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Operational procedure: Basic food label verification

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1.0 Purpose

The purpose of this document is to provide guidance to Canadian Food Inspection Agency (CFIA) inspection staff on standard commodity inspection procedures related to a basic food label verification, in order to ensure that all mandatory information is present, appears accurate and is declared according to Canadian regulatory requirements.

The procedure outlined below may be used when verifying compliance of a food label and advertisement, to support export certification, to aid in the assessment of a Preventive Control (PC) related sub-element, or as part of a food safety investigation or follow-up to a complaint.

This guidance is written with the assumption that inspection staff have been trained in the Standard Inspection Process (SIP) and in the basic labelling requirements.

This document is intended to be used in conjunction with other guidance documents as referenced in Section 3.0 of this document.

2.0 Authorities

The inspection powers, control actions and enforcement actions authorized by the above legislation are identified and explained in the Operational guideline – Food regulatory response guidelines.

3.0 Reference documents

4.0 Definitions

Definitions are located in the documents listed below or as a defined word where it is intended to supersede the definitions within the glossary documents:

5.0 Acronyms

Acronyms are spelled out the first time they are used and are consolidated in the Food business line acronyms list.

6.0 Operational procedure

This operational guideline provides inspection procedures specific to a basic food label verification. A basic food label verification is an inspection task performed by the inspector to verify that all mandatory information is present, that all information is accurate and declared according to regulatory requirements.

Where more specific procedures are required to what is provided in the standard inspection process (SIP), these will be indicated in this section.

Commodity inspection operational guidance (OG) refers the inspector to the SIP for basic guidance on the four inspection steps. If the commodity inspection is being conducted to support a preventive control inspection currently underway, some or parts of the inspection steps will have already been completed.

6.1 Prepare for inspection

Refer to SIP, section 3, step 1. Only supplementary information (if any) unique to the inspection is included below.

Table 1. Recording inspection data in the Digital Service Delivery Platform (DSDP)
DSDP Trigger Preventive Control Inspection Plan
Sample Collection Plan
Commodity Inspection Plan
Incident Response
Domestic Permission
Export Permission
Import Permission
DSDP Inspection task type Commodity inspection
DSDP Inspection level 1 task Inspect Commodity
DSDP Inspection level 2 task Basic Label Verification

6.2 Conduct the inspection

Refer to SIP, section 4, step 2. Only supplementary information (if any) unique to the inspection task is included below.

6.2.1 Do a preliminary label and advertisement verification

Determine which regulatory requirements apply for the specific product. In particular, confirm:

Inspection staff can use the labelling requirements checklist available in the Industry Labelling Tool (ILT) as a guide when conducting a label or advertisement verification. Please note that this checklist is not all inclusive of the regulatory requirements for verification of a label or advertisement.

6.2.2 Verify mandatory label requirement

  1. Using the information found in the Core Labelling Requirements section of the ILT, verify that the label contains the mandatory labelling information that must appear on the label of the prepackaged or consumer prepackaged food. Mandatory labelling information includes:
  2. If any of the mandatory labelling information is missing, verify the conditions that may exist that exempt the food from requiring some label information
  3. Using the information found in the Food Specific Labelling Requirements section of the ILT, verify that the label also contains additional mandatory requirements, such as, standard container size, inspection legend, grade declaration as applicable for the specific commodity being inspected

6.2.3 Verify the legibility, location of information and bilingual requirement

Using the information in the Legibility and Location section of the ILT, verify that the mandatory information on the label is:

  1. clearly and prominently displayed
  2. readily discernible to the purchaser or consumer under the customary conditions of purchase and use, and
  3. in both official languages, that is, French and English (some exemptions may apply – refer to Bilingual Labelling section of the ILT)

6.2.4 Verify additional or voluntary information

Information that is provided voluntarily on food labels or in advertisements is often referred to as a claim. Voluntary information includes information presented in written or pictorial form on the label or in advertising.

  1. Verify that all claims on the label are truthful, not misleading nor likely to create an erroneous impression, and that they are in compliance with any specific requirements that exist for a given type of claim
  2. For specific claims, such as those relating to nutrient content, organic, kosher, halal and certain disease-risk reduction claims, refer to the Claims and Statements section of the ILT
  3. For many claims that are not subject to specific regulatory requirements, consult the General Principles for Labelling and Advertising page in the ILT to assist in assessing the compliance of the claims with subsections 5(1) of the FDA and 6(1) SFCA

6.2.5 Categorize non-compliance

A further in-depth review may be required and additional level 2 commodity inspection tasks may be included (for example: ingredient verification, net quantity verification, etc.). If a non-compliance is identified related to food labelling and advertising, consult the Operational Guideline: Guidelines on categorizing labelling and advertising non-compliance and timeframes for correction (accessible only on the Government of Canada network – RDIMS 9912657).

Consult the Operational guideline: food regulatory response guidelines if any product action is deemed necessary (for example: seizure and detention) and SIP section 4.5 to determine if immediate control action is required.

6.2.6 Capturing notes related to commodity inspection in DSDP

For information on capturing notes relating to commodity inspections in the DSDP, refer to Appendix A section 5.4.1 of the SIP and section 3.5.1 of the DSDP SOP INS – conducting an inspection (accessible only on the Government of Canada network – RDIMS 9839405).

In addition to capturing an accurate description (brand name, common name, net quantity, lot number) of the commodity inspected in the "Commodity Description'' field in DSDP, enter the same commodity description in the "objective evidence'' field along with the non-compliances found so that it appears in the final inspection report.

Save a copy of the assessed label and the labelling requirements checklist, if used to conduct the label verification, in RDIMS and reference the RDIMS number in the "documents" field of DSDP.

6.3 Communicate the results

Refer to SIP, section 5, step 3.

6.4 Conduct follow-up

Refer to SIP, section 6, step 4.

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