Available display surface (ADS)

Calculating the available display surface

In general, the Nutrition Facts table must be displayed on the available display surface (ADS) (definition) of a package. This is defined as the total surface area of a package which is physically available for labelling. It includes all unlabelled surfaces on which information can be legibly set out and easily viewed. Also included is any surface that has any printing, designs or graphics already printed on it, whether mandatory, optional or promotional (other than the area occupied by the Universal Product Code (UPC) – see Elements not included as part of the available display surface). For example, any label surface containing any printed information, such as a list of ingredients, a name and address of a manufacturer, a brand name, graphics, claims, promotional information, recipes, etc., is considered part of the ADS.

The ADS is usually determined by numerical calculation. The calculation of the ADS is a pivotal concept in the application of the nutrition labelling requirements, because the choice of a Nutrition Facts table format and its size are based, in part, on the ADS of the package.

Ornamental containers

As per the Food and Drug Regulations, "ornamental container" means a container that, except on the bottom, does not have any promotional or advertising material thereon, other than a trade mark or common name and that, because of any design appearing on its surface or because of its shape or texture, appears to be a decorative ornament and is sold as a decorative ornament in addition to being sold as the container of a product; (emballage décoratif) [B.01.001(1), FDR].

Ornamental containers have the potential for an extended life, as they are reusable. Ornamental containers must be substantial enough to be sold on their own merit (i.e., without the food). They are usually made of metal (e.g., cookie tins), plastic or glass (e.g., candy-filled figurines).

The container on the left is an ornamental container. The container on the right is no longer considered an ornamental container as it has a label affixed to the top of the container.

Decorative containers

Decorative containers, although aesthetically pleasing, are usually not reusable (as opposed to ornamental containers) because they are not sturdy enough and often get torn or damaged upon opening. Fabric-covered or embossed cardboard boxes for chocolates (e.g., for Valentine's Day) are normally considered decorative container. There are no special exemptions for measuring the ADS of decorative containers.

Available display surface for tags

The Nutrition Facts table may alternatively be presented on a tag attached to a package in the following situations:

• when none of the versions of the Nutrition Facts table fits within 15% of the available display surface
• when none of the versions of the Nutrition Facts table will fit on a continuous surface (i.e., when a label cannot be physically applied or on which information cannot be legibly set out and easily viewed by the purchaser or consumer under the customary conditions of purchase); or
• when the container is ornamental.

The total area of both sides of a tag attached to a package to which a label cannot be physically applied is considered ADS. The ADS does not include the area occupied by the Universal Product Code (UPC) symbol.

The Nutrition Facts table may appear on either side of a tag and any version (size) of a suitable format may be used. For the appropriate formats of Nutrition Facts tables on a tag, please see Alternate methods of presentation section under Nutrition Facts table formats. A toll-free telephone number is not an acceptable method of presenting a Nutrition Facts table on a tag.

Some examples of foods which might be labelled with a tag include ornamental bottles, whole frozen turkeys, waxed-encased small cheeses in a mesh bag; and foil-wrapped milk chocolate Easter eggs in a mesh bags.

The small package <100 cm²  exemption (ADS < 100 cm²) does not apply to tags.

Guidance on measuring ADS

Determining the ADS for packaging with geometric forms

Many packages are in standard shapes for which the areas can be calculated using mathematical formulas. These formulas are available in the section Mathematical calculations for the area of some geometric forms.

Determining the ADS for uniform bottles and jars

There is a proliferation of bottle and jar shapes and sizes in the market place. For the purposes of determining ADS, a uniform shaped jar or bottle (e.g., stubby form, not long necked) is a jar or bottle that is straight from the base to the beginning of the neck. The ADS of these jars and bottles consists of the sides of the jars or bottles and their lids.

Determining the ADS for non-uniform bottles and jars, sold by volume

Measurement of the ADS on irregular shaped bottles and jars is difficult, leading to inconsistent results. Consequently, Health Canada and the Canadian Food Inspection Agency (CFIA) developed a fair and consistent alternative method of estimating the ADS of these containers. This option uses the declared net quantity of products sold by volume, and the actual volume of products sold by weight, to estimate an approximate ADS for non-uniform bottles and jars.

The ADS by volume method of calculating ADS is an alternative option to measuring the ADS of non-uniform bottles and jars. The CFIA plans to use this method of estimating the ADS on non-uniform bottles and jars in carrying out its inspection activities. When determining the ADS of irregular shaped containers, industry has the choice of either using this alternative ADS by volume method or measuring the container as prescribed in the regulations. If the second option is chosen, all packaging technology available must be taken into consideration when measuring the area of a container where a label may be physically applied, such as shrink wrapping and plastic and paper labels that may be affixed to irregular shapes, not just the current packaging technology in use by a company.

The following rule applies to all non-uniform glass and plastic bottles and all non-uniform shaped jars sold by volume.

ADS = Calculation based on the declared volume

To calculate the ADS of a non-uniform bottle or jar, use the following formula.

Volume of container	ADS
≤ 149 ml	< 100 cm2 (small package exemption)
150 ml - 250 ml	100 cm2 (requires NFt) May choose one of the Nutrition Fact tables in the lowest level of options in the Hierarchy of Formats, i.e., the smaller Nutrition Fact tables. See Nutrition Facts table formats section.
> 250 ml

Determining the ADS on non-uniform bottles and jars, sold by weight

Since the density of different products may vary, the volumes of different products of the same weight may also vary. For example, a 450 g jar of coffee whitener is almost the same size as a 100 g jar of artificial sweetener. Consequently, the volume of the container should be determined and the formula for non-uniform bottles and jars should be applied.

ADS = Calculation based on the measured volume of the container

How to determine the ADS of a non-uniform bottle or jar sold by weight:

1. Starting with an empty container, fill the container with water to 1 cm below the rim.
2. Empty water into a graduated container (e.g., measuring cup or graduated cylinder), and measure in milliliters.
3. Apply the formula for "Bottles and Jars – Non-Uniform, Sold by Volume". (See preceding section.)

Elements not included as part of the available display surface

Areas destroyed upon opening

Any part of the package that is destroyed upon opening (e.g., a tear strip, a band straddling a bottle cap and bottle neck, a single label made up of several lids on a multi-pack of individual yogurt-type containers where each unit is snapped off, destroying the Nutrition Facts table, etc.) is not considered part of the ADS, unless the product is in a non-reusable container or single-serving package (i.e., the entire contents can be reasonably expected to be eaten by one person during a single eating occasion).

Bag closures

Bag closures such as zip locks, cut lines, or heat seals and the area past these closures (i.e., area often cut off when opening the package) are not considered ADS.

Curves

Acute curves on rigid packaging are not considered ADS.

Eye spot

Certain packaging processes use an electronic eye to cut packaging material to the correct length. An "eye spot", usually a dark oblong spot, is printed onto the continuous film of labelling material to trigger the cutting process. On the final package the eye spot is usually present on the seams. The area that incorporates the width of the eye spot and whole length of package is not considered ADS, unless the area is already labelled.

Gabled ends

Gabled ends of packaging, such as those found on milk cartons and on cookie bags, are not considered ADS unless label information (mandatory or non-mandatory) appears in these areas.

Gathered ends of packaging material

Packaging material that is gathered, making any written material impossible to read (e.g. the end of a bread bag, gathered ends of a tube of cookie dough or gathered ends of a prepackaged tube of ground beef) is not considered ADS.

If this area is covered by a flat sticker, then the whole area is considered ADS. Note that ADS includes the whole area, even if the sticker is small. Examples include the end of a roll of biscuits or cookies and the back of a round of cheese packaged in a paper overwrap.

• The NFt should not be placed in gathered areas where printing is not legible at time of sale.

Labelling information on non-ADS surfaces

This may include areas of the package where a label cannot be physically applied or where information cannot be legibly set out or viewed or the bottom of a package if the product would be damaged or leak if turned upside down to view the NFt. However, if labelling information exists on these surfaces (other than the UPC symbol or coding information, public service announcements (e.g., Kids Phone), recycle instructions, or opening instructions), then these areas become ADS.

For example, normally the bottom of a pie container is not considered to be part of the ADS. However, if an NFt is placed on the bottom of the container, the entire bottom of the product becomes ADS.

Lids on jars and tubs

Lids are generally considered ADS. However, raised areas and ridges that interfere with labelling are excluded from ADS. Sides less than 10 mm wide, sides with spirals or grooves, and very small lids are also excluded if no print information is in this area. In some cases, very small caps of bottles are considered very small areas of continuous surface and, consequently, not ADS.

Paper labels on the inside of clear packages

When paper labels are on the inside of a clear packaging material, then the ADS includes the area occupied by the paper label, as well as the rest of the same label panel that is not occupied by the paper label. There is no consideration for minor ridges and uneven surfacing of these panels. Other panels that do not have inner paper labels are calculated as though they did have an inner paper label.

For example, in the case of a clear plastic egg carton with a paper label on the inside of the top of the carton, the entire top and sides of the lid are considered ADS. However, since it would be almost impossible to place an inner paper label in the bottom cups, the bottom half of the egg carton is not considered ADS.

Ridges in packaging material

Ridges in the packaging that make it impossible to affix a label or to print on the ridged sections are not considered ADS.

UPC symbol

Usually the UPC (Universal Product Code or bar code) symbol is not considered ADS and must not be included in the calculations for the ADS [B.01.001(1), FDR]. However, if the UPC is present on the label more than once, the area occupied by the additional UPCs would be included in the ADS calculation.

Since the UPC symbol is a machine-readable bar code, the definition between lines must be significant enough for the machine to register. As a result, the size of the UPC symbol may vary depending on the precision of the printing process. Some printing processes and packaging materials cause ink to spread. Consequently, on some packaging the UPC symbol may be 200 % larger, or more, than the standard size.

When the UPC is enclosed in a box, the entire box is excluded from ADS. When the UPC is not enclosed in a box, only the area covered by the actual UPC is deducted from the ADS. The area of the UPC includes the outer characters.

Very small areas of "continuous surface"

Any "continuous surface (definition)" of 12 cm² or less (e.g., bottle caps, lids, folded triangles on package surfaces) which is too small to accommodate even the smallest available Nutrition Facts table is not included in the ADS, provided that this continuous surface does not already have printed mandatory, optional or promotional labelling on it.

Windows and transparent packaging

Flexible or rigid transparent packaging materials, such as those found on bacon packages or covering windows in pie and candy boxes, are considered ADS. However, if the window is open with no inner covering, then the empty window is not considered ADS.

Reference information

Mathematical calculations for the area of some geometric forms

Image	Mathematical calculations
	Rectangle: Area = length(L) x width(W)
	Parallelogram: Area = base (B) x height (H)
	Triangle:
	Trapezoid:
	Circle: Area =∏r2
	Cylinder (can): Area of top and bottom = 2(∏r2) Area of sides = 2∏rh or height of can x circumference Note: Only the sides of a regular tin can are considered ADS. There are exceptions for cans with plastic lids or cans that are labelled on the top and/or bottom of can.
	Sphere: Area = 4∏r2
	Cone: Total Area = Area of cone + Area of base Area of cone = ∏rs Area of base = ∏r2
	Pyramid with a square base (4 sides):  Total Area = Area of 4 triangles + Area of base Area of base = b2
	Box: Total Area = (front and back) + (top and bottom) + (2 sides) = 2(Ll + Lh + hl)
	Prism Total Area = ends (2 triangles) + sides (2 rectangles) + base Area of sides (2 rectangles) = Ll x 2 Area of base (1 rectangle) = Lb
	Sides of Conical Frustum (e.g. sides of plastic yogurt tub): Area of sides = ∏[R1+R2] S R1 = large radius R2 = small radius S=slant

Calculation methods for different packaging types

Bacon packages

The space equivalent to the length of the package by the width of a strip of bacon, that allows the customer to see the bacon, is excluded in the calculation of the ADS no matter what the size of the window is.

On this package of bacon, a transparent area the width of one bacon slice is provided on the back of the package, allowing the consumer to evaluate the lean/fat composition of the bacon. This area is not included in ADS.

In this package, the bacon is placed in such a way that the consumer may evaluate the fat/lean composition of the bacon from the front window of the package. Nevertheless, the area equivalent to the width of one bacon slice by the whole length of the package is still excluded from the ADS calculation.

Bags – Flat, back central seam

Bags with gathered ends

Sides: Side areas are measured from crust to crust in the case of bread bags, or from the end of the bag to where the gathering starts and obstructs reading of printed material.

End: ADS includes the whole end of the bag.

Bags – Cookie

Bottom: ADS does not include the seam and smaller bottom panel. The typical cookie bag is constructed in such a manner that the smaller bottom panel is very narrow. Very small continuous surfaces are not considered ADS.

Bags – Flat pouch without gussets

A gusset is a folded or pleated inset area at the bottom or sides of a bag.

Bags – Stand-up pouch with inset gusset

The bottom of this large stand-up pouch would be considered ADS as it presents a large flat surface when the bag has been filled.

The bottom of this small stand-up pouch would not be considered ADS as the area is very small and the gusset retains its inset pleated shape when the package is full.

Bags – Stand-up pouch with flat bottom

Baked goods – Fresh, not packaged at retail: rigid plastic containers

e.g., "clam shells"

Baked goods are generally fragile and many will be damaged if turned upside down to view labelling information on the bottom of the container. When evaluating whether the bottom of the container should be considered as ADS, it should be taken into consideration that the product may be handled by many consumers and repeatedly turned upside down before purchase.

Top: ADS includes the area that can support a label, e.g., raised panels.

Sides: The tightly repeated ridging on the sides of plastic containers will usually support a paper label.

Bars – Foil wrapped or wrapped in similar material

These bars are usually wrapped in foil or similar packaging material, with end and central seams.

Manufacturers often use the flap to provide labelling information. When labelling information is present, this area is considered part of the ADS. In some cases, one side of the central seam/flap contains printed information while the other side has the eye spot. The seam side with printed information is considered ADS, while the other side is not.

Bars – Paper label over foil wrap

Bottles and jars – Regular cylindrical glass and plastic

Bottles and jars – Non-uniform, sold by volume; glass and plastic

Cans – Metal cans with paper labels

ADS includes the area of the sides of a can but does not include the top or bottom of the can unless the top or bottom has been labelled with information other than coding or the UPC symbol. In these cases, the area with labelling information is also included in the calculation of ADS.

Cans – Flat with print directly on can

Areas with keys make the space unavailable for labelling.

Cans – Cardboard or metal with plastic lid

Cardboard cartons – Milk, cream or juice

The bottom of the carton is not included in the ADS for a number of reasons. Milk and cream cartons are delivered flat to the dairy. The top and bottom seams are formed and heat-sealed during the filling process. The bottom is an area where many seams come together and is consequently bumpy, which is not conducive to clear labelling.

Catch weight meat products of similar size and form

These products are individually shrink wrapped. In some cases the label is printed directly on the packaging material, while in other cases paper labels are applied.   These products are similar but not uniform in size and shape. This does not apply to products that are highly variable in size such as frozen turkeys.

Egg cartons

For egg cartons (flat top cartons made of pulp, foam or clear plastic), the NFt may be printed on the inside of the lid. There is no requirement for the producer to indicate on the outer surface that the NFt appears on the inside of the carton. When the inside of the lid contains any written material, mandatory or promotional, the inside of the lid is considered part of the ADS calculation.

Frozen foods – Foil container, plastic or cardboard lid

A foil container is excluded from the ADS calculation because a paper label will not adhere to the foil due to the condensation in the frozen environment.

Frozen foods – Foil container, plastic or cardboard lid and overwrap

If the UPC is located on a non-ADS surface (i.e., foil container), the area of the UPC is not subtracted in the ADS calculation.

Multi-pack with dropped units (plastic cups)

Common top: The entire top of the yogurt multi-pack is considered ADS. However, it is not considered a single continuous surface, as the top is broken into smaller units as it is consumed. Each individual lid is considered a continuous surface.

Common top – Box: ADS includes both the top and sides of the box, but not the ends if the ends are absent (i.e., if the box is open ended).

Multi-pack – Transparent cellophane wrapper over fully labelled individual units

Fully prepackaged units are sometimes sold in a variety of formats. For example, single-serving units of juice in tetra pak containers may be sold individually and the same product may also be sold in multi-packs of 3, 5, or 10 units, etc.

When product is sold both individually and in multi-packs, special consideration is given to the labelling of the multi-packs with transparent outer packaging, as each individual unit is already required to be fully labelled with a NFt and is visible through the outer packaging material. Two options exist:

The NFt may appear on the outer cellophane wrapper. In this case, the ADS includes total outer package. The choice of format and version (size) of format may be based on the ADS of this surface.

The NFt may appear on the individual units providing that all mandatory information is visible at the time of purchase (including: common name, ingredients, Nutrition Facts table, dealer identification, etc.). The choice of format and version (size) of format may be based on the ADS of the individual unit.

Pillow packs

The sides of the pillow package on the left would be considered ADS as they are greater than 4 cm, while the sides of the pillow package on the right would not be included in the ADS calculation.

Tetra pak

Tetra Pak packaging is available in a number of sizes (volumes) and shapes including rectangular box shapes and octagonal box shapes.

Tubs – Printed plastic

Sides: When calculating the ADS of the sides of a plastic tub, do not include the bottom curve (if any), the ridges at the top of the tub and the area covered by the lip of the lid.

To calculate the area of the sides of a tub, use the mathematical formula for the area of a conical frustum (refer to Mathematical calculations for the area of some geometric forms).

Tubs – Plastic with paper label

Tubs – Cardboard

Lid: It is impossible to print on some of the plastics used in the construction of these lid rims. As it is difficult to determine the type of plastic used, plastic rims are not considered ADS unless printed material is present in this area. However, if the rim is constructed of cardboard, it is considered ADS.

Sides: To calculate the area of the sides of a round tub, use the mathematical formula for the area of a conical frustum (refer to Mathematical calculations for the area of some geometric forms). Include only the area visible at the time of purchase (i.e., do not include the area covered by the rim of the lid.)

Wrappers, tube shapes