Centre for Science in the Public Interest

For the Record

CSPI Centre for Science in the Public Interest
Centre pour la science dans l’intérêt public

November 30, 2000

Mr. Allan Rock, M.P., P.C.
Minister of Health
House of Commons
Ottawa, ON K1A 0A6

Re: Mandatory Nutrition Labelling

Dear Minister Rock:

     The Centre for Science in the Public Interest (CSPI)(1) is pleased that Health Canada has decided to proceed with a mandatory nutrition labelling program for foods. Mandatory nutrition labelling will benefit consumers immensely by helping them select more healthful foods and reduce their risk of diet-related disease.

     Although we are generally supportive of the proposal, we have several suggested changes that we have attached in an appendix to this letter. We urge you to carefully consider each of them. We also encourage you to ensure that Health Canada and the Canadian Food Inspection Agency have the funds necessary to educate the public about the new labels, monitor compliance by manufacturers, and take appropriate enforcement measures when necessary.

     In contrast to our support of Health Canada's nutrition labelling proposal, we have serious objections to another Health Canada labelling proposal to allow health claims for foods. This proposal would result in misleading food labels that will not only fail to benefit consumer health, but will undermine the credibility of the entire food label. We are concerned that this industry-driven initiative will be finalized as a quid pro quo for the stronger, consumer-oriented nutrition labelling proposal. We urge you to review this proposal to ensure that it will benefit — not harm — consumers.

     If we can be of any assistance to your office in addressing these concerns, please do not hesitate to contact us at (613) 565-2140. We look forward to your reply.

Respectfully submitted,

Bill Jeffery, L.LB.
National Coordinator


cc.The Right Honourable Prime Minister Jean Chrétien, M.P., P.C.
The Honourable Paul Martin, M.P., P.C., Minister of Finance
 The Honourable Lyle Vanclief, M.P., P.C., Minister of Agriculture and Agri-food
 The Honourable Lucienne Robillard, M.P., P.C., President of the Treasury Board
 Ms. Val Merideth, M.P., Canadian Alliance Party Health Critic
 Mr. Reed Elley, M.P., Canadian Alliance Party Deputy Health Critic
 Ms. Judy Wasylycia-Leis, M.P., New Democratic Party Health Critic
 Mr. Greg Thompson, M.P., Progressive Conservative Party Health Critic
 M. Réal Ménard, député, porte-parole de Bloc Québécois en matière de Santé
 Mr. Tom Wappel, M.P.
 Mr. Svend Robinson, M.P.
 Mr. Mel Cappe, Clerk of the Privy Counsel and Secretary to the Cabinet
 Mr. Ronald L. Doering, President, Canadian Food Inspection Agency
 Ms. Eunice Chao, Project Coordinator, Nutrition Evaluation Division, Health Canada
 Ms. Melodie Wynne, Generic Claims Project, Health Canada
 Ms. Christina Zehaluk, Nutrition Evaluation Division, Health Canada
 Dr. Margaret Cheney, Nutrition Evaluation Division, Health Canada
 Ms. Mary Bush, Nutrition Evaluation Division, Health Canada



Suggested Changes to the Nutrition Labelling Proposal

1. Foods "packaged at retail" should not be exempt from mandatory nutrition labelling.

     Although we agree that foods processed at retail stores may be exempt from nutrition labelling, foods that are simply packaged at retail stores — such as fresh meat, poultry, seafood, and cheese — should not be exempt. It is important that all foods provide nutrition information so that consumers can make informed purchasing decisions — especially foods such as red meat, one of the largest sources of saturated fat in the average Canadian's diet. Diets that are high in saturated fat increase the risk of heart disease. High-fat diets are also associated with a higher risk of cancers of the colon, rectum, prostate, and endometrium. The Canada Food Guide to Healthy Eating advises Canadians to "choose leaner meats, poultry, and fish" and the Nutrition Recommendations advise us to reduce our intake of saturated fat.(2) But without nutrition information on the labels of those products, this is difficult advice for most consumers to follow.

2. Fresh fruits, vegetables, and foods sold in bulk should not be exempt from mandatory nutrition labelling.

     Health Canada proposes that all fresh fruits and vegetables (whether packaged or not) and bulk foods be exempt from nutrition labelling requirements. We see no reason for this arbitrary exemption. First, the degree of processing should not determine whether nutrition information is provided for consumers. All fruits and vegetables — whether fresh, frozen, or canned — should be required to provide full nutrition information. Why should canned or frozen carrots be required to include a nutrition label, while fresh packaged carrots are not? Nutrition information for pre-packaged produce can simply be included on the label, as is proposed for all other packaged foods.

     In the case of unpackaged produce and foods sold in bulk, nutrition information should be provided at the point-of-purchase with shelf markers, bin labels, or posters. This information should be provided in the same standardized format as is proposed for packaged food labels.

3. Added sugars should be added to the core list of required nutrients.

     CSPI recommends that food labels disclose the amount of added sugars in addition to total sugars because treating all sugars as equal fails to assist consumers in choosing a healthy diet. While naturally occurring sugars are chemically identical to added sugars, treating them as equal for labelling purposes provides misleading nutrition information. Added sugars are found largely in soft drinks, baked goods, candies, and other empty-calorie, nutrient-poor foods that most Canadians should consume in smaller quantities. In contrast, naturally occurring sugars are found in nutrient-dense fruits and dairy products. While fruit and low-fat dairy products appear to lower the risk of major illnesses that threaten Canadians' health,(3) foods that are high in added sugars offer no known benefits. Instead, they increase the risk of health problems or replace foods that appear to reduce the risk of disease.

     Data from the U.S. Department of Agriculture indicate that people who consume diets high in added sugars consume lower levels of protein, fibre, vitamins A, E, C, B-6, B-12, riboflavin, niacin, folate, calcium, iron, zinc, and magnesium.(4) They also consume fewer servings of grains, fruits, vegetables, meats, and dairy products than people who consume less added sugar. For some people, diets rich in added sugars also contribute to obesity, which increases the risk of diabetes, heart disease, high blood pressure, and other health problems. Thus, food labels should provide information that enables consumers to distinguish added sugars from naturally occurring sugars.

     The U.S. Department of Agriculture recommends a limit of 40 g of added sugars per day. Accordingly, we recommend that Health Canada adopt this figure as the Canadian Daily Value (DV) so that amounts of added sugars (rather than total sugars) can also be expressed as a "%DV" like most other nutrients.

4. Folate should be added to the core list of required nutrients.

     CSPI acknowledges that dietary folate is not naturally occurring in sufficient quantities in most foods to satisfy the 400 microgram recommended daily intake to reduce the risk of neural tube defects such as spina bifida and fetal anencephaly. However, we believe that a mandatory requirement for disclosure of folate content of foods would encourage consumers to choose good sources of folate, as well as act as an effective incentive for food manufacturers to fortify their products with folate, thereby increasing its availability in the food supply. As a result, folate fortification of commonly consumed foods such as bread, cereals, and pasta would increase folate intake, which is especially important for women of childbearing age who do not take folic supplements.

     Taking a multivitamin with folic acid may be the most convenient and foolproof way to ensure an adequate intake of folacin to reduce these risks. However, for the millions of Canadians who do not take supplements, it is critical that food labels disclose folacin levels.

5. The proposed format for small packages should be revised to ensure that nutrition information is easier to read and is provided on the label whenever possible.

     Health Canada proposes that labels on packages with less than 80 cm2 of available labelling space may either provide nutrition information in a type size no smaller than six points or provide an address or telephone number so that consumers can obtain the nutrition information. We recommend that manufacturers only be permitted to provide nutrition information in one of these alternative formats when it is not physically possible to display the information in the standard format. In the latter format, a toll-free number (not only a mailing address) should be required so that consumers can obtain nutrition information in a simple and timely manner. Requesting nutrition information by mail is a much more cumbersome, time-consuming method of obtaining nutrition information and it is much less likely to be used by consumers.

     Health Canada also proposes that labels on packages with between 80 cm2 and 260 cm2 of available labelling space may present nutrition information in a string design (i.e., linear format) if there is insufficient labelling space available for a tabular format. We recommend that the linear format be prohibited except in very limited circumstances because it is much more difficult to read than the tabular formats. Indeed, the example provided in section 2 of the Consultation Document on Label Format indicates that very little space is saved by using the linear format.

     We recognize that the use of a standard horizontal tabular format may be impracticable for some types of packages that have surface areas of less than 260 cm2 surface area where the package is long and very narrow. However, manufacturers should not have the discretion to determine how much space is sufficient to provide nutrition in a tabular format. We recommend that labels of these types of long, narrow packages provide nutrition information in a tabular format using a smaller type size (but no smaller than six point) to ensure maximum readability. Manufacturers should only be permitted to use the linear format on packages where the width of the narrower dimension of the broadest package surface is less than 4 cm.

6. Foods that use the "simplified format" should be required to include a statement indicating which of the core list nutrients are not present in significant amounts.

     Health Canada proposes that a food containing insignificant amounts of seven or more of the core list nutrients may use a simplified nutrition information panel. Health Canada also proposes that when nutrients other than calories, fat, carbohydrate, and protein are declared, then the statement "Not a significant source of [list of any applicable core list nutrients]" be included at the bottom of the nutrition information panel. However, we recommend that product labels always disclose the fact that a food is devoid of any of the fourteen core nutrients. They must do so by reporting a zero beside the name of the nutrient in the Nutrition Facts Box or, when eligible to use the simplified format, they may do so by naming any of the applicable ten secondary nutrients in a footnote beside the statement "Not a significant source of:."

7. Nutrition information for foods which require the addition of other ingredients before consumption should be provided for foods "as prepared," in addition to "as sold."

     For products that require the addition of other ingredients before consumption (such as beverage mixes and cake mixes), nutrition information should be provided for the food both "as sold" by the manufacturer and "as prepared" by the consumer. The failure to provide nutrition information "as prepared" would be very misleading and would make it difficult for consumers to independently determine the actual nutritional composition of the finished product.

8. Strict requirements should be established to ensure the accuracy of nutrition information.

To ensure the accuracy and reliability of food labels, we propose that all nutrition information provided on labels vary by no more than 10% from the actual amounts of nutrients found in a sample of the food offered for sale. If variances greater than 10% are permitted, this will likely undermine the public's confidence in, and effective use of, all nutrition labels.

9. The number of servings per container should be reported.

     Manufacturers should be required to report the number of servings per container. This information would assist consumers in visualizing how large a serving is and in planning meals accordingly. For example, a 240 mL serving size of juice may be easier to visualize if a consumer knows that there are eight such servings in a 1.89 L carton. Disclosing the number of servings per package is also useful in comparing products whose package volume is the same, but whose weight is significantly different.

10. Nutrition labels should disclose the basis of Daily Values.

     All nutrition labels should be required to disclose the fact that the Daily Values are based on a 2,000 calorie diet. This information is important to help consumers understand how Daily Values are derived, and it allows each consumer to adjust the Daily Values to fit his or her own dietary needs.

11. Small businesses should be defined.

     Health Canada sought comment on what would be a reasonable way of defining "small business" for purposes of exemption from nutrition labelling requirements. In response, we propose that small business be defined as a company that has less than $500,000 in gross annual revenues, produces fewer than 10,000 average units of the relevant food product, and employs fewer than ten employees in either of the two calendar years prior to the sale of the food.


1. The Centre for Science in the Public Interest (CSPI) is a non-profit health advocacy organization specializing in food safety and nutrition issues with offices in Ottawa and Washington, D.C. CSPI's Ottawa health advocacy office is funded by 135,000 subscribers to the Canadian edition of Nutrition Action Healthletter. CSPI does not accept funding from industry or government. For three years, CSPI has urged Health Canada and Members of Parliament to establish mandatory, comprehensive, easy-to-read nutrition information on all food labels.

2. Health and Welfare Canada, Nutrition Recommendations: Report of the Scientific Review Committee, (Ottawa: Minister of Supply and Services, 1990).

3. Numerous studies suggest that a diet rich in fruits and vegetables is associated with a lower risk of several cancers. Food, Nutrition and the Prevention of Cancer: A Global Perspective, Washington, D.C.: World Cancer Research Fund/American Institute for Cancer Research (1997). Other studies have found lower rates of stroke in people who eat more fruits and vegetables. M. W. Gillman, Protective Effect of Fruits and Vegetables on Development of Stroke in Men, 273 JAMA 1113 (1995). The recent DASH study, which found that a low-fat diet rich in fruits (as well as vegetables, low-fat dairy products, etc.) lowered blood pressure in people with high-normal levels. L. J. Appel, A Clinical Trial of the Effects of Dietary Patterns on Blood Pressure: DASH Collaborative Research Group, 336 New Eng. J. Med. 117 (1997). A large body of research also indicates that adequate calcium intakes can reduce the risk of osteoporosis by increasing peak bone mass or by raising (or maintaining) bone density.

4. Testimony of Rachel Johnson, U.S. Dietary Guidelines Advisory Committee Meeting, Washington, D.C., Mar. 9, 1999, at 364.

CSPI is an independent consumer health organization, specializing in nutrition and food safety, that is funded in Canada by more than 135,000 subscribers to its Nutrition Action Healthletter.

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