Freshfiles - Labelling

7/21/2019 Freshfiles - Labelling

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fresh files A series of practical farm management guides compiled by the Ontario Farm Fresh Marketing Association

LABELLINGTe federal Food and Drugs Act prohibits the labelling,packaging, treating, processing, selling or advertising of anyfood in a manner that is false, misleading or deceptive toconsumers or is likely to create an erroneous message regardingthe character, value, quantity, composition, merit or safetyof the product. It also prohibits health claims that mightsuggest that a food is a treatment, preventative or cure forspecied diseases or health conditions, unless provided forin the regulations.

Federal responsibility for Canadian food labelling isshared between Health Canada and the Canadian FoodInspection Agency (CFIA ).

Under the Food and Drugs Act , Health Canada isresponsible for establishing policies and standards relatingto the health, safety, and nutritional quality of food sold inCanada.

CFIA is responsible for the administration of foodlabelling policies related to food labelling, packaging andadvertising, as well as general agri-food and sh labellingprovisions specied in theCanada Agricultural Products Act ,the Meat Inspection Act and the Fish Inspection Act .

Of importance to bakeries is that the CFIA administersthe food-related provisions of the Consumer Packaging andLabelling Act, which includes basic food label information,net quantity, metrication and bilingual labelling. Here is alink to the Department of Justice,Consumer Packaging andLabelling Regulations:http://laws-lois.justice.gc.ca/eng/regulations/ C.R.C.%2C_c._417/FullText.html

Food labelling comprises 4 areas:1) Mandatory Information2) Nutrient Facts ables3) Allergens and precautionary allergen statements (e.g. May Contain. )4) Bilingual Requirements (some exemptions)

905-841-9278 OntarioFarmFresh.com [email protected] Farm Fresh Marketing Association (OFFMA) | 2002 Vandorf Sideroad | Aurora Ontario L4G 7B9 CANADA

TEL. 905-841-9278 | FAX 905-726-3369| E-MAIL [email protected]

Consumer Packaging & Labelling Regulations

Regulations Summary

1 Mandatory InformationIt is commonly thought that prepackaged baked goods produceand sold on the same farm are exempt from labelling regulationTat is not true. All prepackaged prepared foods (baked goodspreserves), made and sold on the same farm must contain:- Common name of the product (e.g. chocolate chip cookie)- Net quantity by: (1) weight OR (2) volume - if a liquid (soupOR (3) count but count only applies to buns, rolls, doughnutsand sandwiches; the rest require weight or volume.- Your farms name and address- List of ingredients listed in descending order by weighand must declare all food allergens- Best-before date (required if shelf life is less than 90 days therefore not required on preserves)

Best-before dates are required for foods with a shelf life less than 90 days and provide guidance only on nutrition, tastand quality. Best-before dates can vary because of differpreparation methods, preservatives and storage/display methodHere are two websites with helpful guidelines:http://shelflifeadvice.com/bakery-goods-and-sweets/bakery-goods

http://www.stilltasty.com/searchitems/index/8

Here is an interactive CFIA website showing a cereal boxhttp://www.inspection.gc.ca/english/fssa/labeti/mapcarte.shtml

It is a good way for you to better understand each label component. If you run your mouse over the various parts of the labeinformation boxes appear, illustrating the terms used with eacaspect of labelling.

Ingredients: You will read ingredients of ingredientseveral times in this section. Tis may sound confusing, but isimply means that if you have an ingredient such as chocolatthat is made up of several ingredients (cocoa powder, cocliquor, sugar, soy and lecithin), you need to include those ingredients. Also, because the soy is an allergen, you have to maspecial note of that fact, in the Contains portion of the labe

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A series of practical farm management guides compiled by the Ontario Farm Fresh Marketing Association

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discussed later, because you have to let the consumer knowthat soy (an allergen) is in this product.

2 Nutritional Facts Tables What you dont need to have on prepackaged productsmade and sold from the same farm is Nutritional Facts

ables, unless you are implying a nutritional benet to thisproduct, such as: low-fat muffins, diabetic pies, sugar-freecookies, etc. In this case, you need to substantiate yourclaim that it is sugar-free or low-fat by including a nutritionalfacts table.http://www.inspection.gc.ca/english/fssa/labeti/guide/ch5e.shtml#a5_3is a link to a CFIA website showing what foods andbusinesses are exempt from a Nutritional Facts able. Te

items (f) and particularly (g) are the most important to anon-farm bakery.(f) Foods sold only in the retail establishment where theproduct is prepared and processed from its ingredients,including products made from a pre-mix, when an ingredientother than water is added to the pre-mix;NO E: A Nutritional Facts able is required when only water is added to a pre-mix or when a product is only baked,cooked, etc. on the premises without the addition of otheringredients (e.g. pre-proofed bread).(g) Foods sold only at a road-side stand, craft show, ea

market, fair, farmers market and sugar bush by theindividual who prepared and processed the product.

3 AllergensIt is estimated that 1-2% of the adult population and 5-8%of children are allergic to one or more foods in Canada andthe USA so you will likely have customers with foodallergies and you need to take precautions. An articleexplaining allergens can be found at:http://hc-sc.gc.ca/fn-an/securit/eval/reports-rapports/allergen_paper-evaluation_allergene-01-eng.php#1

Below is a list of allergens that theCFIA say need to belabelled for the consumer:- peanuts, almonds, Brazil nuts, cashews, hazelnuts, maca-damia nuts, pecans, pine nuts, pistachios or walnuts- sesame seeds- wheat, triticale, rye, oats, barley (all contain gluten)- eggs- milk (cows milk is the issue, so milk includes butter,cheese, etc. made from cows milk)- soybeans- crustaceans (list the common name of the crustaceansused)

- shellsh (list the common name of the shellsh used)- sh (list the common name of the sh used)- mustard seeds

- sulphitesIf you use any of these ingredients in your bakery and yo

do not have a good system for maintaining total separation oingredients (including separate equipment and surfaces fpreparation) it is recommended, for your own protection, as weas the consumers, that you include a warning: May conta__________.http://www.inspection.gc.ca/english/fssa/invenq/inform/20070925e.shtmlis a February 2011 statement by CFIA on how May containstatements should be worded.

http://www.inspection.gc.ca/english/fssa/labeti/allerg/allergee.shtmlis a Q&A from the CFIA regarding labelling of food allergeand the use of precautionary May Contain statements.http://www.hc-sc.gc.ca/fn-an/labeletiquet/allergen/project_1220_qa_qr-eng.phpis a link to a Health Canada Q&A website about the newregulations (effective Aug. 4, 2012) to enhance the labelling food allergens, gluten and added sulphites. Current regulationrequire all ingredients and ingredients of ingredients that aallergens to be declared however, new regulations comiinto force August 4, 2012 are more detailed in how declarationmust be made.

Here are the steps you can follow to create an ingredient lithat has ingredients listed by weight and the allergens identieCFIA says that one area of frequent food recalls with smalmanufacturers of jams, preserves and baked goods is impropelisting the ingredients in a food product. One of the morefrequent errors is not listing Ingredients of Ingredients: whean ingredient in the recipe contains its own list of ingredient(e.g. purchased pie shell, chocolate), you must also list theingredients.

EXAMPLE RECIPE:S RAWBERRY RHUBARB CHOCOLA E CREAM PIE

Ingredients:2 cups (500 mL) sliced strawberries1 cup (250 mL) chopped rhubarb1 (9"/23cm) homemade or prepared deep-dish pie shell(contains some allergens that must be listed)1 1/2 cups all-purpose our * (made from wheat, containsgluten)1/2 teaspoon salt *6 tablespoons butter * (made from milk, an allergen)

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page 3 LABELLING A series of practical farm management guides compiled by the Ontario Farm Fresh Marketing Association

4 tablespoons margarine* (on exempt list,explained below ,but contains allergens which must be declared, e.g. milk,soy)

2 to 3 tablespoons ice water1 large egg 1 can (300 mL) sweetened condensed milk *1 tablespoon (15 mL) concentrated lemon juice (oftencontains sulphites, an allergen that must be declared) cup (125 mL) packed brown sugar * cup (125 mL) all-purpose our * cup (50 mL) chopped pecans tsp (1 mL) cinnamon cup (50 mL) butter * (made from milk, an allergen) cup grated dark chocolate (ingredients: cocoa powder,cocoa liquor, soy, sugar, lecithin)STEP ONE Start by determining the weight of the recipesingredients. As the list of ingredients on a food label must bein descending order by weight, a scale is required (dontforget to subtract the container weight).

You will need a scale for the net quantity declarationalso (net quantity of the entire package, e.g. weight of adozen cookies in an overwrap). Tis is one of the require-ments outlined in 1 Mandatory Information describedabove. NOTE : the container (pie plate, pie box, etc.) is notto be included in net quantity weight.STEP TWO From all the ingredients, identify those thatare exempt from the component declarations (listing theindividual ingredients of ingredients).

Tis may seem a bit confusing, but they are saying thatsome products are well enough known that you dont needto list their ingredients (e.g. margarine) but if thatexempted ingredient (margarine) contains an allergen (suchas soy), then you need to list the ingredients and theallergen. Tat is why, in our recipe example above, soy wasincluded in the list of ingredients of margarine.

Ingredients that are exempt are listed in Annex 2-3Ingredients Exempt from Component Declaration of the

Guide o Food Labelling:http://www.inspection.gc.ca/english/fssa/labeti/guide/ch2-1e.shtml#a3

In our recipe example above, the ingredients that areexempt are marked with an asterisk *.STEP THREE For those that are not exempt (not listed in Annex 2-3) and do contain ingredients, those ingredientsmust be listed in your list of ingredients. Dark chocolate isan example of an ingredient that has components and is notone of the foods exempt from component declaration;therefore its list of ingredients would be included.

- With dark chocolate, you would list chocolate (cocoa powdecocoa butter, sugar, salt, soy, natural and articial avours).- With cinnamon although it is not on the list of foods

exempt from component declaration it is likely a singleingredient food so there are no ingredients to list.STEP FOUR Underline all allergens in your recipe (see recipabove ). Choose which method of declaring allergens you prefeither in brackets after the ingredient, such as our (wheamargarine (soy, milk), lemon juice concentrate (sulphites)ORyou can create your entire list of ingredients as required, then the end, add Contains: gluten (wheat), soy, milk, pecansulphites, egg.

Te goal is to ensure the consumer is aware of any of theprimary allergens in your nal food.

Calculating Ingredients by Weight Tis sounds troublesome, but you only have to do it once

for a recipe. Also, it has been suggested that having recipesvolume is not the best way for commercial recipes because 1 cof shortening that someone quickly measured, with an air pockin it, isnt the same as precisely 220g of shortening. So usin

weight should help your staff make the quality of your bakgoods more consistent.

Tere are lots of conversion sites on the web. Here is the onthat seems to consider all the variables. Choose the product yo

want converted in the top box, then the quantity to be converted

before you do the conversion in the two boxes at the bottom:http://www.onlineconversion.com/weight_volume_cooking.htm

For items that you cant nd on this chart, consult:http://www.answers.com

One other issue to consider when converting your volumrecipes (cup, ounces, etc.) is to establish whether your recipeusing U.S. measurements or U.K./Canadian. Here are a fewexamples:1 Canadian uid ounce = 0.96 of a U.S. uid oz.1 Canadian tablespoon = 0.96 of a U.S. tablespoon

1 Canadian teaspoon = 0.72 of a U.S. teaspoon1 Canadian pint = 1.2 U.S. pints.NOTE : Some U.S. measures are smaller and some are larger thatheir Canadian equivalents; that might be another reason fousing weight rather than volume.

See sample of ingredients listed by weight on following page ~

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A series of practical farm management guides compiled by the Ontario Farm Fresh Marketing Association

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(1) 304g sliced strawberries(4) 150g chopped rhubarb

1 (9"/23cm) homemade or prepared deep-dish pie shell(this component is not exempt so ingredients must belisted)158g all-purpose our * (made from wheat, containsgluten)(13) 1.8g salt *83g butter * (made from milk, an allergen)(7) 53g margarine* (on exempt list, but contains allergens which must be declared, e.g. milk or soy)(10) 35g ice water (2.5 tbsp)(8) 50g large egg (2) 279g sweetened condensed milk *(12) 15g concentrated lemon juice ** (bottled lemon juiceoften contains sulphites and must be declared)(6) 106g packed brown sugar *53g all-purpose our *(11) 30g chopped pecans(14) 0.5g cinnamon49g butter *(9) 50g grated dark chocolate (ingredients: cocoa powder,

cocoa butter, sugar, salt, soy, natural & articial avours)Totals:(5) Butter (83g + 49g = 132g (3) Flour (158g + 53g) = 211g

Based on the above recipe, what you need on your label(in descending order by weight) is:Ingredients: strawberries, sweetened condensed milk,our, rhubarb, butter, brown sugar, margarine, egg, darkchocolate (cocoa powder, cocoa butter, sugar, salt, soy, naturaland artical avours), water, pecans, lemon juice fromconcentrate (sulphites), salt, cinnamon.

Contains: gluten (wheat), soy, milk, pecans, sulphites, egg.4 Bilingual Requirements All mandatory label information needs to be in English andFrench, unless it is local products, sold in a local area, in which one official language is the mother tongue of fewerthan 10% of the residents.

It is recommended that you submit your label to CFIA for approval. At time of writing (2011), it is a free serviceand could save you from having to reprint labels if someonends an error. Here is the procedure:

When submitting a label for review, the following is requested

1. Submit a legible draft label, in the most denitive formpossible (preferably a printers proof), containing all mandatoinformation.2. Submit label(s) in exact size and format that will be applied the package (including any pictorial representations). Includcontainer (if possible), dimensions of the container or area of thprincipal display surface with the submission.3. Claims are regulated; they must be true, factual and veriablSubmit information that substantiates label claims, if applicab4. Where applicable, include complete information on produccomposition, method, method of preparation, analytical datsupporting the list of ingredients and nutrition values (if stateon the label).5. Include any applicable promotional and/or advertising materirelating to the product. (CFIC regulations cover both labellinand advertising. You may advertise that you sell apple pies, byou are not likely to be advertising individual sugar-free apppies, so this is not likely to apply to a typical on-farm market6. Include dealer identication (your business name anaddress).

CFIA try to respond within 10-15 working days, but it coulvary, depending upon the complexity of the label.

If you have any questions on labelling, or wish to submitlabel for review, contactCFIA by e-mail:(1) [email protected] OR (2) telephone 1-800-667-2657.Tey are very helpful.

905-841-9278 OntarioFarmFresh.com [email protected]

Review Service & Guidelines:

~ Material provided by Bob Cobbled

We are in the process of creating a series of FRESHfileson a variety of topics to help you in your farm business.If there is any aspect of farm marketingthat you would like to know more about,please get in touch!

A complete set of FRESHfiles can befound on our website @OntarioFarmFresh.com

AN INV ITATION TO OFFMA MEMB ERS:

2011 Ontario Farm Fresh Marketing Association

Documents

Freshfiles - Labelling