Frequently asked questions

 Q: What are Canada’s priority food allergens?

The ten priority food allergens include:

  • Peanuts
  • Eggs
  • Milk
  • Tree Nuts
  • Wheat (including spelt and kamut)
  • Soy
  • Sesame Seeds
  • Seafood (Fish, Crustaceans and Shellfish)
  • Sulphites
  • Mustard

Reference: http://www.hc-sc.gc.ca/fn-an/securit/allerg/fa-aa/index-eng.php

Sulphite Declaration

Sulphites, like any other food additive, are required to be declared in the list of ingredients of food labels when they are added directly to a prepackaged food as an ingredient or a component of an ingredient that is not exempt from component declaration. If added sulphites are present in a prepackaged product in the first generation (i.e. ingredient) or second generation (i.e. component), and are not exempt from declaration, they must be declared in the list of ingredients regardless of their quantity. Refer to Generations for more information on the generations of ingredients.
In the following examples, sulphites are a component of the dried apricots. Dried apricots are not exempt from component declaration, therefore sulphites, along with all the other components of the dried apricots, must be declared regardless of their quantities.

  • Sulphites added as a food additive ingredient

For example: Ingredient list: apricots, sugar, sulphites

  • Sulphites added as a component of an ingredient that is not exempt from component declaration

For example: Ingredient list: Rolled oats, wheat flour, dried apricots (apricots, sugar, sulphites), liquid whole egg (liquid whole egg, beta carotene), salt, baking soda, soy lecithin.

Added Sulphite Declaration

If the total amount of added sulphites are present in a prepackaged product in a total amount of 10 parts per million or more, and are not already required to be shown in the list of ingredients under section B.01.008 or B.01.009 of the FDR, the sulphites must be shown in:

  1. The list of ingredients;

or

  1. In a “contains” statement that complies with the naming and locationrestrictions outlined in B.01.010.3(1) of the FDR.

Sulphites that are declared in the list of ingredients must be shown as follows:

  • (a) Sulphites that are a component of an ingredient that is shown in the list of ingredients must be shown either in parentheses immediately after the ingredient or at the end of that list where they may be shown in any order with the other ingredients that are shown at the end of that list under B.01.008(4) of the FDR [B.01.010.2(7)(a), FDR].
  • (b) In all other cases, the sulphites must be shown at the end of the list of ingredients where they may be shown in any order with the other ingredients that are shown at the end of that list under subsection B.01.008(4) of the FDR[B.01.010.2(7)(b), FDR].

For example: In a box of cookies that are made with apricot jam, sulphites are a component of the apricot jam with pectin. Assuming that the jam is only 5% or less of the cookie, it is exempt from component declaration [B.01.009(1), item 24 FDR], and that the sulphites are a level of 13 ppm (therefore greater than 10 ppm), the sulphites must be declared as per subsection B.01.010.2(3), FDR. Both of the above examples are acceptable ways to declare sulphites (at levels of 10 ppm or more) in the list of ingredients.
In the list of ingredients, sulphites can be declared in parentheses after apricot jam with pectin:

Ingredients: Rolled oats, wheat flour, liquid whole egg, apricot jam with pectin (sulphites), salt, baking soda, soy lecithin.

Or at the end of the list of ingredients in any order:

Ingredients: Rolled oats, wheat flour, liquid whole egg, apricot jam with pectin, salt, baking soda, soy lecithin, sulphites.

Note: In situations where added sulphites are a component that must be declared in the list of ingredients as per B.01.008(1)(b), B.01.008(5) FDR, but the total amount is less than 10 parts per million, then the sulphites will not have to be declared in the contains statement.

Reference: http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/list-of-ingredients-and-allergens/eng/1383612857522/1383612932341?chap=2#s7c2

 

Q: What are the major food allergens in the USA?

The 8 major food allergens include:

  • milk
  • egg
  • fish
  • crustacean, shellfish
  • tree nuts
  • wheat
  • peanuts
  • soybeans

Reference: https://www.fda.gov/food/resourcesforyou/consumers/ucm079311.htm

 

Q:  What are the major food allergens in the EU?

EU

  • Cereals containing gluten: namely wheat (including specific varieties like spelt and Khorasan), rye, barley, oats and their hybridised strains) and products thereof
  • Crustaceans and products thereof (for example prawns, lobster, crabs and crayfish)
  • Egg and products thereof
  • Fish and products thereof
  • Peanut and products thereof
  • Soybeans and products thereof
  • Milk and products thereof (including lactose)
  • Nuts: namely almond, hazelnut, walnut, cashew, pecan nut, Brazil nut, pistachio nut and Macadamia nut (Queensland nut) and products thereof
  • Celery and products thereof
  • Mustard and products thereof
  • Sesame seeds and products thereof
  • Sulphur dioxide and sulphites (at concentrations of more than 10mg/kg or 10mg/L in terms of the total SO2 which are to be calculated for products as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers)
  • Lupin and products thereof
  • Molluscs and products thereof (for example clams, oysters, scallops, snails and squid)

Reference: http://farrp.unl.edu/ref-sit-eu

 

Q: How can flavours be labelled in Canada?

Flavouring Preparations

B.10.003 [S]. (naming the flavour) Extract or (naming the flavour) Essence shall be a solution in ethyl alcohol, glycerol, propylene glycol or any combination of these, of sapid or odorous principles, or both, derived from the plant after which the flavouring extract or essence is named, and may contain water, a sweetening agent, food colour and a Class II preservative or Class IV preservative.

B.10.004 [S]. Artificial (naming the flavour) Extract, Artificial (naming the flavour) Essence, Imitation (naming the flavour) Extract or Imitation (naming the flavour) Essence shall be a flavouring extract or essence except that the flavouring principles shall be derived in whole, or in part, from sources other than the aromatic plant after which it is named, and if such extract or essence is defined in these Regulations, the flavouring strength of the artificial or imitation extract or essence shall be not less than that of the extract or essence.

B.10.005 [S]. (naming the flavour) Flavour

  • (a) shall be a preparation, other than a flavouring preparation described in section B.10.003, of sapid or odorous principles, or both, derived from the aromatic plant after which the flavour is named;
  • (b) may contain a sweetening agent, food colour, Class II preservative, thaumatin, Class IV preservative or emulsifying agent; and
  • (c) may have added to it the following liquids only:
    • (i) water,
    • (ii) any of, or any combination of, the following: benzyl alcohol; 1, 3-butylene glycol, ethyl acetate, ethyl alcohol, glycerol, glyceryl diacetate, glyceryl triacetate, glyceryl tributyrate, isopropyl alcohol, monoglycerides and diglycerides; 1, 2-propylene glycol or triethylcitrate,
    • (iii) edible vegetable oil, and
    • (iv) brominated vegetable oil, sucrose acetate isobutyrate or mixtures thereof, when such flavour is used in beverages containing citrus or spruce oils.
  • SOR/84-300, s. 27(E);
  •  SOR/86-1112, s. 1;
  •  SOR/2010-142, s. 8.

Previous Version

B.10.006 [S]. Artificial (naming the flavour) Flavour or Imitation (naming the flavour) Flavour shall be a flavour except that the flavouring principles may be derived in whole or in part from sources other than the aromatic plant after which it is named, and if such flavour is defined in these Regulations, the flavouring strength of the artificial or imitation flavour shall be not less than that of the flavour.

B.10.007 [S]. Notwithstanding sections B.10.003 and B.10.005, a (naming the fruit) Extract Naturally Fortified, (naming the fruit) Essence Naturally Fortified or (naming the fruit) Flavour Naturally Fortified shall be an extract, essence or flavour derived from the named fruit to which other natural extractives have been added and 51 per cent of the flavouring strength shall be derived from the named fruit.

B.10.008 On any label of or in any advertisement for an artificial or imitation flavouring preparation, the word “artificial”, or “imitation” shall be an integral part of the name of such flavouring preparation and shall be set out in identical type and identically displayed with such name.

  • SOR/84-300, s. 28.

B.10.009 [S]. Almond Essence, Almond Extract or Almond Flavour shall be the essence, extract or flavour derived from the kernels of the bitter almond, apricot or peach and shall contain not less than one per cent by volume of hydrocyanic acid-free volatile oil obtained therefrom.

B.10.010 [S]. Anise Essence, Anise Extract or Anise Flavour shall be the essence, extract or flavour derived from natural or terpeneless oil of anise and shall correspond in flavouring strength to an alcoholic solution containing not less than three per cent by volume of oil of anise, the volatile oil obtained from the fruit of Pimpinella anisum L. or Illicium verum Hook.

B.10.011 [S]. Celery Seed Essence, Celery Seed Extract or Celery Seed Flavour shall be the essence, extract or flavour derived from celery seed, or oil of celery seed, or terpeneless oil of celery seed and shall correspond in flavouring strength to an alcoholic solution containing not less than 0.3 per cent by volume of volatile oil of celery seed.

B.10.012 [S]. Cassia Essence, Cassia Extract, Cassia Cinnamon Essence, Cassia Cinnamon Extract, Cassia Flavour or Cassia Cinnamon Flavour shall be the essence, extract or flavour derived from natural or terpeneless oil, obtained from leaves and twigs of Cinnamomum cassia L. containing not less than 80 per cent cinnamic aldehyde, and shall correspond in flavouring strength to an alcoholic solution containing not less than two per cent by volume of volatile oil of cassia cinnamon.

B.10.013 [S]. Ceylon Cinnamon Essence, Ceylon Cinnamon Extract or Ceylon Cinnamon Flavour shall be the essence, extract or flavour derived from the volatile oil obtained from the bark of Cinnamomum zeylanicumNees, and shall contain

  • (a) not less than two per cent by volume of oil of Ceylon cinnamon;
  • (b) not less than 65 per cent cinnamic aldehyde; and
  • (c) not more than 10 per cent eugenol.

B.10.014 [S]. Clove Essence, Clove Extract or Clove Flavour shall be the essence, extract or flavour derived from the volatile oil obtained from clove buds, and shall contain not less than two per cent by volume of oil of clove.

B.10.015 [S]. Ginger Essence, Ginger Extract or Ginger Flavour shall be the essence, extract or flavour derived from ginger and shall contain in 100 millilitres the alcohol-soluble matter from not less than 20 grams of ginger.

B.10.016 [S]. Lemon Essence, Lemon Extract or Lemon Flavour shall be the essence, extract or flavour prepared from natural or terpeneless oil of lemon or from lemon peel and shall contain not less than 0.2 per cent citral derived from oil of lemon.

B.10.017 [S]. Nutmeg Essence, Nutmeg Extract or Nutmeg Flavour shall be the essence, extract or flavour prepared from natural or terpeneless oil of nutmeg and shall correspond in flavouring strength to an alcoholic solution containing not less than two per cent by volume of oil of nutmeg.

B.10.018 [S]. Orange Essence, Orange Extract or Orange Flavour shall be the essence, extract or flavour prepared from sweet orange peel, oil of sweet orange or terpeneless oil of sweet orange, and shall correspond in flavouring strength to an alcoholic solution containing five per cent by volume of oil of sweet orange, the volatile oil obtained from the fresh peel of Citrus aurantium L., that shall have an optical rotation, at a temperature of 25°C, of not less than +95° using a tube 100 millimetres in length.

B.10.019 [S]. Peppermint Essence, Peppermint Extract or Peppermint Flavour shall be the essence, extract or flavour prepared from peppermint or oil of peppermint, obtained from the leaves and flowering tops of Mentha piperita L., or of Mentha arvensis De.C., var. piperascens Holmes, and shall correspond in flavouring strength to an alcoholic solution of not less than three per cent by volume of oil of peppermint, containing not less than 50 per cent free and combined menthol.

B.10.020 [S]. Rose Essence, Rose Extract or Rose Flavour shall be the essence, extract or flavour prepared from the volatile oil obtained from the petals of Rosa damascena Mill., R. centajolia L., or R. moschata Herrm, and shall contain not less than 0.4 per cent by volume of attar of rose.

B.10.021 [S]. Savory Essence, Savory Extract or Savory Flavour shall be the essence, extract or flavour prepared from savory or oil of savory and shall contain not less than 0.35 per cent by volume oil of savory.

B.10.022 [S]. Spearmint Essence, Spearmint Extract or Spearmint Flavour shall be the essence, extract or flavour prepared from spearmint or from oil of spearmint, obtained from the leaves and flowering tops of Mentha spicata L. and shall contain not less than three per cent by volume of oil of spearmint.

B.10.023 [S]. Sweet Basil Essence, Sweet Basil Extract or Sweet Basil Flavour shall be the essence, extract or flavour prepared from sweet basil or from oil of sweet basil, obtained from the leaves and tops of Ocymum basilicum L. and shall contain not less than 0.1 per cent by volume of oil of sweet basil.

B.10.024 [S]. Sweet Marjoram Essence, Sweet Marjoram Extract, Marjoram Essence, Marjoram Extract, Sweet Marjoram Flavour or Marjoram Flavour shall be the essence, extract or flavour prepared from marjoram or from oil of marjoram and shall contain not less than one per cent by volume of oil of marjoram.

B.10.025 [S]. Thyme Essence, Thyme Extract or Thyme Flavour shall be the essence, extract or flavour prepared from thyme or from oil of thyme and shall contain not less than 0.2 per cent by volume of oil of thyme.

B.10.026 [S]. Vanilla Extract, Vanilla Essence or Vanilla Flavour

  • (a) shall be the essence, extract or flavour prepared from the vanilla bean, the dried, cured fruit of Vanilla planifolia, Andrews, or Vanilla tahitensia, J. W. Moore;
  • (b) shall contain in 100 ml, regardless of the method of extraction, at least the quantity of soluble substances in their natural proportions that are extractable, according to official method FO-17, Extraction of Soluble Substances from Vanilla Beans, dated September 15, 1989, from
    • (i) not less than 10 g of vanilla beans, where the beans contain 25 per cent or less moisture, and
    • (ii) not less than 7.5 g of vanilla beans on the moisture-free basis, where the beans contain more than 25 per cent moisture; and
  • (c) notwithstanding sections B.10.003 and B.10.005, shall not contain added colour.
  • SOR/82-768, s. 25;
  •  SOR/84-300, s. 29(F);
  •  SOR/91-149, s. 1.

B.10.027 [S]. Wintergreen Essence, Wintergreen Extract or Wintergreen Flavour shall be the essence, extract or flavour prepared from oil of wintergreen, the volatile oil distilled from the leaves of Gaultheria procumbens L. or from Betula lenta L. and shall contain not less than three per cent by volume of oil of wintergreen.

Reference: http://laws.justice.gc.ca/eng/regulations/C.R.C.,_c._870/FullText.html

 

Q: How are flavours labelled in the USA?

(a)(1) The term artificial flavor or artificial flavoring means any substance, the function of which is to impart flavor, which is not derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, fish, poultry, eggs, dairy products, or fermentation products thereof. Artificial flavor includes the substances listed in 172.515(b) and 182.60 of this chapter except where these are derived from natural sources.

(3) The term natural flavor or natural flavoring means the essential oil, oleoresin, essence or extractive, protein hydrolysate, distillate, or any product of roasting, heating or enzymolysis, which contains the flavoring constituents derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, seafood, poultry, eggs, dairy products, or fermentation products thereof, whose significant function in food is flavoring rather than nutritional. Natural flavors include the natural essence or extractives obtained from plants listed in 182.10, 182.20, 182.40, and 182.50 and part 184 of this chapter, and the substances listed in 172.510 of this chapter.

  1. g) A flavor shall be labeled in the following way when shipped to a food manufacturer or processor (but not a consumer) for use in the manufacture of a fabricated food, unless it is a flavor for which a standard of identity has been promulgated, in which case it shall be labeled as provided in the standard:

(1) If the flavor consists of one ingredient, it shall be declared by its common or usual name.

(2) If the flavor consists of two or more ingredients, the label either may declare each ingredient by its common or usual name or may state “All flavor ingredients contained in this product are approved for use in a regulation of the Food and Drug Administration.” Any flavor ingredient not contained in one of these regulations, and any nonflavor ingredient, shall be separately listed on the label.

(3) In cases where the flavor contains a solely natural flavor(s), the flavor shall be so labeled, e.g., “strawberry flavor”, “banana flavor”, or “natural strawberry flavor”. In cases where the flavor contains both a natural flavor and an artificial flavor, the flavor shall be so labeled, e.g., “natural and artificial strawberry flavor”. In cases where the flavor contains a solely artificial flavor(s), the flavor shall be so labeled, e.g., “artificial strawberry flavor”.

(h) The label of a food to which flavor is added shall declare the flavor in the statement of ingredients in the following way:

(1) Spice, natural flavor, and artificial flavor may be declared as “spice”, “natural flavor”, or “artificial flavor”, or any combination thereof, as the case may be.

(6) Any pyroligneous acid or other artificial smoke flavors used as an ingredient in a food may be declared as artificial flavor or artificial smoke flavor. No representation may be made, either directly or implied, that a food flavored with pyroligneous acid or other artificial smoke flavor has been smoked or has a true smoked flavor, or that a seasoning sauce or similar product containing pyroligneous acid or other artificial smoke flavor and used to season or flavor other foods will result in a smoked product or one having a true smoked flavor.

(7) Because protein hydrolysates function in foods as both flavorings and flavor enhancers, no protein hydrolysate used in food for its effects on flavor may be declared simply as “flavor,” “natural flavor,” or “flavoring.” The ingredient shall be declared by its specific common or usual name as provided in 102.22 of this chapter.

(i) If the label, labeling, or advertising of a food makes any direct or indirect representations with respect to the primary recognizable flavor(s), by word, vignette, e.g., depiction of a fruit, or other means, or if for any other reason the manufacturer or distributor of a food wishes to designate the type of flavor in the food other than through the statement of ingredients, such flavor shall be considered the characterizing flavor and shall be declared in the following way:

(1) If the food contains no artificial flavor which simulates, resembles or reinforces the characterizing flavor, the name of the food on the principal display panel or panels of the label shall be accompanied by the common or usual name of the characterizing flavor, e.g., “vanilla”, in letters not less than one-half the height of the letters used in the name of the food, except that:

(i) If the food is one that is commonly expected to contain a characterizing food ingredient, e.g., strawberries in “strawberry shortcake”, and the food contains natural flavor derived from such ingredient and an amount of characterizing ingredient insufficient to independently characterize the food, or the food contains no such ingredient, the name of the characterizing flavor may be immediately preceded by the word “natural” and shall be immediately followed by the word “flavored” in letters not less than one-half the height of the letters in the name of the characterizing flavor, e.g., “natural strawberry flavored shortcake,” or “strawberry flavored shortcake”.

(ii) If none of the natural flavor used in the food is derived from the product whose flavor is simulated, the food in which the flavor is used shall be labeled either with the flavor of the product from which the flavor is derived or as “artificially flavored.”

(iii) If the food contains both a characterizing flavor from the product whose flavor is simulated and other natural flavor which simulates, resembles or reinforces the characterizing flavor, the food shall be labeled in accordance with the introductory text and paragraph (i)(1)(i) of this section and the name of the food shall be immediately followed by the words “with other natural flavor” in letters not less than one-half the height of the letters used in the name of the characterizing flavor.

(2) If the food contains any artificial flavor which simulates, resembles or reinforces the characterizing flavor, the name of the food on the principal display panel or panels of the label shall be accompanied by the common or usual name(s) of the characterizing flavor, in letters not less than one-half the height of the letters used in the name of the food and the name of the characterizing flavor shall be accompanied by the word(s) “artificial” or “artificially flavored”, in letters not less than one-half the height of the letters in the name of the characterizing flavor, e.g., “artificial vanilla”, “artificially flavored strawberry”, or “grape artificially flavored”.

(3) Wherever the name of the characterizing flavor appears on the label (other than in the statement of ingredients) so conspicuously as to be easily seen under customary conditions of purchase, the words prescribed by this paragraph shall immediately and conspicuously precede or follow such name, without any intervening written, printed, or graphic matter, except:

(i) Where the characterizing flavor and a trademark or brand are presented together, other written, printed, or graphic matter that is a part of or is associated with the trademark or brand may intervene if the required words are in such relationship with the trademark or brand as to be clearly related to the characterizing flavor; and

(ii) If the finished product contains more than one flavor subject to the requirements of this paragraph, the statements required by this paragraph need appear only once in each statement of characterizing flavors present in such food, e.g., “artificially flavored vanilla and strawberry”.

(iii) If the finished product contains three or more distinguishable characterizing flavors, or a blend of flavors with no primary recognizable flavor, the flavor may be declared by an appropriately descriptive generic term in lieu of naming each flavor, e.g., “artificially flavored fruit punch”.

(4) A flavor supplier shall certify, in writing, that any flavor he supplies which is designated as containing no artificial flavor does not, to the best of his knowledge and belief, contain any artificial flavor, and that he has added no artificial flavor to it. The requirement for such certification may be satisfied by a guarantee under section 303(c)(2) of the act which contains such a specific statement. A flavor user shall be required to make such a written certification only where he adds to or combines another flavor with a flavor which has been certified by a flavor supplier as containing no artificial flavor, but otherwise such user may rely upon the supplier’s certification and need make no separate certification. All such certifications shall be retained by the certifying party throughout the period in which the flavor is supplied and for a minimum of three years thereafter, and shall be subject to the following conditions:

(i) The certifying party shall make such certifications available upon request at all reasonable hours to any duly authorized office or employee of the Food and Drug Administration or any other employee acting on behalf of the Secretary of Health and Human Services. Such certifications are regarded by the Food and Drug Administration as reports to the government and as guarantees or other undertakings within the meaning of section 301(h) of the act and subject the certifying party to the penalties for making any false report to the government under 18 U.S.C. 1001 and any false guarantee or undertaking under section 303(a) of the act. The defenses provided under section 303(c)(2) of the act shall be applicable to the certifications provided for in this section.

(ii) Wherever possible, the Food and Drug Administration shall verify the accuracy of a reasonable number of certifications made pursuant to this section, constituting a representative sample of such certifications, and shall not request all such certifications.

(iii) Where no person authorized to provide such information is reasonably available at the time of inspection, the certifying party shall arrange to have such person and the relevant materials and records ready for verification as soon as practicable: Provided, That, whenever the Food and Drug Administration has reason to believe that the supplier or user may utilize this period to alter inventories or records, such additional time shall not be permitted. Where such additional time is provided, the Food and Drug Administration may require the certifying party to certify that relevant inventories have not been materially disturbed and relevant records have not been altered or concealed during such period.

(iv) The certifying party shall provide, to an officer or representative duly designated by the Secretary, such qualitative statement of the composition of the flavor or product covered by the certification as may be reasonably expected to enable the Secretary’s representatives to determine which relevant raw and finished materials and flavor ingredient records are reasonably necessary to verify the certifications. The examination conducted by the Secretary’s representative shall be limited to inspection and review of inventories and ingredient records for those certifications which are to be verified.

(v) Review of flavor ingredient records shall be limited to the qualitative formula and shall not include the quantitative formula. The person verifying the certifications may make only such notes as are necessary to enable him to verify such certification. Only such notes or such flavor ingredient records as are necessary to verify such certification or to show a potential or actual violation may be removed or transmitted from the certifying party’s place of business: Provided, That, where such removal or transmittal is necessary for such purposes the relevant records and notes shall be retained as separate documents in Food and Drug Administration files, shall not be copied in other reports, and shall not be disclosed publicly other than in a judicial proceeding brought pursuant to the act or 18 U.S.C. 1001.

Reference: https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=101.22