Is the use of PLU labels a Canadian Regulatory Requirement?
No, PLU (Price Look-up) is a voluntary labelling system for bulk fresh fruits and vegetables. There are no Canadian federal regulations specific to PLU stickers or what constitutes one (Source: Fair Labelling Program, Canadian Food Inspection Agency). No regulatory body requires a PLU sticker on loose/variable measure produce but most medium to large retailers expect a PLU as part of their business model. Ontario Provincial Legislation (Farm Products Grades and Sales Act) does not require the use of or regulate the content of a PLU label; however, any information contained thereon must be correct.
Do I need to include English & French on my PLU labels?
There are no language requirements for PLU labels at a Federal level but, should your product be destined for the Quebec marketplace, it will be expected to meet the French language legislation of that province. This means that all printed consumer product information must be in both official languages and that the French text be of at least the same prominence as the English (e.g. same font size, bolding or shading, etc.). Any information not exempted under the Quebec Charter of the French Language will require translation into French.
What information is exempt under the Quebec Charter of the French Language?
This language legislation (Division I, Exceptions to Section 51 of the Charter of the French Language, number 7) exempts only the following information on a product from translation into French:
- the firm name of a firm established exclusively outside Québec;
- a name of origin, the denomination of an exotic product or foreign specialty, a heraldic motto or any other non-commercial motto;
- a place name designating a place situated outside Québec or a place name in such other language as officialized by the Commission de toponymie du Québec, a family name, a given name or the name of a personality or character or a distinctive name of a cultural nature; and
- a recognized trade mark within the meaning of the Trade Marks Act (R.S.C. (1985). c. T-13), unless a French version has been registered.
I would like to indicate on my label that the product is organic. Is this allowed?
Yes, but any information related to organic status of a fruit or vegetable included on a PLU for use in Canada, must satisfy Canadian requirements for organic produce marketed in Canada; if the product is to enter the Quebec marketplace, the information must satisfy the Quebec organic regulations, as well as the language legislation referred to above. (The approved certifying body for your organic product should be aware of legislation applicable to organic product sold in Canada.)
My product is a source of potassium – can I say this on my PLU label?
If the PLU label contains any claims information, such as nutrient content or health claims they are subject to the requirements set out in the Food and Drug Act and Regulations and other applicable legislation. If a PLU label contains a nutrient content claim such as a “source of Potassium” the accompanying information required by the applicable regulations/legislation must appear on the sticker - for example, the amount of potassium per serving of stated size must also be on the sticker.
If the PLU label contains a health claim it may trigger the requirement for a Canadian Nutrition Facts Table on the sticker.
Canada has country of origin declaration requirements and the United States has emerging Country of Origin Labelling (COOL) requirements so do I need to include the country of origin on my PLU label?
There is no Canadian regulatory requirement to put country of origin information on a PLU label but, in general, Canadian labelling regulations do require a country of origin declaration on pre-packaged product and shipping containers.
Is it acceptable to add our company’s website on the PLU label?
This is a marketing decision each company makes but be aware that the URL will be subject to same regulatory requirements as other printed information and claims (i.e. language and nutritional claims requirements noted above).
Where can I find additional information about PLUs and GS1 Data Bars?
Additional Sources of Information for both PLUs and GS1 DataBar are available at the following sites:
CPMA makes every effort to ensure that accurate information is provided but does not accept any responsibility for errors or omissions. Acts and regulations are evolutionary and this document will be updated should any changes occur which impact information included above.