Food Fax

March 2003

Science meets Compliance: The New Canadian Nutrition Facts Panel
By Carol T. Culhane, P.H.Ec. MBA

Canada's New Nutrition Facts
On January 1st of this year, Health Canada announced new legislation that will mandate nutrition information on most pre-packaged foods. Declaration of the values of several nutrients will be required, there are a few changes to nutrient content claims, and for the first time, diet-related health claims will be permitted providing specific conditions are met. Manufacturers have until December 12, 2005 to comply.

Not all Declared Values are Equal
Results from analytical tests used to determine nutrient values could easily result in a wide range of difference due to three sources of variability.

Natural Variability in which Mother Nature herself does not create the same level of Vitamin C in each apple from every bushel. Human Nature plays a further hand; Lot Variability arises, for example, when diverse manufacturing conditions result in differing amounts of Vitamin C from separate batches of apple juice.

Method Variability notes the range in laboratory data due solely to the use of different analytical methods. For instance, recognized procedures for each of the following nutrients were found to generate these ranges of variability: Total fat: 3 to 16%; Saturated fatty acids: 3 to 21%; Dietary fibre: 4 to 18%; Protein: 1 to 14%.

Can you see where we're heading? Adding natural variability with lot and method variability has shown to generate differences in nutrient values by as much as 30%!

Who's at Stake and How?
A huge scientific challenge presents itself, that of ensuring the declared nutrient values are as accurate and reproducible as possible. There are three groups of stakeholders involved, each with related but different requirements:

  1. The Canadian Food Inspection Agency (CFIA) the governmental enforcement arm has developed a matrix of compliance measures that reconciles the variances and sets analytical standards.
  2. The food manufacturer requires direction to assure that declared nutrient values would not be invalidated by some unforeseen variability resulting in a judgment of non-compliance.
  3. The consumer has the right to unquestioningly believe that declared nutrient values accurately represent the product.

Strategies for Food Manufacturers
First, select only those service providers who are familiar with the wide scope of hazards and who therefore conduct only analyses that are consistent with the CFIA's compliance measures.

Second, take a moment to cast a fresh look (in some cases a first look) at the nutrient profile of your products. Consult with marketers, product developers and nutritionists (see web-sites below) to reveal unforeseen strengths that will capitalize upon marketplace opportunities in existing or new sectors. Or, consider product re-formulation and re-position on a nutrition platform.FF

Sources of Assistance
For product development and nutrient analysis advice, visit Treloar Product Development:
For marketing and nutrition profile advice, visit our web-site:
For all aspects of the new labelling legislation see:

To view the entire legislative document visit:

2003 International Food Focus Ltd., 211 Carlton Street, East Office,
Toronto, ON M5A 2K9
T: 416-924-3266 F: 416-924-2726

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