Notice of proposal to update the nutrition labelling: Table of reference amounts for food (NOP/ADP-QRA-2023-2)

December 21, 2023

Background

Health Canada's Food Directorate is proposing three amendments to the Table of Reference Amounts for Food (TRA) based on stakeholder feedback, consumption data, market trends, and to address identified gaps for specific food categories.

The TRA sets out reference amounts for different food categories.

Reference amounts:

The TRA also provides detailed instructions on how to determine and declare the serving size for each food.

Proposed changes and rationale

Add new serving size instructions for very high fibre cereals (C.3)

Based on stakeholder feedback and market analysis, Health Canada is proposing to add new serving size instructions in column 3A and B for very high fibre cereals in item C.3 of the TRA. The resulting serving size for these products in the NFt would be closer to the amount typically consumed and contain a more realistic amount of fibre. As for all ready-to-eat breakfast cereals in categories C.2, C.3 and C.4 of the TRA, the serving size and nutrition information declared in the NFt is currently based on "1 cup" and the weight of 1 cup in grams. This approach was introduced as part of the 2016 nutrition labelling changes to help consumers compare different cereals. It was determined that a consistent serving size of 1 cup is easier to visualize, given the varying density across breakfast cereal categories. However, due to density of some very high fibre cereals, a serving size of 1 cup may correspond to a weight that is well above the reference amount and in some cases, a large fibre declaration in the NFt that is not reflective of the amount of fibre typically consumed in a sitting.

Proposal for updated item C.3
Item Column 1 Column 2 Column 3
Product Category Reference Amount (RA) A. Criteria to Determine the Serving of Stated Size for Multiple-Serving Prepackaged Products B. Units for Expressing the Serving of Stated Size for Multiple-Serving Prepackaged Products
HM (MM)
C.3 Ready-to-eat breakfast cereals, puffed and coated, flaked, extruded, without fruit or nuts (weighing 20 g to 42 g per 250 mL), very high fibre cereals (with 28 g or more fibre per 100 g) 30 g

Ready-to-eat breakfast cereals, puffed and coated, flaked, extruded, without fruit or nuts (weighing 20 g to 42 g per 250 mL):

  • HM: 1 cup
  • MM: the weight of the HM in grams
1 cup (# g)

Very high fibre cereals (with 28 g or more fibre per 100 g):

  • MM: RA
  • HM: fraction of a cup closest in weight in grams to the RA
fraction cup (30 g)

Package of multiple, individually prepackaged units, where one unit weighs either 50% to 200% of the RA, or more than 200% of the RA but can reasonably be consumed by one person at a single eating occasion:

  • HM: one prepackaged unit
  • MM: the weight of the HM in grams
1 unit (# g)

Add a new reference amount and corresponding serving size instructions for nutritional yeast (M.17)

Based on market trends and stakeholder feedback, Health Canada is proposing a new reference amount category (item M.17) and corresponding serving size instructions for nutritional yeast. This update will provide clearer guidance on this food category, which is not currently captured in the TRA.

Proposal for new item M.17
Item Column 1 Column 2 Column 3
Product Category Reference Amount (RA) A. Criteria to Determine the Serving of Stated Size for Multiple-Serving Prepackaged Products B. Units for Expressing the Serving of Stated Size for Multiple-Serving Prepackaged Products
HM (MM)
M.17 Nutritional yeast 5 g
  • MM: RA
  • HM: number of teaspoons or tablespoons closest in weight in grams to the RA
# tsp (5 g)
# tbsp (5 g)

Change the reference amount for fondue cooking broths (T.2)

Based on stakeholder feedback, Health Canada is proposing to change the reference amount for fondue cooking broths to 15 mL. This would be accomplished by removing fondue cooking broths as an example in item T.1 of the TRA, and creating a new item, T.2, for fondue cooking broths. Fondue cooking broths are currently captured in the All varieties of soups category (T.1) of the TRA and have a reference amount of 250 mL. However, fondue cooking broths are typically used as a cooking medium for meats, vegetables, etc., and are consumed in small quantities as a result.

Proposal for updated item T.1 and new item T.2

Item

Column 1 Column 2 Column 3
Product Category Reference Amount (RA) A. Criteria to Determine the Serving of Stated Size for Multiple-Serving Prepackaged Products B. Units for Expressing the Serving of Stated Size for Multiple-Serving Prepackaged Products
HM (MM)
T.1 All varieties of soup, including bouillon and broth 250 mL

Ready to serve:

  • MM: RA
  • HM: 1 cup
1 cup (250 mL)
Amount to make 250 mL final product
  • MM: amount in grams or millilitres needed to prepare RA
  • HM: the number of cubes, tablespoons or fraction of a cup or of the package to prepare the RA (according to directions for use)

# cubes (# g)
# tbsp (# g)
# tbsp (# mL)
fraction cup (# g)
fraction cup (# mL)
fraction package (# g)
fraction package (# mL)

Package of multiple, individually prepackaged units, where one unit prepares 50% to 200% of the RA, or more than 200% of the RA but can reasonably be consumed by one person at a single eating occasion:

  • HM: one prepackaged unit
  • MM: the weight of the HM in grams
1 unit (# g)
T.2 Fondue cooking broths 15 mL
  • MM: RA
  • HM: 1 tablespoon
1 tbsp (15 mL)

Nutrition labelling considerations

Updating the TRA will have nutrition labelling implications for very high fibre cereal, nutritional yeast and fondue cooking broth. The changes may affect the serving size declaration and the information declared in the NFt. Since claim eligibility is assessed against both the serving of stated size and the RA, the proposed modifications may have an impact on the ability to make certain claims. Reference amounts also factor into the requirements for the new front-of-package nutrition symbols.

As such, a transition period will be provided, described below, to allow time for regulated parties to make the necessary changes to their labels.

Implementation and enforcement

The proposed changes will come into effect the day on which the Notice of Modification is published on Health Canada's website. Given the nature of the proposed changes, Health Canada is proposing to give industry until January 1, 2026 to implement the changes. During this time, the updated TRA and the previous versions of the TRA would apply (2016 and 2022).

The proposed changes are being put forward at this time to provide industry time to make the necessary changes to their labels while aligning with a compliance date under the joint Health Canada and Canadian Food Inspection Agency Food Labelling Coordination policy. This policy was developed, in part, to provide greater predictability with respect to the compliance dates for changes to food labelling requirements and establishes compliance date options for food labelling requirements at a two-year interval, beginning on January 1, 2026. The compliance date of January 1, 2026 also aligns with the compliance date established for related nutrition labelling updates, including the front-of-package nutrition labelling regulations published on July 20, 2022 and other updates to the TRA published on November 24, 2022.

The Canadian Food Inspection Agency is responsible for the enforcement of the Food and Drugs Act and its associated regulations with respect to foods.

Public comments and contact Information

Health Canada's Food Directorate is committed to reviewing any new information relating to this proposal. Interested persons wishing to submit comments or any inquiries on this proposal may do so electronically by February 28, 2024, 70 days from the date of this posting. All such submissions must use the words "Table of Reference Amounts for Food (NOP/ADP-QRA-2023-2)" in the subject line of the e-mail and be addressed to:

Bureau of Nutritional Sciences, Food Directorate
Health Products and Food Branch, Heath Canada
251 Sir Frederick Banting Driveway
Mail stop 2203E
Ottawa, ON
K1A 0K9

E-mail: nut.labelling-etiquetage@hc-sc.gc.ca

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