases, criteria exist for their use. For example, if a company chooses to apply a voluntary organic, kosher or halal claim, then specific regulatory requirements are triggered and must be met. Other method of production claims, like irradiated foods, also trigger mandatory labelling requirements.
Regardless if specific criteria exist for the claim or not, during Canadian Food Inspection Agency (CFIA) inspections, regulated parties may be requested to demonstrate how they meet the requirements of the claim.
As outlined in the Overview section, all method of production claims provided on food labels or in advertising must be accurate, truthful, and must not mislead or deceive the consumer. During compliance and enforcement activities carried out by the CFIA, regulated parties should be able to substantiate the claims.
Acceptable manners to substantiate a method of production claim include:
- third party audit
- valid documentation, or
- non-government certification programs
All documents used to substantiate a method of production claim must be made available to a CFIA inspector upon request.
Refer to Preventive control plan (PCP) content for consumer protection for more information and examples of documentation to assist companies comply with the requirements for truthful and not misleading packaging and labelling of food.
The guidance outlined below is being provided to assist with industry compliance and consumer protection in accordance with the requirements set out in the FDA and SFCA and associated regulations. Companies are not restricted by the following guidance and may use an outcome-based approach for natural claims.
In general, a food can be described as "natural" if the following criteria are met, namely that the food and its ingredients:
- do not contain, or have ever contained, an added vitamin, mineral nutrient, artificial flavouring agent or food additive
- have not had any constituent or fraction thereof removed or significantly changed, except the removal of water (for example, the removal of caffeine)
- have not been subjected to processes that have significantly altered their original physical, chemical or biological state (that is to say, maximum processes)
Note that processes that do not significantly alter the food's original physical, chemical or biological state (that is to say, minimum processes) would be recognized as "natural".
Substances that impart flavours that have been derived from a plant or animal source may claim to be "natural". Furthermore, acids, bases, salts and sweeteners may be used to impart sour, bitter, salty and sweet tastes in conjunction with natural flavours. They do not alter the "natural" status of the flavours.
An outcome-based approach for natural claims
Companies have the option of following the above guidance on natural claims in its entirety, partially adhering to the above guidance, or using other criteria and methods to substantiate the claim is not misleading to consumers. This outcome-based approach to natural claims for foods or ingredients also applies to the use of the word "natural" in a trademark name.
Follow the guidance in its entirety
Where the guidance on natural claims is followed in its entirety, regulated parties are still required to have controls in place to ensure a natural claim is truthful and not misleading. Companies should be prepared to demonstrate how they follow and meet the criteria for the natural claim outlined in the guidance, if requested during an inspection.
Partially adhere to the guidance
Companies may partially adhere to the guidance on natural claims, which may include modifying the criteria, provided they substantiate any deviation.
- a food may be fortified with vitamins or contain an ingredient or additive that has been sourced from a plant or animal and/or derived from minimum processes. While the guidance provided for natural claims would not normally recognize a food to be natural if it contains added vitamins or additives (for example, milk with added vitamins A and D, enriched flour), companies would clarify, using evidence-based measures, the meaning of the claim and demonstrate how this interpretation still meets the objective of the claim and is not misleading to consumers
- to claim "natural" for an ingredient or food, the ingredient(s) and the food would not normally be allowed to have been subjected to processes that have significantly altered their physical, chemical or biological state (that is to say, maximum processes). Companies deviating from this must provide evidence and justification to demonstrate that a process could be considered not to have altered the original state of the food (for example, a process that does not include chemical addition)
- a food or ingredient with constituent(s) other than water (for example, fat or milk sugars) removed using minimum processes could be labelled as "natural". Companies would substantiate this deviation as described in the above examples
Use other criteria and methods
Companies may choose other criteria and methods beyond this guidance for determining whether the term "natural" can be used. In such cases, companies are required to demonstrate with evidence-based rationale that both the objectives of the claim and the regulatory requirements of truthful and not misleading labelling are met.
Information on evidence-based measures is provided in the section Substantiation of natural claims which follows.
Substantiation of natural claims
Regardless of which option of this outcome-based approach a company chooses to follow, companies should be prepared to provide evidence that substantiates the information on their food labels to CFIA inspectors, or as part of their preventive control plans (PCP) for consumer protection if required under the Safe Food for Canadians Regulations (SFCR).
The PCP must describe the measures taken to substantiate that labelling information is not false or misleading. The PCP must also include the documents used as evidence of the measures taken to ensure truthful and accurate labelling. These measures and documents may include results of consumer engagement, laboratory testing, third party certification or supply chain controls. Refer to the Preventive control plan interactive tool to determine if a written PCP is required. If not required under the SFCR, companies may still refer to the information provided by the CFIA on PCP to help them determine appropriate forms of substantiation.
Industry must also have procedures in place to respond to complaints from consumers. In accordance with section 83 of the SFCR, companies must log complaints received and how they were addressed. As part of inspection activities, CFIA can assess these records to evaluate if consumers are being misled by any labelling information. Refer to the Procedure for receiving, investigating and responding to complaints for more information.
Options to substantiate a natural claim
To demonstrate that a natural claim is truthful and not misleading to consumers, companies may follow the guidance for natural claims. If they choose other evidence-based means to substantiate the claim, they should be prepared to answer inquiries or adjust the claim if it is misleading.
They should also be able to explain to consumers and to CFIA what the claim means either on the product label, on a website or through another accessible method (for example, commercial advertisement) to decrease the likelihood that the consumer will be misled. To help companies substantiate and explain the meaning of the claim, they may use 1 or more of the following options of evidence-based measures:
- develop criteria for a truthful and not misleading claim
Since not defined in regulation, there may be various interpretations by the general public of the meaning of a natural claim. In such instances, companies may develop their own guidance that includes a definition or interpretation of the term or claim and criteria required to meet it. The guidance may include a process of oversight, such as verification measures for ensuring the criteria developed meet regulatory requirements of truthful and not misleading labelling.
- conduct consumer research
Companies may opt to conduct consumer research, such as online, telephone or mail surveys, product focus groups, or customer quizzes, to determine if the consumer would be misled by the claim. While a minimum sample size is not set, the consumer research should be robust enough to draw significant conclusions. Examples to show robustness include descriptions of the research method, recruitment process, participant characteristics such as demographics, data collection method and data analysis.
- use a third-party certification with established criteria that are available to consumers
A non-government or third-party organization may have already established criteria and methods of oversight for a claim. Companies may choose to comply with the third-party certification and use their logo or trademark on the label or advertising to identify that the product and/or the ingredient(s) comply with the criteria described in the certification. The use of a third-party certification indicates that a third party has certified the product after verifying its compliance against a standard, and the consumer can find additional information provided on the third-party website.
Other means may be used as long as evidence-based measures are taken to ensure the use of the term is truthful and not misleading to consumers.
Role of consumers
Consumers have a role to play and should expect the labelling of the foods they buy to be truthful and not misleading.
Consumers who are concerned about labelling information, or would like to learn more about a claim, are encouraged to contact companies directly to obtain more information.
If consumers are not satisfied with a company's response, they can report their concern to the CFIA.
Novel foods, including novel foods that are products of genetic modification
Simply put, novel foods are food products that are new or changed compared to existing foods.
There are specific requirements related to novel foods in the Food and Drug Regulations (FDR) [B.28.001, FDR]. Novel foods include foods that are derived from plants, animals or microorganisms that have been genetically modified and show a new or altered characteristic/trait. Genetically modify means to change the heritable traits of a plant, animal or microorganism by means of intentional manipulation. Genetically engineered foods are one type of genetically modified foods.
Manufacturers are required to submit detailed scientific data to Health Canada for a safety assessment before such foods can be authorized for sale.
Health Canada's approach is outlined in its 2006 Guidelines for the Safety Assessment of Novel Foods. On May 18, 2022, Health Canada added, as appendices to these guidelines, guidance on the novelty interpretation of products of plant breeding and on the pre-market assessment of foods derived from retransformants. This represents the first phase of a broader, multi-year effort to modernize guidance for all novel foods. Based on the outcome of this phase, Health Canada has published a Notice of Intent regarding the development of proposed regulatory changes. Regulated parties should refer to Health Canada's new guidance until amendments are made to the FDR.
For questions or concerns regarding the Health Canada guidance, including related specific complaints, please contact Health Canada at email@example.com.
If after review Health Canada deems a novel food to be safe for consumption, a letter of no-objection is issued notifying the petitioner to that effect.
Health Canada may require, for those novel foods that result in a health or safety change or a significant change in nutrition or composition, a declaration on the label that details the manner in which the novel food differs from its non-modified counterpart. This applies to any novel food, including products of genetic modification. This statement then becomes mandatory on the label of the novel food.
For additional information including the safety assessment process and regulation of novel foods, lists of recent Health Canada approvals of novel foods, and other resources, consult Health Canada's webpage on Novel foods.
Voluntary labelling and advertising of foods that are and are not products of genetic engineering
In Canada, voluntary claims on foods that are and are not products of genetic engineering may be made provided such claims are truthful and not misleading, as outlined in the Overview section.
The National standard of Canada for Voluntary labelling and advertising of foods that are and are not products of genetic engineering (Standard), developed by the Canadian General Standards Board, provides criteria for making voluntary labelling and advertising claims that identify foods sold in Canada that are or are not products of genetic engineering. It includes detailed information including criteria for claims on both single and multi-ingredient foods, verification, and examples of claims. It provides guidance on the appropriate use of the terms such as "genetically engineered" and "product of genetic engineering".
For more information on genetically engineered foods, please see the Labelling of genetically engineered foods in Canada factsheet.
Kosher, which means "fit" or "proper", describes foods and practices that are specifically permitted by Jewish dietary laws. Certification that a food is processed in accordance with the requirements of the Kashruth is made by a Rabbi or Rabbinical organization and identified by the appropriate Rabbi or Rabbinical organization symbol.
In the labelling, packaging and advertising of a food, the FDR prohibit the use of the word "kosher" or any letter of the Hebrew alphabet, or any other word, expression, depiction, sign, symbol, mark, device or other representation that indicates or that is likely to create an impression that the food is kosher, if the food does not meet the requirements of the Kashruth applicable to it [B.01.049, FDR].
The terms "kosher style", "kind of kosher", and other similar terms are considered to create an impression that the food is kosher, and therefore, the food must meet the requirements of the Kashruth in order for these terms to be used. The terms "Jewish-style food" or "Jewish cuisine" are not necessarily considered to create the impression that the food is kosher.
In the labelling, packaging or advertising of a food, the FDR prohibit the use of the word "halal" or any letters of the Arabic alphabet, or any other word, expression, depiction, sign, symbol, mark, device or other representation that indicates or that is likely to create an impression that the food is halal, unless the name of the person or body that has certified the food as halal is indicated on the label, package, or in the advertisement for that food [B.01.050, FDR].
The name of the certifying body or person is required where the claim is being made, whether that is on the label or the package or in the advertisement. Having the name of the certifying body or person on one of these elements does not preclude it from being required to appear on the other elements when a halal claim is made.
Acronyms and some company logos may not be easily recognizable to all consumers. Therefore, the complete name of the person or body that certified the food as halal must be present.
There are no specific requirements on the proximity of a halal claim and the name of the person or body that certified the food to one another.
The intent of the requirement is to provide additional information to consumers so as to enable them to make informed decisions about the food they purchase. Like all claims, halal claims must be truthful and not misleading.
Homemade, artisan made
The term "homemade" describes a food that is not commercially prepared. "Homemade" foods do not require further preparation. The use of a brand name or trademark symbol in conjunction with the term "homemade" is considered misleading if the food is prepared in a commercial establishment, including small, artisan like establishments.
The terms "homemade style", "home-style", "like homemade" may be used to describe a food that may contain mixes, in whole or in part, from commercial or private recipes. In advertising, these terms are potentially misleading when the food is portrayed in a home setting.
When a food is prepared in the style of a "homemade" food, the term must be qualified (for example, "homemade" baked beans versus "homemade style" canned baked beans).
The claim "tastes like homemade" is left to the judgment of the consumer and is, therefore, acceptable.
The claim "artisan made" describes products that are manufactured in small batches. The claim "artisan made" is not specific for a particular type of food, rather it is a manufacturing method that would be considered traditional and rudimentary, involving a significant portion of manual labour and a limited use of automated machines performing functions on mass quantities of food, as compared to similar products. The use of additives and preservatives that would typically be purchased from a grocery store and found in a common household kitchen such as vinegar, salt, sugar, lemon juice would be acceptable. The process of heat treatment and sterilization would be accepted for food safety purposes.
The claim "artisan-style" may be used to describe a food prepared in the style of an "artisan" food. In this case, it is a best practice to qualify the claim "artisan-style" to describe how it is different from an "artisan" food.
Method of production claims for meat, poultry and fish products
Claims about how meat, poultry and fish were raised or fed are voluntary. However, when used on a food label or advertisement, the guidance outlined below is intended to assist with industry compliance and consumer protection.
Meat, poultry and fish products may bear the claim "natural" if they use the same criteria as all foods. Refer to Nature, natural for more information on the criteria for making a natural claim.
Given that the definition of "natural" is not based on raising practices, the claim "naturally raised" may be used as long as further explanation of what is meant by the claim appears along with the claim on the label, to avoid misleading the consumers.
Other, more specific claims that convey information on the methods used to raise a particular animal may be used, as long as they are truthful and not misleading.
The following criteria support several different feed claims and their variations.
"Fed no" or "raised without" and
- animal products
- animal by-products
- animal fat
- animal meal, and/or
- bone meal
The above claims may only appear on meat, poultry, or fish products that were raised on feed that is free of ingredients or components of ingredients of animal origin (including animal products and animal by-products). This criteria applies to:
- non-nutritive feed additives
- supplemental sources of minerals and vitamins that contain animal products, such as
- vitamins and minerals which are encapsulated in gelatin of animal origin
- vitamin D3 derived from the lanolin of sheep wool
Each of these claims may be used provided they are accurate, truthful and not misleading. For example, a meat product labelled "fed no bone meal" may be acceptable when the animal feed is free of all ingredients or components of animal origin.
An exception to the above is that for ruminants, until a legally approved non-animal source of vitamin D3 is available in Canada for use in feed, a meat product of these species fed vitamin D3 derived from lanolin of sheep's wool may bear these claims (for example, "fed no animal by-products"), as long as a statement is added to inform the consumer of the source of vitamin D3.
Some animal feed is manufactured with bakery and snack food waste that contains animal products as well as animal by-products. If this type of feed is used, the resulting meat products may not be labelled or advertised with these claims.
The milk fed to an animal is not taken into consideration when evaluating these claims for the absence of animal products and animal by-products in the animal's diet.
This claim may be used when a minimum percentage of the feed is made up of grains and grain by-products calculated over the animal's entire life cycle. The minimum percentages of grain content are as follows:
- feed for beef and other sources of red meat: 75%
- feed for turkey: 80%
- feed for chicken: 85%
The remaining portion of the feed may contain other feed ingredients, regardless of origin. Examples include:
- antioxidants (for preservation)
- fish meal (as a source of omega-3 or omega-6)
- enzyme supplements
- pellet binders
- anti-caking agents (to help with milling and pelleting)
- flavouring agents
- other non-nutritive feed additives
Note that the species-specific percentages are based on attainable levels of grain in feed. Because of nutritional needs, most animals are not fed diets made only of grains. Other ingredients are an important part of the feed, required to make it nutritionally balanced.
"Grain fed" and
- no animal products
- no animal by-products
- no animal fat
- no animal meal, and/or
- no bone meal
These claims are a combination of the criteria for the claims in sections A and B, mentioned above.
For example, "grain fed, no animal meal" or "grain fed, no bone meal or animal fat" may be acceptable if the feed:
- uses the criteria for "grain fed" (section B), and
- is free of ingredients or components of ingredients of animal origin (section A).
Note the exception made for ruminants meat products that may bear claims referred to in section A, as long as the clarifying statement is added.
Please refer to sections A and B for complete details.
"Raised without the use of antibiotics" claims
To display the claim "raised without the use of antibiotics," in relation to a meat, poultry or fish product, the animal may not have been treated with antibiotics, administered by any method, from birth to slaughter or harvest.
This includes administration through:
- local application, or
- injection to embryos and eggs
In addition, antibiotics may not be given to the lactating mother of the animal in question in any manner that would result in antibiotic residue in the animal.
In the event that antimicrobial agents are given for the purpose of having an antimicrobial effect, the claim may not be consistent with subsection 5(1) of the FDA and subsection 6(1) of the SFCA.
Meat, poultry and fish products are not considered eligible to make the claim "raised without the use of antibiotics" if the animals were raised with arsenicals or substances that fall into the 4 categories of antimicrobial drugs listed in Health Canada's antimicrobial categorization document. Examples include:
- aminoglycosides, such as gentamicin and neomycin
- beta-lactams including penicillins and cephalosporins, such as amoxicillin and ceftiofur
- fluoroquinolones, such as enrofloxacin and danoflaxacin
- ionophoresFootnote 1, such as monensin
- macrolides, such as tylosin
- streptogramins, such as virginiamycin
However, meat, poultry and fish products may claim "raised without the use of antibiotics" if the animals were raised with the following veterinary drugs or biological products (the list is not exhaustive):
- chemical coccidiostats, such as amprolium and decoquinate
- direct-fed microbial products registered with the CFIA as feed ingredients
Additionally, in order for the claim to be used, vitamins and minerals given to the animals may only be given at the level of physiological action for dietary supplement, not for antimicrobial effect.
A claim such as "fed no antibiotics" may imply that the animal was raised without the use of antibiotics in cases where the animal has received antibiotics through injection or spraying. If such a claim is applied, the criteria for the claim "raised without the use of antibiotics" may be used to avoid misleading information.
"Raised without the use of added hormones" claims
Meat, poultry and fish products may carry the claim "raised without the use of added hormones" on the label or advertising as long as no hormones or β-agonists, such as ractopamine, were administered in any way to the animal. In addition, hormones may not be administered to the lactating mother of the animal in question in any manner which would result in increased hormone levels in the animal. However, consumers may not be aware that the use of hormones is only permitted with certain animals.
- In cases where the use of hormones is legally authorized and none were used, the products may claim "raised without the use of added hormones."
- In cases where the use of hormones is prohibited or not authorized, the claim "raised without the use of added hormones" may be considered misleading as it creates false uniqueness between similar products. This misleading impression may be avoided by applying an additional statement, such as "like other (naming the product or source animal)".
For example, since the use of hormones is not authorized in Canada for chickens, the use of the claim "raised without the use of added hormones" on chicken products could imply that other chickens may have been raised using hormones. A claim such as "like other chickens, this chicken was raised without the use of added hormones" may be used.
The claim "hormone free" used without any other information could create the impression that the animal product in question does not contain hormones. As meat, poultry and fish products contain naturally occurring hormones, the claim "hormone free" is not considered acceptable.
The claim "no growth stimulants" may also be misleading for consumers and be inconsistent with the relevant legislation on truthful and accurate labelling. Due to a broad and diverse understanding of the term "growth stimulant," the simple statement "no growth stimulants" could mean the absence of a number of substances (such as hormones, β-agonists or low dose of antibiotics) and the presence of others (such as vitamins and minerals).
Method of production claims for fresh fruits and vegetables
Genetic engineering claims
Claims that a fresh fruit or vegetable is or is not a product of genetic engineering may be made if it meets certain criteria. Refer to Voluntary labelling and advertising of foods that are and are not products of genetic engineering for more information.
"Free of pesticides residues" claims
The use of the claim "free of pesticides residues" on fresh fruits and vegetables may be considered misleading and is subject to subsection 5(1) of the FDA and subsection 6(1) of the SFCA. These legislations prohibit claims that may create an erroneous impression regarding the character, value, quantity, composition, merit or safety of the product.
Growing practices (soil, hydroponic or greenhouse) for fruits and vegetables may involve direct, indirect use of or exposure to pesticide or pest control product. For example, fresh produce may be exposed to residue of pesticides present in soil and/or water from background contamination, chemical drift or runoffs. Considering the possibility that pesticides can remain or move in the environment before crop emergence, claim such as "free of pesticide residues" may be considered misleading.
It is the responsibility of the regulated party to demonstrate that their product is free of pesticides residues when such claims are made.
Annex 1 – Minimum processes
Examples of processes affecting the natural character of foods with a minimum of physical, chemical or biological changes
- Agglomeration (without chemical change or addition)
- Chilling (including refrigerating and freezing)
- CleaningFootnote 2
- Concentration (without chemical change)
- Deboning (manual)
- Defatting (without chemical change)
- Drying, dehydration, desiccation, evaporation, freeze-drying
- Emulsifying (without synthetic chemical addition)
- FermentationFootnote 2
- FilteringFootnote 2 and clarifying
- Fining, finishing (without chemical change)
- Flocculation (without chemical addition)
- Heating (including baking, blanching, boiling, canning, cooking, frying, microwaving, pasteurizing, sterilizing, parboiling, roasting)
- MaturationFootnote 2 (without chemical addition)
- Melting, thawing
- Mixing, blending
- Packaging, canning
- Peeling (without chemical change)
- Reconstitution (without chemical addition)
- RipeningFootnote 2 (other than by chemical means)
- Separating (including screening, clarifying, centrifugation, decanting, extraction, filtering, shelling, trimming)
- Smoking (without direct chemical addition)
- Treatment with inert gases (nitrogen pack)
- Treatment with toxic gases (with no chemical change)
Annex 2 – Maximum processes
Examples of processes affecting the natural character of foods with a maximum of physical, chemical or biological changes
- Anion exchange
- Bleaching (with chemical addition)
- Cation exchange
- Conversion (with chemical addition or synthesis)
- Curing (with chemical addition)
- Deboning (mechanical)
- Decaffeination (with chemical addition)
- Denaturation (with chemical change)
- Enzymolysis (with chemical addition)
- Hormonal action
- Hydrolysis (with chemical addition)
- Oxidation (with chemical addition)
- Reduction (with chemical addition)
- Smoking (with chemical addition)
- Synthesis (chemical)
- Tenderizing (with chemical addition)
Labelling of genetically engineered foods in Canada
Fact sheet - Labelling of genetically engineered foods in Canada
Animal by-product includes blood or any of its components, bones, bristles, feathers, flesh, hair, hides, hoofs, horns, offal, skins and wool, and anything containing any of those things [2(1), Health of Animals Act].
Animal product includes cream, eggs, milk, non-fertilized ova and semen [2(1), Health of Animals Act].
Antibiotic is any drug or combination of drugs such as those named in C.01.410 to C.01.592 which is prepared from certain micro-organisms, or which formerly was prepared from micro-organisms but is now made synthetically and which possesses inhibitory action on the growth of other micro-organisms [C.01.001(1), FDR].
Antimicrobial agent means a naturally occurring, semi-synthetic or synthetic substance that exhibits antimicrobial activity (kills or inhibits the growth of micro-organisms) at concentrations attainable in vivo. Anthelmintics and substances classed as disinfectants or antiseptics are excluded from this definition. (WOAH: World Organisation for Animal Health (founded as Office International des Épizooties (OIE)))Footnote 3
For the purpose of a grain fed claim, grain includes barley, beans, buckwheat, canola, chick peas, corn, fababeans, flaxseed, lentils, mixed grain, mustard seed, oats, peas, rapeseed, rye, safflower seed, soybeans, sunflower seed, triticale and wheat [Canada Grains Act and Canada Grain Regulations].
Prepare, in respect of a food commodity, includes to process, treat, preserve, handle, test, grade, code or slaughter it or to do any other activity in respect of it that is prescribed [2, SFCA].
The growing and harvesting of any fresh fruits or vegetables are also included under this definition [3, SFCR].
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