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Operational procedure: Food nutrient content and claims 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 nutrient content and claims verification, in order to ensure labels meet 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, as part of a food safety investigation or follow-up to a complaint.

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 in this document and are consolidated in the Food business line acronyms list.

6.0 Operational procedure

This operational procedure provides inspection procedures specific to nutrient content and claims verification. A nutrient content and claims verification is an inspection task performed by the inspector to verify the accuracy of the Nutrition Facts table (NFt), the nutrient content claims and health claims on food labels and advertisement according to regulatory requirements.

On December 14, 2016, amendments to nutrition labelling, list of ingredients and food colour requirements of the FDR came into force. Regulated parties have until December 14, 2022 to meet the new labelling requirements. Please consult the Operational directive – Direction on compliance and enforcement activities for the amendments to the Food and Drug Regulations related to nutrition labelling, list of ingredients and food colours (accessible only on the Government of Canada network – RDIMS 11214835).

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) refer 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. In addition to the general guidance provided in SIP, the following applies.

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

6.2 Conduct the inspection

Refer to SIP, section 4, step 2. In addition to the general guidance provided in the SIP, the following applies.

6.2.1 Verification of the NFt

The NFt is mandatory for most prepackaged foods and must be presented in a certain manner when it appears on a food label [section B.01.001 and subsection B.01.401 (1) of the FDR]. Some foods are exempt from nutrition labelling, and presenting an NFt is strictly prohibited for certain other foods. Please consult the exemptions and prohibitions in the Nutrition Labelling section of the Industry Labelling Tool (ILT) for more information.

Steps for evaluating the NFt:

  1. Check whether the NFt is present (if not, verify whether it is an exempt food or if the food is intended for use in manufacturing other foods)
  2. Check whether the NFt is bilingual (if not, verify if there is an applicable exemption)
  3. Check the location and orientation criteria of the NFt
  4. Based on the format decision trees (available under the Nutrition Facts Table Formats section of the ILT), check whether the specific format and version (size) of the NFt have been correctly chosen based on the Available Display Surface (ADS) of the packaging. Select the largest version of the formats that fits within 15% of the ADS on one continuous surface. For more information on the ADS, including on calculating the ADS, refer to Available Display Surface under the Nutrition Labelling section of the ILT. Consult the page Steps for Choosing a Nutrition Facts Table under the Nutrition Labelling section of the ILT
  5. Check whether the NFt information is presented in accordance with subsections B.01.401 and B.01.402 of the FDR: serving size, mandatory nutrients, supplementary information, units (g, mg, %DV), terminology, etc
  6. Check whether the nutrient values have been rounded in accordance with the FDR (column 4 of the table following section B.01.401 and of the table following section B.01.402 of the FDR)
  7. Check whether the prescribed technical and graphic criteria have been respected, for example, spacing, font, font size, indents, colours, using the nutrition labelling rules. Consult the page Graphic and Technical Requirements within the Nutrition Facts Table under the Nutrition Labelling section of the ILT for a summary of technical and graphic requirements

Where there is a doubt on values in the NFt, ask the licence holder for supporting documents and/or analysis done on the product. If the regulated party is not a licence holder and does not have supporting documents, you may choose to sample the product and use the Nutrition Labelling Compliance Test to evaluate the accuracy of nutritional data on food. Please refer to the Operational guideline: Food sample collection and the appropriate sampling plan on the web page CFIA sampling information (accessible only on the Government of Canada network).

6.2.2 Claims

Take into consideration the overall impression created by the logos, symbols, graphics, slogans, trademarks, brand names etc. in conjunction with the claim wording.

There are several types of claims. Those that link to the nutrients in a food are listed below.

6.2.2.1 Nutrient content claims

Nutrient content claims are statements or expressions which describe, directly or indirectly, the level of a nutrient or energy in a food or a group of foods, such as "low in sodium", "source of fibre" and "source of energy." The list of permitted nutrient content claims can be found in the table following section B.01.513 of the FDR.

Follow the steps listed on the Steps for making a nutrient content claim page under the Nutrient Content Claims section of the ILT to verify whether the claim is permitted and meets the requirements of the FDR.

It is also permitted to make quantitative declarations about the energy or nutrient values per serving indicated outside the NFt, on labels or in advertising [B.01.301, FDR]. More information about this is available on the page Quantitative declarations outside the Nutrition Facts table under the Nutrient Content Claims section of the ILT.

6.2.2.2 Health claims

A health claim is any representation in labelling or advertising that states, suggests, or implies that a relationship exists between the consumption of a food and health.

Follow the steps listed on the page Steps for determining the type of health claim in the Health Claims section of the ILT to determine the claim type and criteria associated with each type. The list of health claims with specific wording requirements is found in the table following section B.01.603 of the FDR. Refer to Health Canada's Health Claim Assessments page for a list of health claims submitted, reviewed and accepted.

6.2.3 Categorize non-compliance

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) and the Operational guideline: Food regulatory response guidelines.

6.2.4 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.

6.3 Communicate the results

Refer to SIP, section 5, step 3.

6.4 Conduct follow-up

Refer to SIP, section 6, step 4.

For general inquiries related to this Operational Guidance Document, please follow established communication channels, including submitting an electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network).

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