General Principles for Labelling and Advertising
Overall Impression Created About a Product
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All information on food labels or in advertisements, including words, pictures, vignettes and logos, will contribute to the overall impression created about a product. The individual components on food labels or in advertisements, as well as the overall impression created when the components are viewed together, all contribute to the overall compliance of food labels and advertisements.
In some situations, certain components of a label or advertisement may become misleading when used in conjunction with other components. For example, a heart symbol on its own may be interpreted as showing affection, which is acceptable. However, if the same heart symbol is placed beside a third party endorsement about the product's effect on heart health, the combined effect may likely create an overall impression in relation to the product's merit on heart health. For more information refer to Heart Symbols and Heart Health Claims.
All labelling information that is provided on food labels or in advertisements, as required by legislation, must be accurate, truthful and not misleading. For example:
- Ingredient lists must accurately reflect the contents and their relative proportions in a food
- Nutrition Facts tables must accurately reflect the amount of a nutrient present in a food
- Net quantity declarations must accurately reflect the amount of food in the package
Voluntary Labelling Information – Claims and Statements
Information that is provided voluntarily on food labels or in advertisements is often referred to as a claim. This may include any specific claims such as "Product of Canada," "Low in Fat" or "fair trade," as well as any other text or wording about specific manufacturing processes, descriptions about certain ingredients or properties of the food, historical references, environmental statements, etc. It also includes images, pictures or other visual representations, or any combination of these.
The international standard setting body Codex Alimentarius defines a claim as:
Claim: any representation which states, suggests or implies that a food has particular characteristics relating to its origin, nutritional properties, nature, production, processing, composition or any other quality [Codex Alimentarius, 2009].
In general, claims may be made about various aspects of a food, providing they 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.
Certain claims, such as those relating to nutrient content, organic, kosher, halal and certain disease-risk reduction claims, are subject to specific regulatory requirements in addition to the prohibitions in the FDA and CPLA.
For many claims that are not subject to specific regulatory requirements, the Canadian Food Inspection Agency (CFIA) and/or Health Canada have developed interpretive guidance that is intended to assist industry in complying with subsections 5(1) of the FDA and 7(1) of the CPLA. These guidelines also assist the CFIA in assessing the compliance of claims with subsections 5(1) of the FDA and 7(1) of the CPLA.
More information on specific claims and statements can be accessed from the Claims and Statements index of the Industry Labelling Tool.
Where there are no specific regulatory requirements or interpretive guidance associated with a given claim, industry remains responsible for compliance with the general prohibitions against false or misleading labelling and advertising.
The general principles in the following section provide broad guidance on the types of factors the CFIA takes into consideration when assessing information and representations in food labelling and advertising, in addition to any specific requirements or guidance that may apply.
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