August 6, 1999
Ms. Mary Bush
Nutrition Evaluation Division, Food Directorate
Health Protection Branch P.L. 2203A
Ottawa, Ontario Canada K1A 0L2
The Centre for Science in the Public Interest (CSPI)(1) is pleased to submit the enclosed comments in response to Health Canadas nutrition labelling policy review. Our comments address all of the numerous labelling changes that Health Canada is considering. However, we wish to highlight the one change we consider most essential nutrition labelling, whatever form it ultimately takes, must be made mandatory for all foods, regardless of whether manufacturers decide to put any nutrition or health information on food labels (such as nutrition claims, health claims, third party symbols, or amounts of selected nutrients).
There are several reasons why any type of voluntary labelling system is inherently inadequate and
mandatory nutrition labelling is necessary:
- Many manufacturers will simply not provide nutrition information unless forced to do so.
Manufacturers of products with unhealthful levels of fat, saturated fat, trans fat, cholesterol,
sodium, or added sugars have absolutely no incentive to voluntarily provide nutrition
information. Furthermore, simply expanding current labelling requirements, without making
them mandatory, provides an additional disincentive for all manufacturers to voluntarily provide
- A voluntary nutrition labelling system misleads consumers. Under a voluntary labelling
scheme, the mere absence of nutrient disclosures misleads many consumers. A recent survey
revealed that 49% of respondents believe that, if a nutrient is not listed on a food label, then it is
not present in the food.
- Mandatory nutrition labelling is necessary to help consumers select more healthful foods
and reduce their risk of disease. It is extremely difficult for consumers to reduce their intake of
fat, limit their intake of sodium, increase their intake of fibre, or follow other nutrition
recommendations to reduce their risk of disease unless nutrition information is required on all
- Mandatory nutrition labelling will encourage food manufacturers to reformulate their
products and produce healthier foods. If nutrition labelling remains voluntary, manufacturers of
foods with unhealthful levels of fat, saturated fat, trans fat, cholesterol, sodium, or added sugars will
have no incentive to reformulate their products.
- Mandatory nutrition labelling will result in financial savings to the health care system and the
economy as a whole. A study by the U.S. Food and Drug Administration concluded that mandatory
nutrition labelling would result in $4 billion to $118 billion in cost savings over a 20-year period
resulting from reductions in premature deaths and health care costs. Such savings will not result
from a voluntary program.
- Mandatory nutrition labelling is necessary for consumers to efficiently compare different food
products. Under a voluntary labelling scheme, nutritional comparisons are often impossible
because many products provide no nutrition information at all. Mandatory nutrition labelling is
necessary for consumers to effectively compare nutrient content among a variety of food products.
- Mandatory nutrition labelling addresses consumers concerns. A recent survey shows that 74%
of Canadian consumers believe that nutrition information should be provided for all foods.
For these reasons, we urge Health Canada to make nutrition labelling mandatory. Merely adjusting the
current voluntary labelling guidelines will not accomplish these objectives.
Bill Jeffery, L.LB.
Public Policy Analyst