Labelling

Products produced in provincially-licensed plants are labelled in accordance with several regulations. The labels must be in compliance with the following regulations: The Meat Regulations (Ontario), The Meat Inspection Regulations (Canada), The Food and Drug Regulations (Canada), The Consumer Packaging and Labelling Regulations (Canada) and; the Livestock and Poultry Carcass Grading Regulations (Canada).

Meat Inspection Legend

Every edible dressed carcass or part of a carcass that has passed inspection must be legibly stamped with the inspection legend before refrigeration. Only rabbit and poultry carcasses are excluded. In these cases, the inspection legend can be applied via a carcass tag. If the carcass or parts of carcass cannot be stamped, the inspection legend can be alternatively applied to a sealed bag or a label used on the sealed bag. It can also be applied to a bulk shipping container or applied to a label attached to the shipping container.

Only edible ink may be used to mark meat or products with the inspection legend. In addition to the stamping of carcasses and parts of carcasses, the meat inspection legend must also be applied to all pre-packaged meat products. The stamp can be applied directly to the packaging or to a tag attached to the packaging. Animal food, meat and meat products which will be used for pharmaceutical, research or therapeutic purposes, shall not bear the meat inspection legend stamp.

Mandatory Label Information

The purpose of a label is to provide basic production information to the consumer. The label makes the consumer aware of storage and handling requirements and possibly the nutritional profile of the product. Promotional information and claims can also be relayed through the use of the label.

All pre-packaged foods require a label. A label is defined as a legend, word or mark attached to, included in, belonging to or accompanying a food (Guide to Food Labelling and Advertising, 2.1). Only pre-packaged foods that are one-bite confections, for example candy that is sold individually, or fresh fruits and vegetables with minimal packaging, do not require any label.

A carcass or part of a carcass that has been approved and stamped with the meat inspection legend is considered to be fully labelled. In addition to the requirement for a meat inspection legend, the label on all other meat product must be labelled and must meet the following requirements:

Common name (identity) - this must be the common name prescribed by the Food and Drug Act,
   or the name by which the product is commonly known.

• The name of a product must also conform to compositional standards. For example, lean ground
  meat can not be labelled as such unless it contains no greater than 17 per cent fat and contains
  only boneless comminuted beef with no added ingredients [see Meat Regulations (O. Reg. 31/05),
  Table 1: Meat Product Standards]. Other compositional standards include maximum or minimum
  amounts of certain contents, and mandatory ingredients.

• If a product contains meat from more than one species, the species can be listed in the name of the product in descending order by percentage of composition or simply named as "meat." The name must be shown on the principal display panel.
• For foods that do not contain more than 80 per cent whole muscle weighing more than 25 grams, the common name/product description must include "chopped and formed."

Net quantity - all pre-packaged products must declare the net quantity of the product. (exceptions: individual servings of food [i.e. vending machines, mobile canteens] and portions served by airlines). In addition, catch weight products [i.e. turkeys] vary in size when they are sold to the retailer and do not require individual weights. Shipping cartons must declare the net weight. The net quantity must be declared in metric, rounded to three figures, and must have a type height of at least 1.6 mm, depending on the container size. The declared quantity should not contain punctuation marks. There are standard sizes that have been established for some prepackaged meat products.

Name and address - the label must include the name and address of the person or company responsible for the production of the product or, the name and address of the company for whom the product was prepared, prefaced by "prepared for". The address must be complete enough for postage and have a minimum type height of 1.6 mm.

List of ingredients - foods that are pre-packaged and contain more than one ingredient require a list of ingredients. There are some exceptions: pre-packaged products packed from bulk at retail [i.e. individual servings from a deli counter];pre-packaged individual portions of food [i.e. from an airline]; pre-packaged food from commissaries; pre-packaged meat or poultry which was roasted/barbecued on site and; standardized alcohol. Ingredients must be listed in descending order of proportion by weight in the food. There are several ingredients that can be shown at the end of the list in any order (spices, seasonings, herbs, flavours, flavour enhancers, food additives, vitamin and mineral nutrients). Water and smoke if present must always be listed in the ingredient declaration. If meat is mechanically separated, this must be declared along with the species.

• Components of ingredients must be listed. They can be shown in brackets following the name of the ingredient, in descending order, or they can be listed in descending order of proportion by weight within the main ingredient declaration without listing the ingredient. There are ingredients and preparations that do not require the declaration of their components and there are some components of ingredients that must always be declared on the label.
  
  
• Collective names may be used when listing some ingredients. This is one option that may help to reduce the size of the ingredient declaration. For example, if there are several spices or seasonings listed (except salt), they may be declared under "spices." Also, if there are several different colours added to a product (with a few exceptions), these can be declared collectively as "colour."
  
  
• Processing aids that do not appear in the finished product or are present in insignificant levels do not require to be listed in the ingredients. Examples of these are hydrogen, cleansers and sanitizers, packaging gasses, freezing and cooling agents, washing and peeling agents, filtering agents, catalysts and water treatment chemicals. A complete list of processing aids exempt from labelling can be found in the Guide to Food Labelling and Advertising, 2.8.3.

Durable life date - if a product has a durable life of 90 days or less, a best-before date is required on the label or packaging. The durable life date is the amount of time between when the food was packaged and when the food begins to lose wholesomeness, palatability and nutritional value (Guide to Food Labelling and Advertising, 2.9).

Production Date or Code - Must be shown on the product label (except for carcasses or half carcasses). The production date or a code identifying the production lot may be shown.

Storage instructions must appear on the label or packaging of consumer and bulk products if the product must be stored at a different temperature than room temperature. If the food is packaged at the retail site and has a durable life date of less than 90 days, the label may list the storage instructions and best before date or, the information may be listed on a poster beside the food. Storage instructions will state "Keep refrigerated" or "Keep frozen."

Bilingual - all information on the label must be in both English and French (exceptions: the identity and place of business may be in one official language, shipping containers not for sale to consumers, test market products and specialty foods may be in one official language). Also, if the product is sold in a local area in which one of the official languages is the mother tongue of less than 10% of residents, the label may be presented in the predominant language.

Allergens and Labelling

While the labelling of allergens is not required by the regulations, it is strongly recommended. Allergenic reactions are an immunologic response to protein in a food. Reactions can vary from mildly uncomfortable to life threatening. Anaphylaxis can occur which may involve the skin, respiratory tract, cardiovascular system, central nervous system and stomach. Because allergens can cause such severe reactions, improper and incomplete labelling of food products can be very serious.

Undeclared allergens may be present in food for several reasons; many times it is the result of a labelling error. As was previously discussed, there are several components of ingredients that are exempt from the ingredient declaration. If an allergen is contained in one of these components, the consumer may be unaware. Undeclared allergens may also be present in the product as a result of cross-contamination. Food surfaces, equipment and handlers themselves, may cross-contaminate non-allergenic product if proper sanitation is not practiced. Some other reasons for undeclared allergens may include products in the wrong packaging, outdated packaging, use of uncommon ingredient names or use of material from a previous production run.

It is recommended that the following allergens be listed if they are present in foods as either an ingredient or component: peanuts, tree nuts, sesame seeds, milk, eggs, fish, crustaceans and shellfish, soy, wheat and sulphites.

Allergens may be hidden in foods and ingredients. For example, worcestershire sauce contains soy protein and anchovies, which are rarely declared. Flavours in products do not need component declarations. Some components of seasonings can include lactose, milk powder or whey powder.

Declaration of Percent Protein

If the meat product contains water or phosphate salts, and the product is not cured or preserved and/or there is no standard for the product, a declaration of the per cent meat protein in the product must be declared as part of the common name of the product.

Labelling of Non-traditional Meat Products

All products included in the definition of "meat" under the Meat Regulation (O. Reg. 31/05), must meet the same labelling requirements as listed in the section "Mandatory Labelling Information." This definition lists all parts of the dressed carcass of an animal and includes the blood, edible organs and edible tissues of an animal. All products to be sold for human consumption must have the meat inspection legend.

Labelling of Inedible Meat Products

Products being shipped from the plant which are deemed inedible, for use in animal food or destined for use in the pharmaceutical industry must be marked with: the identity of the product (including the species), net quantity, name and address of where the product was produced, and storage instructions. If the containers are destined for animal food, they must be marked, "animal food." If the product is destined for pharmaceutical, research or therapeutic use the container must be marked, "For pharmaceutical purposes," "For research purposes" or "For therapeutic purposes." It should be noted that the meat inspection legend must not be applied to containers.

Nutrition Labelling

Health Canada published an amendment to the Food and Drug Regulations on January 1, 2003. As result, nutrition labelling is required on all pre-packaged products with some exceptions. The nutrition information panel is now referred to as "Nutrition Facts."

Large businesses, defined as manufacturers with gross revenues from Canadian food sales of more than $1,000,000 in the 12-month period prior to the proposed regulations coming into effect, were required to comply with the new regulations effective December 12, 2005.

Small businesses, defined as manufacturers with gross revenues from Canadian food sales of less than $1,000,000 in the 12-month period prior to the proposed regulations coming into effect have until December 12, 2007 to make the information available on prepackaged food products.

Note: Depending on the type of product, there may be additional labelling requirements.

CFIA Manual of Procedures Chapter 7
www.inspection.gc.ca/english/anima/meavia/mmopmmhv/table7e.shtml

Guide to Food Labelling and Advertising
www.inspection.gc.ca/english/fssa/labeti/guide/toce.shtml

Food and Drug Regulations
laws.justice.gc.ca./en/F-27/C.R.C.-c.870/index.html

Consumer Packaging and Labelling Regulations
laws.justice.gc.ca./en/C-38/C.R.C.-c.417/index.html

Ontario Regulation 31/05 Part 12
www.e-laws.gov.on.ca/DBLaws/Regs/English/050031_e.htm

Andrea Smallwood
Food Safety Advisor, Regulatory/Meat
Meat Inspection Policy & Audit Services
Food Inspection Branch
1-888-466-2372 Ext. 64966

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