The Food and Drugs Act, the Fresh Fruit and Vegetable Regulations, the Consumer Packaging and Labelling Act, and the Official Languages Act collectively govern the labelling and packaging of fresh fruits and vegetables in Canada.
Interpreting these varied regulations can be extremely challenging. Non-compliant labels can adversely affect product marketing or result in punitive action. In addition to complex requirements, there are many ‘grey’ areas in the legislation and regulations that have the potential to create issues of non-compliance. Without a clear understanding of the intricacies of the requirements and the relevant technical expertise, it can be extremely difficult to ensure that the label developed for the product will be acceptable for the Canadian marketplace.
Making claims on labels about the health benefits, nutrient content, or the production method can be complicated, as very few of these claims are approved for use in Canada. An accurate nutritional facts table whenever a claim is made is mandatory to fulfill legal labelling requirements.
In order to ensure compliance, companies can engage a label review service, usually offered by a team of legal experts. This practice can be cost prohibitive with a poor cost-to-benefit ratio. Current average costs for the review of an average label are in the area of $1,500 to $3,500 CDN.
CPMA members labelling at a case level can access the newly released Labelling Guidance for Shipping and Master Containers of Fresh Produce in the Canadian Marketplace document available by logging into myCPMA.
For more information, contact Sally Blackman at: sblackman@cpma.ca
CPMA’s Label Review Service is available to CPMA Members only. For more information please examine the Label Review Service.