In a move towards promoting healthier food choices, Canada has introduced new regulations regarding Front-of-Package (FOP) nutrition symbol labelling. The regulation is aimed at aiding consumers in identifying foods high in saturated fat, sugars, and sodium.

These regulations can have significant implications for food manufacturers, retailers, and importers that intend to sell food products in Canada. Let’s break it down together and make sure you’re fully prepared for this new requirement.

What is the FOP Labeling?

The Front of Pack Labelling requirements is a new initiative by the CFIA designed to provide clearer nutritional information on the front of packaged food items. This move aims to help our consumers make healthier food choices at a glance by highlighting key nutritional elements directly on the packaging.

Think of it as a quick and easy way for your customers to see the most important nutritional information without having to flip the package around.

But… it may or may not help you as the manufacturer. 

When is FOP Labelling Effective?

As food manufacturers, you will need to comply with the labels starting Jan 1, 2026. Currently, we are entering a transition phase for the FOP labelling requirements.

Perhaps the bigger question is when do you need to start changing your labels to meet this requirement? 

It depends on your strategies but please note that the products imported, manufactured, or packaged before Dec 31, 2025 can still be sold until inventory is depleted.

Food labels aren’t something that we can change the next day. The earlier you think and manage the expectation for FOP changes, the better. 

Being Aware of Nutrient Thresholds and %DV Limits

Here’s the nitty-gritty of the nutrient thresholds you’ll need to keep in mind. The FOP symbols are required for foods that exceed certain thresholds for saturated fats, sugars, and sodium. Specifically:

• Saturated Fat: More than 15% of the Daily Value (DV) per serving.
• Sugars: More than 15% of the DV per serving.
• Sodium: More than 15% of the DV per serving.

For foods with small serving sizes such as ≤ 30 grams or ≤ 30 mL, the threshold is even stricter at 10% DV. These percentages are designed to highlight foods that have significant amounts of these nutrients, nudging your consumers towards healthier choices.

Are there any Exemptions for FOP?

Yes, there are some exemptions to the Front of Pack Labelling regulations that you can take advantage of. Here’s the scoop:

• Full Exemptions: Certain foods are completely exempt from the FOP labelling requirements. This includes:
  • Fresh fruits and vegetables.
  • Raw, single-ingredient meat, poultry, and fish.
  • Foods that are not prepackaged for direct sale to consumers.
  • Foods in very small packages (less than 15 square centimetres of available display surface).
• Conditional Exemptions: Some foods might be exempt under specific conditions. For example:
  • Foods that are intended solely for children under two years of age.
  • Foods sold in packages smaller than a certain size may be exempt if the surface area is too small to display the symbols effectively.
  • Foods with very small serving sizes (≤ 30 grams or ≤ 30 mL) may be subject to different threshold limits.

What Do You Need to Do to ensure ccompliance ?

What are the next steps you need to do to ensure compliance? Here’s a quick roadmap you can follow:

1. Review the Guidelines: Start by thoroughly reviewing the CFIA’s detailed guidelines to understand all requirements and exemptions.
   
2. Assess Your Products: Identity which of your products will need the new FOP labeling and which ones are exempt.
3. Plan Your Labels: Work with your design team to incorporate the new FOP nutrition symbols. Make sure these symbols are prominent and easily readable.
4. Update Packaging: Coordinate with your packaging suppliers to ensure the new designs are ready for production well before the deadline.
5. Train Your Team: Ensure that your marketing, compliance, and production teams are fully aware of the new requirements and understand their roles in the transition.

What are some of the questions you must ask yourself when it comes to FOP? 

FOP labelling may come with a risk that the consumer wouldn’t choose other food products over your products due to the obvious labels for high sugar, fat, salt or a combination of these. 

If this is a concern to you, you can do a few things including reviewing your recipe and serving size. 

Reevaluate Recipe for FOP labelling

Here are the opportunities to reevaluate your recipe and serving size to ensure you do not need to provide prominent labelling highlights such as the FOP label.

You must declare the nutrient content in the front label packaging when the sugar, saturated fats and sodium as considered exceed 15 % of the Daily Value. By reformulating or reviewing your serving size, you have the opportunity to adjust the % DV for this content to make sure they go below 15% DV. 

Additionally, educating consumers regarding your products and nutrient sources can help consumers understand the reasons for the nutrient density in your products. 

Even if you have to declare certain nutrients in the front label packaging, it is not the end of your products and brands. You need to plan to meet the expectations and monitor consumer demand when you launch your new product labels. 

FOP Labelling as the Brand Positioning Strategy

Implementing the new FOP labelling might seem like a daunting task, but it also presents an excellent opportunity for your business. By adopting these labels early, you can position your brand as a leader in transparency and health-consciousness, building trust with consumers who are increasingly making informed choices about their food.

This proactive approach can help you stay ahead of regulatory deadlines and also enhance your brand’s reputation and loyalty in the marketplace.

Navigating regulatory changes can be challenging, but with careful planning and a proactive mindset, you can turn this into a strategic advantage. Think of this as your opportunity to shine and show your commitment to your customers’ well-being.

References:

Health Canada. (2023, May). Front-of-package nutrition symbol labelling guide for industry. Government of Canada. https://www.canada.ca/en/health-canada/services/food-nutrition/legislation-guidelines/guidance-documents/front-package-nutrition-symbol-labelling-industry.html