Food Products that Require a Label
Labelling Requirements

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General

Most prepackaged foods sold in Canada require a label (definition) [B.01.003, FDR; 10, CPLA]. Additionally, certain non-prepackaged foods require a label when sold in Canada.

Only once a label is required do other labelling requirements apply, such as a list of ingredients or common name. For more information on food labelling requirements, visit the Industry Labelling Tool.

Foods manufactured for export are not subject to the requirements of the Food and Drugs Act (FDA) or Consumer Packaging and Labelling Act (CPLA), including labelling requirements [CPLR 3(1), FDA 37 (1)].

Exemptions

Exemption from the requirement to carry a label

The Food and Drug Regulations (FDR) and the Consumer Packaging and Labelling Regulations (CPLR) exempt the following prepackaged foods are exempt from the requirement to carry a label:

  • One bite confections that are sold individually;
    • When more than one individual one-bite confection are sold together in the same package, the product sold is not considered to be a one-bite confection. Additionally, lollipops are not considered to be one bite confections regardless of size, as the stick allows for the lollipop to be eaten in several bites [B.01.003(1)(a)(i), FDR; 4(3), CPLR].
  • Fresh fruits or fresh vegetables packaged in a wrapper or confining band of less than ½ inch in width;
    • Fresh fruits or vegetables that are packaged in a clear, colourless transparent wrapper (e.g. shrink wrap) on individual units of fresh produce when absolutely no printed, written or graphic information appears on the wrapper, other than a price sticker, bar codes, number codes, environmental statements and product treatment symbols qualify for this exemption. Examples of these products typically found in such wrappers include an English cucumber, a head of lettuce, a bunch of grapes, etc. Examples of fresh fruits or vegetables that are packaged in a confining band of less than ½ inch (13 mm) in width are fresh broccoli, asparagus or rhubarb, held together by twist ties, elastics or rubber bands [B.01.003(1)(a)(ii), FDR; 4(4), CPLR].

Note: the Consumer Packaging and Labelling Regulations also exempt the following foods from bearing a label:

  1. Raspberries or strawberries packaged in the field in containers with a capacity of 1.14 litres or less [4(5), CPLR];
  2. Soft drink containers that are i) re-used by a dealer as soft drink containers, ii) permanently labelled with any information required to be shown by the FDA, and iii) manufactured prior to March 1, 1975 [4(2), CPLR].

The foods listed in (a) and (b) however; do not have an exemption from labelling requirements under the FDR.

Exemption from all provisions of the Consumer Packaging and Labelling Act

The following products are exempt from all requirements of the CPLA:

  • Prepackaged products that are produced or manufactured for commercial or industrial enterprises or institutions for use by such enterprises or institutions without being sold by them as prepackaged products to other consumers.
  • Prepackaged products that are produced or manufactured only for export or for sale to a duty-free store.

This means that these foods are exempt from all requirements in the CPLA, such as container sizes and claims, as well as the labelling requirements.

Only foods that are manufactured for export are also exempt from the labelling requirements of the FDA. Foods for commercial or industrial enterprises and foods for sale to a duty-free store are subject to the labelling requirements of the FDR.

Exemption for Prepackaged Products Consisting of Less than Seven Identical Products

When a prepackaged product consists of less than seven identical products that are packaged separately, none of the information required by the CPLA and CPLR has to be shown on the outside of the prepackaged product being sold as one unit provided the products inside are labelled to show all the required information in a manner which is clearly visible at the time of sale [28(2), CPLR]. 

Although no similar regulation exists in the FDR, information required by the FDR that is clearly visible through the outer package without undue manipulation is considered to meet the FDR requirement for labelling information to be readily discernible [A.01.016, FDR].  For example, no objection is taken to the sale of six identical completely labelled candy bars in a clear unlabelled plastic bag, providing all mandatory information such as the list of ingredients, Nutrition Facts table, etc. is readily available and legible.

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