freshfiles

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

Consumer Packaging & Labelling Regulations
The federal Food and Drugs Act prohibits the labelling,
packaging, treating, processing, selling or advertising of any
food in a manner that is false, misleading or deceptive to
consumers or is likely to create an erroneous message regarding
the character, value, quantity, composition, merit or safety
of the product. It also prohibits health claims that might
suggest that a food is a treatment, preventative or cure for
specified diseases or health conditions, unless provided for
in the regulations.
Federal responsibility for Canadian food labelling is
shared between Health Canada and the Canadian Food
Inspection Agency (CFIA).
Under the Food and Drugs Act, Health Canada is
responsible for establishing policies and standards relating
to the health, safety, and nutritional quality of food sold in
Canada.
CFIA is responsible for the administration of food
labelling policies related to food labelling, packaging and
advertising, as well as general agri-food and fish labelling
provisions specified in the Canada Agricultural Products Act,
the Meat Inspection Act and the Fish Inspection Act.
Of importance to bakeries is that the CFIA administers
the food-related provisions of the Consumer Packaging and
Labelling Act, which includes basic food label information,
net quantity, metrication and bilingual labelling. Here is a
link to the Department of Justice,Consumer Packaging and
Labelling Regulations:
http://laws-lois.justice.gc.ca/eng/regulations/
C.R.C.%2C_c._417/FullText.html

Regulations Summary
Food labelling comprises 4 areas:
1) Mandatory Information
2) Nutrient Facts Tables
3) Allergens and precautionary allergen statements
(e.g. “May Contain….”)
4) Bilingual Requirements (some exemptions)

LABELLING
1 • Mandatory Information
It is commonly thought that prepackaged baked goods produced
and sold on the same farm are exempt from labelling regulations.
That is not true. All prepackaged prepared foods (baked goods,
preserves), 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 (soup)
OR (3) count — but count only applies to buns, rolls, doughnuts
and sandwiches; the rest require weight or volume.
- Your farm’s name and address
- List of ingredients — listed in descending order — by weight,
and 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 of
less than 90 days and provide guidance only on nutrition, taste
and quality. Best-before dates can vary because of different
preparation methods, preservatives and storage/display methods.
Here are two websites with helpful guidelines:
http://shelflifeadvice.com/bakery-goods-and-sweets/bakerygoods
http://www.stilltasty.com/searchitems/index/8

Here is an interactive CFIA website showing a cereal box:
http://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 label,
information boxes appear, illustrating the terms used with each
aspect of labelling.
Ingredients: You will read “ingredients of ingredients”
several times in this section. This may sound confusing, but it
simply means that if you have an ingredient such as chocolate,
that is made up of several ingredients (cocoa powder, cocoa
liquor, sugar, soy and lecithin), you need to include those ingredients. Also, because the soy is an allergen, you have to make
special note of that fact, in the “Contains” portion of the label
Continued on page 2…

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Ontario Farm Fresh Marketing Association (OFFMA) | 2002 Vandorf Sideroad | Aurora Ontario L4G 7B9 CANADA
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LABELLING

page 2

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

discussed later, because you have to let the consumer know
that soy (an allergen) is in this product.
2 • Nutritional Facts Tables
What you don’t need to have on prepackaged products
made and sold from the same farm is Nutritional Facts
Tables, unless you are implying a nutritional benefit to this
product, such as: low-fat muffins, diabetic pies, sugar-free
cookies, etc. In this case, you need to substantiate your
claim that it is sugar-free or low-fat by including a nutritional
facts table.

- shellfish (list the common name of the shellfish used)
- fish (list the common name of the fish used)
- mustard seeds
- sulphites
If you use any of these ingredients in your bakery and you
do not have a good system for maintaining total separation of
ingredients (including separate equipment and surfaces for
preparation) it is recommended, for your own protection, as well
as the consumer’s, that you include a warning: “May contain
__________.”

http://www.inspection.gc.ca/english/fssa/labeti/guide/ch5e.s
html#a5_3

http://www.inspection.gc.ca/english/fssa/invenq/inform/200709
25e.shtml

…is a link to a CFIA website showing what foods and
businesses are exempt from a Nutritional Facts Table. The
items (f ) and particularly (g) are the most important to an
on-farm bakery.
(f ) Foods sold only in the retail establishment where the
product is prepared and processed from its ingredients,
including products made from a pre-mix, when an ingredient
other than water is added to the pre-mix;
NOTE: A Nutritional Facts Table 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 other
ingredients (e.g. pre-proofed bread).
(g) Foods sold only at a road-side stand, craft show, flea
market, fair, farmers’ market and sugar bush by the
individual who prepared and processed the product.

…is a February 2011 statement by CFIA on how “May contain”
statements should be worded.

3 • Allergens
It is estimated that 1-2% of the adult population and 5-8%
of children are allergic to one or more foods in Canada and
the USA — so you will likely have customers with food
allergies and you need to take precautions. An article
explaining 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 the CFIA say need to be
labelled for the consumer:
- peanuts, almonds, Brazil nuts, cashews, hazelnuts, macadamia nuts, pecans, pine nuts, pistachios or walnuts
- sesame seeds
- wheat, triticale, rye, oats, barley (all contain gluten)
- eggs
- milk (cow’s milk is the issue, so milk includes butter,
cheese, etc. made from cow’s milk)
- soybeans
- crustaceans (list the common name of the crustaceans
used)

http://www.inspection.gc.ca/english/fssa/labeti/allerg/allergee.sht
ml

…is a Q&A from the CFIA regarding labelling of food allergens
and the use of precautionary “May Contain” statements.
http://www.hc-sc.gc.ca/fn-an/labeletiquet/allergen/project_1220
_qa_qr-eng.php

…is a link to a Health Canada Q&A website about the new
regulations (effective Aug. 4, 2012) to enhance the labelling of
food allergens, gluten and added sulphites. Current regulations
require all ingredients and “ingredients of ingredients” that are
allergens to be declared — however, new regulations coming
into force August 4, 2012 are more detailed in how declarations
must be made.
Here are the steps you can follow to create an ingredient list
that has ingredients listed by weight and the allergens identified.
CFIA says that one area of frequent food recalls with smaller
manufacturers of jams, preserves and baked goods is improperly
listing the ingredients in a food product. One of the more
frequent errors is not listing “Ingredients of Ingredients”: when
an ingredient in the recipe contains its own list of ingredients,
(e.g. purchased pie shell, chocolate), you must also list their
ingredients.
EXAMPLE RECIPE:
STRAWBERRY RHUBARB CHOCOLATE CREAM PIE

Ingredients:
2 cups (500 mL) sliced strawberries
1 cup (250 mL) chopped rhubarb
1 (9"/23cm) homemade or prepared deep-dish pie shell
(contains some allergens that must be listed)
1 1/2 cups all-purpose flour * (made from wheat, contains
gluten)
1/2 teaspoon salt *
6 tablespoons butter * (made from milk, an allergen)
Continued on page 3…

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 water
1 large egg
1 can (300 mL) sweetened condensed milk *
1 tablespoon (15 mL) concentrated lemon juice (often
contains sulphites, an allergen that must be declared)
½ cup (125 mL) packed brown sugar *
½ cup (125 mL) all-purpose flour *
¼ cup (50 mL) chopped pecans
¼ tsp (1 mL) cinnamon
¼ cup (50 mL) butter * (made from milk, an allergen)
½ cup grated dark chocolate (ingredients: cocoa powder,
cocoa liquor, soy, sugar, lecithin)
STEP ONE — Start by determining the weight of the recipe’s
ingredients. As the list of ingredients on a food label must be
in descending order by weight, a scale is required (don’t
forget to subtract the container weight).
You will need a scale for the “net quantity” declaration
also (net quantity of the entire package, e.g. weight of a
dozen cookies in an overwrap). This is one of the requirements outlined in “1 – Mandatory Information” described
above. NOTE: the container (pie plate, pie box, etc.) is not
to be included in “net quantity” weight.
STEP TWO — From all the ingredients, identify those that
are exempt from the component declarations (listing the
individual ingredients of ingredients).
This may seem a bit confusing, but they are saying that
some products are well enough known that you don’t need
to list their ingredients (e.g. margarine) — but if that
exempted ingredient (margarine) contains an allergen (such
as soy), then you need to list the ingredients and the
allergen. That is why, in our recipe example above, soy was
included in the list of ingredients of margarine.
Ingredients that are exempt are listed in Annex 2-3
“Ingredients Exempt from Component Declaration” of the
Guide To Food Labelling:
http://www.inspection.gc.ca/english/fssa/labeti/guide/ch21e.shtml#a3

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

- With dark chocolate, you would list chocolate (cocoa powder,
cocoa butter, sugar, salt, soy, natural and artificial flavours).
- 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 recipe
above). Choose which method of declaring allergens you prefer:
either in brackets after the ingredient, such as flour (wheat)
margarine (soy, milk), lemon juice concentrate (sulphites) OR
you can create your entire list of ingredients as required, then at
the end, add “Contains: gluten (wheat), soy, milk, pecans,
sulphites, egg”.
The goal is to ensure the consumer is aware of any of the
primary allergens in your final food.
Calculating Ingredients by Weight
This sounds troublesome, but you only have to do it once
for a recipe. Also, it has been suggested that having recipes in
volume is not the best way for commercial recipes because 1 cup
of shortening that someone quickly measured, with an air pocket
in it, isn’t the same as precisely 220g of shortening. So using
weight should help your staff make the quality of your baked
goods more consistent.
There are lots of conversion sites on the web. Here is the one
that seems to consider all the variables. Choose the product you
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 can’t find on this chart, consult:
http://www.answers.com

One other issue to consider when converting your “volume”
recipes (cup, ounces, etc.) is to establish whether your recipe is
using U.S. measurements or U.K./Canadian. Here are a few
examples:
1 Canadian fluid ounce = 0.96 of a U.S. fluid oz.
1 Canadian tablespoon = 0.96 of a U.S. tablespoon
1 Canadian teaspoon = 0.72 of a U.S. teaspoon
1 Canadian pint = 1.2 U.S. pints.
NOTE: Some U.S. measures are smaller and some are larger than
their Canadian equivalents; that might be another reason for
using weight rather than volume.
See sample of ingredients listed by weight
on following page ~

Continued on page 4…

LABELLING

page 4

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

(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 be
listed)
158g all-purpose flour * (made from wheat, contains
gluten)
(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 juice
often contains sulphites and must be declared)
(6) 106g packed brown sugar *
53g all-purpose flour *
(11) 30g chopped pecans
(14) 0.5g cinnamon
49g butter *
(9) 50g grated dark chocolate (ingredients: cocoa powder,
cocoa butter, sugar, salt, soy, natural & artificial flavours)
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,
flour, rhubarb, butter, brown sugar, margarine, egg, dark
chocolate (cocoa powder, cocoa butter, sugar, salt, soy, natural
and artifical flavours), water, pecans, lemon juice from
concentrate (sulphites), salt, cinnamon.
Contains: gluten (wheat), soy, milk, pecans, sulphites, egg.
4 • Bilingual Requirements
All mandatory label information needs to be in English and
French, unless it is local products, sold in a local area, in
which one official language is the mother tongue of fewer
than 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 service
and could save you from having to reprint labels if someone
finds an error. Here is the procedure:

905-841-9278

Review Service & Guidelines:
When submitting a label for review, the following is requested:
1. Submit a legible draft label, in the most definitive form
possible (preferably a printer’s proof ), containing all mandatory
information.
2. Submit label(s) in exact size and format that will be applied to
the package (including any pictorial representations). Include
container (if possible), dimensions of the container or area of the
principal display surface with the submission.
3. Claims are regulated; they must be true, factual and verifiable.
Submit information that substantiates label claims, if applicable.
4. Where applicable, include complete information on product
composition, method, method of preparation, analytical data
supporting the list of ingredients and nutrition values (if stated
on the label).
5. Include any applicable promotional and/or advertising material
relating to the product. (CFIC regulations cover both labelling
and advertising. You may advertise that you sell apple pies, but
you are not likely to be advertising individual “sugar-free apple
pies”, so this is not likely to apply to a typical on-farm market.)
6. Include dealer identification (your business name and
address).
CFIA try to respond within 10-15 working days, but it could
vary, depending upon the complexity of the label.
If you have any questions on labelling, or wish to submit a
label for review, contact CFIA by e-mail:
(1) labelwindow@inspection.gc.ca
OR (2) telephone 1-800-667-2657.
They are very helpful.
~ Material provided by Bob Cobbledick
© 2011 Ontario Farm Fresh Marketing Association

A N I N V I TAT I O N TO O F F M A M E M B E R S :
We are in the process of creating a series of FRESHfiles
on a variety of topics to help you in your farm business.
If there is any aspect of farm marketing
that you would like to know more about,
please get in touch!
A complete set of FRESHfiles can be
found on our website @
OntarioFarmFresh.com

OntarioFarmFresh.com

info@ontariofarmfresh.com