The goal is to enhance coordination between the departments and make the food labelling change process more predictable. Implementing these changes would reduce the cost needed to make multiple changes required by each governing body at separate intervals. The alignment of requirements will make things more efficient and cost-effective for the industry to implement.
The essential components of this project are:
- Establishing a process for interdepartmental food labelling changes
- Establishing predictable (2-year) compliance dates
Consultation
Based on consultation from February to April 2021, comments were received from 32 parties. The summary is available for the public at the official website of Health Canada.
USA
The USA currently uses a 2-year (1-3 year) transition period for these types of changes. The US FDA and USDA align and publish new rules that culminate in a two-year compliance window. This timeline allows the industry to make changes and use up current inventory. Currently, the USA is the only country with a published labelling cycle for foods.
Scope
Regulatory amendments that do not initiate a label change would be considered out of scope for this program. Business decisions to update labels vs. government-required updates would be the deciding factor here.
Compliance Dates
The compliance date would be the date of registration. Two-year intervals for label changes will start in January 2026. This will align with US rules. Product owners are responsible for ensuring their food products meet regulatory requirements including labelling. Health Canada and the CFIA will continue using their risk-based approach to product oversight.
Transition Period
Transition periods will range from 1-3 years and will be individually tailored based on the extent of the change required with any new regulatory requirement. This piece will be built into the consultation period of any new/proposed regulation that requires food labelling changes.
For predictability purposes, the minimum transition time will be 2 years, unless there is a safety concern. Any complicated or multi-level changes brought on by regulatory requirements/updates may have multiple deadlines, these will be communicated within the proposal/consultation for each regulatory revision.
Exceptions
Areas or items that are detrimental to human risk will be assigned a different timeline. As these label updates are of greater concern shorter update timelines would likely be assigned to allow shift revisions and prevent injury/harm.
Regulatory Development
Updates to new policies and guidance documents will follow this new clear approach. This establishes an open path for aligned label changes at predictable intervals. Scope, complexity, and cost are all factored into new consultations. Long intervals limit flexibility for factors like scope and complexity.
Further Assistance
For any questions regarding this policy, any food labelling needs or help with product registration/classification that you may have, please reach out to our team of specialists!
