{"id":1526,"date":"2015-04-02T10:12:06","date_gmt":"2015-04-02T14:12:06","guid":{"rendered":"https:\/\/acclabel.com\/?p=1526"},"modified":"2015-04-07T15:55:48","modified_gmt":"2015-04-07T19:55:48","slug":"changements-reglementaires-proposes-relatifs-au-tableau-valeur-nutritive","status":"publish","type":"post","link":"https:\/\/acclabel.com\/en\/changements-reglementaires-proposes-relatifs-au-tableau-valeur-nutritive\/","title":{"rendered":"Proposed Regulatory Modifications to the Nutrition Facts Table"},"content":{"rendered":"

After having conducted a series of consultations with Canadian consumers on ways to improve nutritional labelling on food packaging, Health Canada undertook a broad review of the food labelling regulations. Several regulatory updates are proposed to enhance nutritional labelling, as well as the declaration of ingredients, allergens and bio-active compounds added to food (e.g. caffeine).
<\/strong><\/p>\n

What to Expect Regarding the Display of the Nutrition Facts Table?<\/strong><\/p>\n

This article describes the modifications proposed by Health Canada with respect to the presentation of the Nutrition Facts table. Regulatory modifications related to elements within the Nutrition Facts table (declared serving size, nutrients, daily values) and modifications related to the ingredient and allergen declarations will be discussed in separate articles.<\/p>\n

The figure below illustrates the current Nutrition Facts table versus the proposed new version. It is followed by a commentary of the new features, as perceived by Eurofins\u2019s nutritionists and expert advisors in food labelling.<\/p>\n

Figure 1 – Nutrition Facts Table <\/strong>(NFT) \u2013 Current Model versus New Proposed Model\u00a0<\/strong><\/p>\n\n\n\n\n
\u00a0Current Model
<\/strong>(Standard Bilingual NFT \u2013 format 3.1)<\/td>\n		\u00a0<\/td>\n\u00a0Proposed Model<\/strong><\/td>\n<\/tr>\n
\"Current<\/td>\n\u00a0<\/td>\n\n

\"Proposed<\/p>\n

\"Caffeine<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\u00a0What do Eurofins\u2019s nutritionists think about the proposed regulatory changes?<\/strong><\/h2>\n

Overall, the changes proposed by Health Canada should make the NFT easier to understand for the consumer. The proposed table contains more information and is visually better organized. The inclusion of the added sugar content is still uncertain. Eurofins\u2019s nutritionists believe this information may help consumers select foods containing less refined sugars. However, Eurofins nutritionists foresee challenges for food manufacturers in obtaining the added sugar content of certain ingredients and therefore of finished products.<\/p>\n

The table below describes the pros and cons of each of the Nutrition Facts table display feature that Health Canada proposes to change. The table also includes the opinions of Eurofins\u2019s expert advisors.<\/p>\n

Figure 2\u00a0 – Advantages and Inconveniences of the Various Display Features Proposed for the New Canadian Nutrition Facts Table<\/strong><\/p>\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
\n

Proposed Feature\u00a0<\/strong><\/span><\/h3>\n<\/td>\n

\n

Advantages<\/strong>\u00a0<\/span><\/h3>\n<\/td>\n

\n

Inconveniences<\/strong><\/span><\/h3>\n<\/td>\n

\n

Opinion from
ACC<\/strong>\u00a0Label\u2019s Expert Advisors<\/strong><\/span><\/h3>\n<\/td>\n<\/tr>\n

\n

Serving Size
<\/strong>justified to the right<\/p>\n<\/td>\n

Aligns serving size with % DV, thus improving eye flow across information.<\/td>\n\u00a0<\/td>\nIn favor.<\/td>\n<\/tr>\n
\u00a0Deletion of the
Sub-Heading “Amount\/Teneur”<\/strong><\/td>\n		\u00a0<\/td>\n\u00a0<\/td>\nIn favor since these sub- headings were not necessary.<\/td>\n<\/tr>\n
Increased\u00a0prominence of Calories<\/strong><\/td>\n\u00a0<\/td>\nEurofins believes that by putting emphasis on the caloric content, the consumer\u2019s attention will be drawn away from the:<\/p>\n
    \n
  • serving size declared on the line above;<\/li>\n
  • global nutritional value of the food product. This is also the opinion of the Quebec dietetic association, l\u2019Ordre professionnel des di\u00e9t\u00e9tistes du Qu\u00e9bec.<\/em><\/li>\n<\/ul>\n

    For example, a glass of 250\u00a0ml of partly skimmed milk with 130 Calories is nutrient-rich compared to the same amount of cola drink with 100 or even zero Calories.<\/p>\n<\/td>\n

Calories should not appear more prominently than nutrients.<\/td>\n<\/tr>\n
Grouping of nutrients <\/strong>of public health concern for which Canadians should:<\/p>\n
    \n
  • limit their consumption, <\/strong>at the top of the NFT<\/li>\n<\/ul>\n

    and<\/p>\n

      \n
    • get enough, <\/strong>at the bottom of the NFT<\/li>\n<\/ul>\n

      The two groups of nutrients would be separated by a thick line<\/p>\n<\/td>\n

The order is very similar to the order of declaration in the current NFT. The main difference is the order of declaration of fibre and sugar which are reversed.<\/td>\nWithout any indication explaining the nutrient grouping, consumers may not understand that the nutrients of public health concern to:<\/p>\n
    \n
  • limit are in the upper half of the NFT;<\/li>\n
  • get enough are grouped below a thick line, in the bottom half of the NFT.<\/li>\n<\/ul>\n<\/td>\n
To facilitate consumer understanding of the nutrient grouping concept, perhaps the new NFT should include sub-headings (e.g. \u201cAvoid too much of\u201d and \u201cGet enough of\u201d), as proposed for the new US Nutrition Facts panel (see figure\u00a03).<\/p>\n

Carbohydrates are grouped with the nutrients which consumption should be limited. However, according to the Institute of Medicine[1]<\/em><\/a>, <\/em>carbohydrates should constitute 45% to 65% of one\u2019s total caloric intake.<\/p>\n

To be consistent with the nutrient grouping concept:<\/p>\n

Declaration of dietary fibre near other carbohydrates, but separated from them with a thick line.<\/p>\n
    \n
  • Fibre grouped at the bottom of the NFT with nutrients which a higher consumption is recommended<\/strong><\/li>\n
  • Other carbohydrates grouped at the top of the NFT with nutrients which consumption should be limited<\/strong><\/li>\n<\/ul>\n<\/td>\n
The position of fibre in the proposed NFT is strategic.<\/p>\n
    \n
  • Listing fibre immediately below other carbohydrates and sugars helps people with diabetes, and on insulin therapy, to adjust their insulin dose requirements on their carbohydrate intake.<\/li>\n
  • Grouping fibre with nutrients which increased consumption is recommended may help Canadians realize that they should consume enough fibre.<\/li>\n<\/ul>\n

    Of course, it will have to be made clear to the consumer what each nutrient group represents, i.e. nutrients to limit consumption in the top half of the NFT, and nutrients to get enough of in the bottom half of the NFT.<\/p>\n<\/td>\n

It is not clear whether the declared total carbohydrate content includes or excludes dietary fibre.<\/td>\nSince dietary fibre would be separated from the other carbohydrates in the NFT, the regulations should clearly state whether the dietary fibre should be:<\/p>\n
    \n
  • included in the carbohydrate count, as currently in Canada and USA<\/li>\n<\/ul>\n

    In this case, the fibre should be indented, and in line with the declaration of total sugars.<\/p>\n

    or<\/p>\n

      \n
    • excluded from the carbohydrate count as in Europe.<\/li>\n<\/ul>\n

      In Europe, the declared carbohydrate value includes only \u201cavailable carbohydrates\u201d (excludes dietary fibre).<\/p>\n<\/td>\n<\/tr>\n

\u00a0% Daily Value for carbohydrates no longer required<\/strong><\/td>\n\u00a0<\/td>\n\u00a0<\/td>\nIn favor, since total carbohydrate intake is not considered a public health concern.<\/td>\n<\/tr>\n
\n

Inclusion of % Daily Value (DV) for total sugars <\/strong>based on a proposed daily value of 100\u00a0g (which represents 20\u00a0% of the daily energy intake for a 2,000\u00a0Cal diet)<\/p>\n

(Added sugar content not declared)<\/p>\n

\u00a0<\/strong><\/p>\n

 <\/p>\n

 <\/p>\n

or<\/p>\n<\/td>\n

\u00a0<\/td>\n\n

Does not inform the consumer, about the source of sugar: naturally occurring or added sugars. Hence, there is no indication as to whether the sugar added to a fruit yogourt, for example, comes mainly from milk and fruit or from sweetening agents.<\/p>\n

The proposed display creates confusion as it is not clear whether the %\u00a0DV applies solely to total sugars or carbohydrates in general.<\/p>\n

The proposed daily value of 100\u00a0g of sugars, i.e. 20\u00a0% of the daily energy intake for a 2,000\u00a0Cal diet, appears excessive.<\/p>\n<\/td>\n

\u00a0If the %\u00a0DV for total sugars is maintained, perhaps it should not appear in bold characters so it is clearer that the % applies specifically to total sugars (which are not shown in bold) rather than to the carbohydrates in general.<\/p>\n

The daily value for total sugars should preferably correspond to 10% of the daily energy value (i.e. 50 g of sugars in a 2000\u00a0Calorie diet), as proposed in March 2014 by the World Health Organization <\/em>in a public consultation, not 20% (or 100\u00a0g).<\/p>\n

Manufacturers of food products intended for use as ingredients in the manufacture other foods to be sold at the retail level should be required to provide with accuracy the amount of added sugar to their products, so their clients can determine the added sugar content of their finished products.<\/p>\n<\/td>\n<\/tr>\n

Declaration of added sugars <\/strong>below the total sugars<\/strong><\/p>\n

(%\u00a0DV for total sugars not declared)<\/p>\n<\/td>\n

Introduces the concept of naturally occurring sugars versus added sugars.<\/p>\n

May increase consumers awareness regarding the significant proportion of sugars added to food products, and can help them make better food choices.<\/p>\n

Could incite food manufacturers in reformulating their products to reduce the sugar content, thus contributing to an improved nutritional offering on the market.<\/p>\n<\/td>\n

Laboratory nutritional analyses can generally not differentiate naturally occurring versus added sugars.<\/p>\n

For database analyses, it may be difficult to obtain accurate added sugar content from foreign ingredient vendors.<\/p>\n

For some manufacturers, this would highlight an element with bad press, and could contribute to reduced sales.<\/p>\n<\/td>\n

A margin of error of 20% should cover inaccuracies to the added sugars content of multi-ingredient food products.<\/p>\n

The term \u201cadded sugars\u201d in the NFT will need to be clearly defined, especially with respect to sweeteners that appear more natural, such as concentrated fruit juices or fruit pastes (e.g. are they added for their fruity flavour or to sweeten the product?)<\/p>\n<\/td>\n<\/tr>\n

\n

Deletion of the thin lines between:<\/strong><\/p>\n

    \n
  • total fat <\/strong>and saturated fat<\/strong><\/li>\n
  • total carbohydrate <\/strong>and sugars<\/strong><\/li>\n<\/ul>\n<\/td>\n
\n

Improved grouping of nutrients helps consumers understand that the indented nutrients are components of fat or carbohydrates.<\/p>\n

De-clutters the NFT, and improves legibility of the information.<\/p>\n<\/td>\n

\u00a0<\/span><\/td>\nIn favor.<\/td>\n<\/tr>\n
\n

Declaration of<\/p>\n

vitamins A and C<\/strong><\/p>\n

replaced by<\/p>\n

vitamin D <\/strong>and potassium<\/strong><\/p>\n<\/td>\n

\n

Relevant choice of nutrients:<\/p>\n

Involves an additional expense for manufacturers who must reanalyze the nutritional composition of their food products.<\/td>\n\u00a0<\/td>\n<\/tr>\n
Vitamin and mineral contents shown by weight<\/strong><\/td>\n\n

Consistent with the manner of declaring other nutrients.<\/p>\n

May be useful for the management of dietary intake, especially for those who consume vitamin and mineral supplements.<\/p>\n<\/td>\n

\u00a0<\/td>\n\u00a0<\/td>\n<\/tr>\n
% DV indicated only for macronutrients which consumption should be limited, and for vitamins and minerals<\/strong><\/td>\n\u00a0 –<\/td>\nBy declaring the fibre content in grams only, consumers have no clue as to whether they are getting enough fibre or not. This is a problem as most Canadians do not consume enough fibre.<\/td>\nThe %\u00a0DV for fibre should be maintained in order to help consumers identify and select sources of dietary fibre.<\/td>\n<\/tr>\n
\n

Footnote <\/strong>explaining % DV benchmark levels<\/p>\n

\u201c5% DV or less is a little; 15% DV or more is a lot\u201d<\/strong><\/p>\n<\/td>\n

Should greatly improve consumers\u2019 comprehension of %\u00a0DV and help them make better food choices.<\/td>\n\u00a0<\/td>\n\u00a0<\/td>\n<\/tr>\n
Voluntary declaration of bioactive compounds in a separate box<\/strong><\/td>\nInformation of interest to consumers.<\/td>\n\u00a0<\/td>\n\u00a0<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Overall, the presentation of the NFT based on the proposed regulatory modifications should help consumers better understand the nutrition information on labels, and help them make healthier food choices.<\/p>\n

For manufacturers, these modifications involve expenses, such as the costs associated with the production of new labels and the cost of reanalyzing every product to determine its potassium and vitamin\u00a0D content. Furthermore, Canadian manufacturers that export to USA also need to budget for new US labels.<\/p>\n

Indeed, the US government is reviewing their labelling requirements and modernizing their Nutrition Facts panel. Similarities between the proposed US and Canadian NFTs are noticeable. For instance, both countries propose to move the declaration of serving size to the right of the NFT. Other similar elements are mostly related to the contents of the NFT, namely:<\/p>\n