The Making of the Bilingual Canadian Nutrition Facts Labelling Tool

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• Mathilde
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Ever since I created an online tool to make nutrition facts panels for the US, I have received numerous requests to create a similar one for Canada. I took finally the time to create one the last couple of weeks.

The first step to make a nutrition facts labelling tool was to find current and reliable information on its format. After some research, I found the 1021 pages of the Food and Drug Regulations and set about reading it.

About 100 pages into it, I was ready to give up. Here is a random example of what these 100 pages look like:

Despite subsections (2) and (3), if the prepackaged product is sold only in the retail establishment where the product is packaged, is labelled by means of a sticker and has an available display surface of 200 cm2 or more, its nutrition facts table shall be set out in a version that is listed in column 1 of items 1 to 3 of Parts 1 and 2 of the table to this section, without regard to any condition specified in column 2.

Fortunately, I was then able to find a summary for the industry with the information written in plain English, without the references to sections, subsections, tables, parts, columns or items.

Here is the final result, the Canadian bilingual nutrition facts labelling tool:

Make your Bilingual Nutrition Facts Label

What the Canadian bilingual nutrition facts labelling tool does

The labelling tool makes sure that you input all the required core nutrition information and allows you to input the additional nutritional information of your choice.

The additional information is in most case optional, but may be mandatory in some cases, for example when some nutrients or sugar alcohol have been added to the food or when some nutritional representation have been made on the label or in an advertisement about the food. You are responsible for checking the rules and make sure to select all the mandatory information from the additional information list.

The core nutrition information is

• serving of stated size
• energy value in Cal
• amount of fat
• amount of saturated fatty acids
• amount of trans fatty acids
• sum of saturated fatty acids and trans fatty acids
• amount of cholesterol
• amount of sodium
• amounf of carbohydrate
• amount of fibre
• amount of sugars
• amount of protein
• vitamin A
• vitamin C
• calcium
• iron

The additional nutritional information is

• number of servings per container
• energy value in kJ
• energy value from fat
• energy value from the sum of saturated and trans fatty acids
• amount of polyunsaturated fatty acids
• amount of omega-6 polyunsaturated fatty acids
• amount of omega-3 polyunsaturated fatty acids
• amount of monounsaturated fatty acids
• amount of potassium
• amount of soluble fibre
• amount of insoluble fibre
• amount of sugar alcohol
• amount of starch
• amount of vitamin D
• amount of vitamin E
• amount of vitamin K
• amount of thiamine
• amount of riboflavin
• amount of niacin
• amount of vitamin B6
• amount of folate
• amount of vitamin B12
• amount of biotin
• amount of pantothenic acid
• amount of phosphorus
• amount of iodide
• amount of magnesium
• amount of zinc
• amount of selenium
• amount of copper
• amount of manganese
• amount of chromium
• amount of molybdenum
• amount of chloride
• basis of the percent daily values

The nutritional information corresponds to a given serving size. A serving size is a quantity of food that can be reasonably consumed at a single eating occasion. The Food and Drug Regulations provide a table with the serving sizes of varied food. Also, the serving size must be expressed in a consumer-friendly measure and in a metric unit. Make sure to check the information on the serving size and its measures in order for your label to conform to the rules.

The Food and Drug Regulations sets complex rules for the rounding of values in the nutrition facts label. The labelling tool make sure that those rules are followed and that the number are correctly rounded. The percent of daily value are also automatically computed from the values you input.

What the Canadian bilingual nutrition facts labelling tool does not do

The labelling tool only creates bilingual labels in standard format. It is not appropriate for food that require a different format, like

• simplified formats,
• prepackaged foods for children under two years of age,
• prepackaged foods for use in manufacturing other foods,
• foods for commercial and industrial enterprises or institutions,
• small packages (< 100cm2).

Also, the labelling tool doesn’t make any check of the consistency of your input. For example, if you choose to include the energy from fat, you are responsible to make sure that it corresponds to the fat content you have declared.

How to get the accurate nutrient values for your food

You have three possible approaches:

• Laboratory Analysis
  For accurate results of laboratory analysis, it has to be done on several samples to account for natural variations of nutrient values.
• Calculation
  In the case of calculation, you can use nutritional information that is specific to the ingredients you are using as base of your calculations or use generic nutritional information from the CNF or the USDA database for standard reference. Also, results from calculation need to be corrected for nutrient loss or changes in the content of fat or water during processing.
• A mixture of both
  You can mix both methods by analysis of a base recipe in laboratory and then adjusting the values for variations of this recipe by calculation. You can also use a method for a set of nutrient and another one for another set.

The Canadian food inspection agency publishes a very useful guide that compares all three methods.

How to get compliant nutrient values for your food

You may wonder why I write a separate section for getting accurate nutrient values and compliant values. Shouldn’t they be same? Actually, no, those are different things. You may have an accurate value that is not compliant – and vice versa.

First, there are natural variations in the nutrient content of food – due to the season, the provenance, the storage, variations on cooking time, etc. An accurate value is always an average of all the variations. On the other hand, a nutrient value is compliant if it passes the compliance test.

This test requires basically that the nutrient values from a random lot of your food are no more than 20% smaller than the declared value for “good” nutrients and no more than 20% larger than the declared value for “bad” nutrients. Added vitamins and minerals have a stronger requirement and their declared values should not be larger than the value measured.

The “good” nutrients are protein, polyunsaturated fatty acids, omega-3 fatty acids, omega-6 fatty acids, monounsaturated fatty acids, carbohydrates, starch, fibre, soluble fibre, insoluble fibre, potassium, vitamins and minerals. The “bad” ones are calories, fat, saturated fat, trans fat, cholesterol, sodium, sugars and sugar alcohols.

As variations in nutrients can be larger than the allowed 20%, you have to decrease the declared values of the good nutrients, and increase the declared values of the bad ones to insure that a random lot is compliant. The amount by which the values have to be increased or decreased depends on the variability of each nutrient. The USDA publishes a guide that explain how to compute the correction factors.

Do you need a nutrition facts label for your products?

After reading all this, you may wish that you don’t have to add a nutrition facts panel to your food product. And maybe you don’t.

If you are prepackaging food, it is likely that you will need a nutrition facts label that follows the Food and Drug Regulations. Certain foods are however exempt from having a nutrition facts label, and other are prohibited from having one.

Ingredient list and allergen declaration

The labelling tool allows you also to create an ingredient list and an allergen declaration.

For the ingredient list, you have to type the ingredients in descending order of proportion by weight, as determined before they are combined to make the food. You are responsible to list the required ingredients in the correct order. Make sure to check the rules too.

You may not have to include an allergen declaration if all the allergens, gluten sources and sulphites are already included in the ingredient list in a format that satisfies the regulations. If however you select to include one, you have to select all the sources of food allergen, gluten and sulphite, even those already included in the ingredient list.

Make your Bilingual Nutrition Facts Label