Food In Canada


The bitter and sweet on sugar labelling

The U.S. has recently finalized rule making on nutrition labelling. By July 26, 2018 manufacturers with food sales of $10 million or more will need to comply with the new rules. Others have until July 26, 2019. In contrast, nutrition labelling modernization in Canada is still hovering at the proposal stage. There is no word on when final regulations will be completed. Based on similar past efforts, this would more likely happen in 2017.


Current nutrition labelling rules in Canada and the U.S. differ in many respects. These differences, which include among other things how serving sizes, dietary fibre, trans fat and vitamins and minerals are accounted for, preclude the opportunity of creating a harmonized nutrition facts table for both countries. The look, while not identical, is similar. For instance, the new U.S. format includes added sugars and a per cent daily value (DV), while Health Canada (HC) has proposed to set a DV for total sugars and not to include “added sugars.” It will be interesting to see whose labelling strategy will be effective in achieving the goal of reducing sugar consumption.


The scientific information on excessive sugar intake and its role in certain chronic diseases, like heart disease and nutritional deficiencies, is only starting to come into focus. There is sufficiently clear science around excess sugar consumption for this to be a public health concern. The consensus is clear, diets in North America need to reduce the consumption of sugars. The tricky part is developing nutrition labelling that is impactful but simple enough for consumers to make healthy dietary decisions.


The approach the U.S. FDA has taken is to include both total sugars and added sugars in a nutrition facts panel (NFP). This will need to include a per cent DV for “added sugars” based on a Daily Reference Value (DRV) of 50 g per 2,000-calorie diet for children and adults four years of age and older, and 25 g for children one to three years of age based on a 1,000-calorie diet. In Canada, HC has proposed daily values of 100 g for “total sugars” for children and adults four years of age and older, which represents five per cent of the caloric intake for a 2,000-calorie diet. For children one to four, the daily value proposed is 50 g total sugars, also five per cent of caloric intake for this age group. The World Health Organization’s (WHO) guidelines suggest that no more than 10 per cent of calories should be from “free sugars.” This does not account for all forms of sugar, but does include added sugars and certain added naturally occurring forms like honey, syrups and concentrated fruit juice.


The approach in the U.S. is more aligned with the WHO approach, putting its eggs in the “added sugar” basket. HC has placed its eggs in the “total sugar” basket. In addition, HC has also proposed to make it mandatory to collectively declare all added forms of sugars as “sugar,” with a parenthetical declaration of the individual sugar forms, in a list of ingredients.


The differences between the Canadian and U.S. approach on sugar labelling is not the result of differences in the core science, and instead has more to do with HC’s consumer research. HC found that Canadian consumers have an easier time understanding how to use total sugar information than a combination of added and total sugars. The per cent DV for total sugars also fits into HC’s simplified footnote identifying that five per cent of the DV is a little. Placing focus on total sugars introduces a one-time cost for the amendment. In contrast, the U.S. approach requiring added sugars to be declared incurs an ongoing cost related to quantifying, documenting and enforcing the regulations. Analytical methods cannot differentiate between added and naturally occurring sugars. This means added forms of sugars need to be manually determined by accounting for total sugars and added sugars from formulation. The U.S. FDA will require manufacturers to maintain records for at least two years after the introduction of food in interstate commerce. The cost and burden to industry and government in the U.S. is far more significant than what has been proposed in Canada.


Both the U.S. and proposed Canadian approach may very well result in the same goal of lowering overall sugar intake. The Canadian approach is well thought-out, practical, simple and more cost effective than that in the U.S. Time will eventually expose what impact this has.


Gary Gnirss

Gary Gnirss

Gary is a partner and president of Legal Suites, Inc., specializing in regulatory software and services
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