Food In Canada


Mother “Natural” versus Canada

If the foods in Mother Nature’s garden are “natural,” would not organic foods be “natural” as well? In Canada the answer is “not necessarily so.” What then makes a food “natural?”

A search of Canadian food laws finds legislation in New Brunswick and Nova Scotia titled the Natural Products Act, and the Natural Products Marketing Act in Newfoundland and Prince Edward Island. In Quebec the Regulations Respecting Bottled Water, under the Food Products Act, define “natural” mineral or spring water as those that have not undergone any treatment other than decantation, filtration or carbonation, or ozonation if it does not alter the concentration of ions. There is also the federal Natural Health Products Regulations, but these pertain to therapeutic products, not foods.

In the vastness of the almost uncountable laws that govern foods in Canada, there is really no single broad scope piece of legislation that defines the designation “natural” in relation to a food. The Canadian Food Inspection Agency (CFIA), however, protects the use of the term “natural” through guidelines in the 2003 Guide to Food Labelling and Advertising (GTFLAA), Section 4.7. The guidelines are some of the most scrutinizing “natural” guidelines on the planet, and are treated as if they were actual regulations. The CFIA can enforce the guidelines under sections within the Food and Drug Act or the Consumer Packaging and Labelling Act that deal with misrepresentation. In other words, if the guidelines are not followed it could be seen as a misrepresentation of the food being claimed as “natural,” with the assumption that the term “natural” assigns a greater value to a food in the view of most consumers.

As per the CFIA’s guidelines, a food or ingredient described as “natural” has not been submitted to processes that have significantly altered its original physical, chemical or biological state, including the removal of a constituent or fraction thereof, except the removal of water. A natural food or ingredient thereof would not be expected to contain, or to ever have contained, an added vitamin, mineral nutrient, artificial flavouring agent or food additive as defined in Division 16 of the Food and Drug Regulations (FDR). The CFIA guide includes processes considered to have minimal effect (such as heating) and maximal effect (such as hydrogenation) with regard to the natural character of the food.

An organic food may not contain any synthetic ingredient, but may include a substance in the permitted substances list for organic foods, as per the National Organic Standard. For example, citric acid, regardless of its source, is a recognized food additive. And naturally derived citric acid is permitted. As such, a food with citric acid may be organic, but not “natural.” An organic food with naturally derived ingredients, including naturally derived food additives, may be declared as being made with “natural ingredients,” meaning the food as a whole may not meet the natural guidelines, but its constituents are derived from natural sources. The guidelines get even pickier in that even most natural flavours do not qualify as “natural” since many are made with extraction solvents and other food additives.

Gary Gnirss

Gary Gnirss

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