Why can’t I use
“flavouring” as an ingredient? Why is
“couleur” not an acceptable name for dyes in French when
“colour” is acceptable in English? Why can’t I use
“colour” as an ingredient instead of naming all dyes? What
is wrong with “saveur” as an ingredient?
If you are asking one of the
above questions or a similar one, you are probably having a problem
with ingredients that can be declared as a group.
Canadian regulations are specific
as to which ingredients can be declared this way and very specific as
to the words used. You must use the name as stated in the
regulations: there are very few permitted exceptions.
The regulations also prohibit
naming one component of a group without naming all of them. For
example, you cannot use “colour” as an ingredient if you also name
a specific dye such as Sunset Yellow in the ingredient list.
The Canadian Food Inspection
Agency currently is more flexible about naming specific ingredients
in circumstances involving allergens. For example, the USA has
named Tartrazine as an allergen and requires that it be specifically
named in all products selling there. Currently, it would be acceptable
to use “colour” to declare dyes other than Tartrazine and name Tartrazine
specifically.
The following table combines
the French and English requirements from the Food and Drug Regulations
for ingredients commonly found in beverage alcohol.
Are American spellings acceptable?
American spellings such as
“color”, “flavor” and “sulfite” are acceptable.
My label was flagged for
different ingredient lists. What do I have to do to fix this?
There are three situations
where products may have differing ingredient lists. The first
occurs when the English and French ingredient lists do not match exactly
(e.g. different order of ingredients, different ingredients).
Usually this is due to a clerical error which is easily corrected by
the manufacturer. The second occurs in products where the ingredient
list on the outside package does not agree with the ingredient list
on the bottle or can inside. The third occurs when an ingredient
list appears in another language that names ingredients not in the English
and French ingredient lists. This would indicate that the English
and French ingredient lists are not complete.
Why can’t I list
“Chardonnay” (or some other item) as an ingredient in a wine beverage?
Ingredients must be called
by their common names. The correct ingredient name is “wine”.
It would be permissible to say “Chardonnay wine”, particularly if
the varietal is important to the nature of the product or the marketing
text refers to the Chardonnay varietal.
Why can’t caffeine be
listed as an ingredient?
Canadian food regulations permit
caffeine as an ingredient only in cola beverages. When you list
caffeine in an ingredient list, you are declaring that chemical caffeine
was an ingredient. Most of the time, products contain caffeine
through an ingredient such as guarana or coffee. If you wish to
warn consumers that your product has high caffeine levels from ingredients
that have natural caffeine, you can declare the caffeine content per
serving or list “contains caffeine” after the ingredient list.
Be very careful that no text on the product implies that chemical caffeine
was added.
Why is
“non-dairy creamer” not an acceptable ingredient?
“Non-dairy creamer” is
not a recognized ingredient. It is a collection of other ingredients.
You can say “non-dairy creamer” and then list its ingredients in
brackets after it. A less consumer friendly option is to place
the ingredients of the creamer through the ingredient list in the appropriate
descending order by weight for the whole product.
What ingredients do not
require an ingredient list?
Ingredients that don’t require
an ingredient list themselves are listed in the Food & Drug Regulations
B.01.009.
Common ingredients in beverage
alcohol that don’t require declaration on ingredients are:
- Mono & diglycerides
- Rice
- Starches or modified
starches
- Milk products subject
to Canadian compositional standards (B.08)
- Sweetening agents
subject to Canadian compositional standards (B.18)
- Cocoa, low-fat cocoa
- Salt
- Beverage alcohol
subject to Canadian compositional standards (B.02)
- Vegetable or animal
fats or oils subject to Canadian compositional standards (B.09)
- Carbonated water
- Gelatin
Also allowed with some restrictions
are colouring preparations, flavouring preparations, artificial flavouring
preparations, spice mixtures, and seasoning or herb mixtures.
Suppliers are responsible for knowing the restrictions that apply to
these ingredients.
Why do I have to declare
salt separately from spices and herbs?
This is one of the restrictions
involved in not having to give an ingredient list for these mixtures.
Why can’t I refer to a
product with its brand name in the ingredient list?
Ingredient lists must use common
names of the ingredients used. CFIA considers brand names to be
distracting from the purpose of the ingredient list, which is to inform
customers of the composition of the product. The brand name belongs
with other marketing information, not the ingredient list.
If a beverage is mostly
water on a composition basis but very little water was added in making
it, where should water appear on the ingredient list?
Ingredient lists must be in
descending order by weight. You can produce a cooler type beverage
by mixing rum with orange juice then adjusting the final alcohol content
with a little water. In this case, the order of ingredients would
likely be orange juice, rum, water. Although both rum and orange
juice compositionally are mostly water, that water is not an ingredient.
When working out the order for an ingredient list, look at the amount
of water actually added and ignore the water content of the other ingredients.
Why does my beer require
an ingredient list?
Any product selling as a beer
in Canada must meet the Canadian standard of identity for beer irrespective
of where it was made. When ingredients are used that are not allowed
in the standard of identity, this product becomes an unstandardized
product and requires an ingredient list. New beer styles outside
of the Canadian standard of identity for beer have become popular in
the last few years so this is happening more frequently. Some
common ingredients that take beer into the realm of an unstandardized
product are coriander (and other spices), orange peel, coffee, guarana,
flavouring preparations and artificial sweeteners. Note that artificial
sweeteners trigger a number of other labelling requirements.
A label reviewer also may recommend
an ingredient list to satisfy requirements for an allergen warning.
Can I put the percentage
of each ingredient in the ingredient list?
Yes, but this is not required.
The ingredients still must appear in descending order by weight.
Why is quinoline yellow
(or another dye) an illegal ingredient?
The list of permitted additives,
particularly synthetic dyes, differs from country to country.
If your product uses a food colouring, check its legal status in Canada.
The only synthetic dyes permitted in beverage alcohol in Canada are
Tartrazine, Sunset Yellow, Amaranth, Brilliant Blue, Allura Red, Fast
Green, Indigotine and Erythrosine.
With the increasing development
of new natural dyes, be aware that many natural dyes are not approved
in Canada. Check the list in the Food and Drug Regulations for
approved “natural” dyes. Contact the Canadian Food Inspection Agency
for the status of new “natural” dyes in Canada but be aware that
the status may change if they are not listed in the Food and Drug Regulations.
Why are E-numbers (or FD&C
numbers) not permitted?
E-numbers and FD&C numbers
have no status in Canada and are considered to be consumer unfriendly.
The name of the ingredient must be stated in the format given by the
Food and Drug Regulations. If these numbers must be used to satisfy
the requirements of other countries, they should be placed in brackets
after the correct ingredient name e.g. Tartrazine (E102)
Note that there is no such
thing as “certified colour” in Canada and is not acceptable to identify
colouring as certified in a Canadian ingredient list.
Why can’t
“colour” be listed as “natural colour” or
“artificial colour” similar to what is permitted for
“flavour”?
The requirement to identify
artificial flavourings is part of the Food and Drug Regulations.
There is no reference to identifying colourings in this manner.
Although it is common to refer to dyes as natural or synthetic in formulations,
it is unacceptable to describe “colour” as natural or artificial
in an ingredient list (see first question).
“Natural colour” is particularly
misleading to consumers, as it implies that the colour of the product
comes solely from the principal ingredients (e.g. beer is dark due to
roasted malt and not due to added caramel). In the consumer sense,
all dyes would be “artificial colour”.
Why is cochineal (or another
dye permitted in Canada) not allowed in my ingredient list?
This is probably because the
product has a standard of identity according to your declared common
name (see section on common names). Some standards of identity
do not permit the use of dyes at all and many allow only caramel.
Can I list the function
of an additive in the ingredient list?
The function of an additive
can be listed in brackets following the ingredient. The ingredient
must be named as per the Food and Drug Regulations. If the function
of the ingredient is declared, the ingredient must be approved for that
function. If not, the ingredient is illegal, even if it is approved
for a different function.
What is required for artificial
sweeteners?
The Food and Drug Regulations
make several extra demands beyond listing artificial sweeteners in the
ingredient list when they are used.
- A nutrition facts
table is required. If the artificial sweetener is neotame, there
is an option of providing the following information for a stated serving
size instead of the nutrition facts table: energy value expressed in
Calories & kilojoules, protein expressed in grams, fat expressed
in grams, and carbohydrate content expressed in grams.
- A declaration of
the presence of the specific artificial sweetener (e.g. “contains
aspartame”) is required on the same panel which shows the common name,
net quantity and alcohol declaration. If another sweetener is
used in conjunction with it, the declaration must also refer to the
other sweetener (e.g. “sweetened with acesulfame-potassium and sugar”).
This declaration must be at least the same size and prominence as the
number in the net quantity declaration.
- A statement of the
milligrams of artificial sweetener per serving of stated size is required
(e.g. “70 mg sucralose per 330 ml serving”).
- If aspartame is
used, a warning that the product contains phenylalanine is required.
Artificial sweeteners cannot
be listed by their E-numbers. If the E-number is required to make
a multi-national label, it can be placed in brackets after the name
of the sweetener.
Note that some artificial sweeteners
approved for use in other countries are not approved in Canada.
Why was my label failed
for bison grass in the ingredient list?
Bison grass contains coumarin,
which is considered to be an adulterant in Canada. Products containing
bison grass will be accepted only after analysis shows that the coumarin
level meets the Health Canada maximum allowable limit. This limit
can be found in the LCBO Product Packaging Standards and Chemical Guidelines.
Why was my
ingredient list flagged with a warning for
wormwood?
Health Canada has a low maximum
allowable limit on thujone, which is the active compound in wormwood.
Because thujone is not identified as an adulterant in Canadian regulations,
the LCBO does not fail the label but notes that this ingredient may
result in the product not being accepted. This warning will not
appear for wormwood-containing products if wormwood is not named on
the label.
