Colour Labeling Changes Coming in Canada
The Canadian Food Inspection Agency (CFIA) passed amendments to overhaul many aspects of its current labeling requirements back in 2016. This shift will take Canadian labels from among the most opaque to possibly the most transparent in the world.
Regulated industries have until December 14, 2021 to comply.
These changes will have a direct impact on Canadian food manufacturers and importers into Canada. The major amendments include a revised nutrition label, list of ingredients, serving size, sugars, and food colour requirements.
Although some of the required updates are simple formatting changes, others are more specific. For example, by 2021, brands must call out all sugar-based ingredients in brackets after the listing of ‘sugar’. Additionally, the CFIA is requiring food manufacturers to be more transparent about colours. The upcoming amendments will also require food companies to list colours by their specific names.
Original
Ingredients: flour, fancy molasses, vegetable oil shortening, brown sugar, liquid whole egg, sugar, salt, sodium bicarbonate, spices, colour
Contains: wheat, egg
New
Ingredients: Sugars (fancy molasses, brown sugar, sugar) · Flour · Vegetable oil shortening · Liquid whole egg · Salt · Sodium bicarbonate · Spices Allura red · Tartrazine
Contains: Wheat · Egg
Historically, from a colour standpoint, products manufactured in or exported to Canada were advised to declare the use of food colouring in an ingredient statement simply as “colour”. The CFIA’s new guidelines state where ‘colour’ was previously accepted, food companies must now declare all used colours by their common names. For example, “Allura Red” must be declared on the label if using the popular synthetic colourant.
Label Changes Impacting Colours
Specifically, the CFIA states the following about the 2021 labeling changes for food colours:
- Food colours must be declared by their specific common names in the list of ingredients of a prepacked product (e.g., “allura red”).
- The term “colour” may no longer be used in the list of ingredients to declare the presence of one or more food colours.
- Specific common names of one of more food colours may not be grouped and listed within parentheses after the term “colour”.
- The common name to be used for the lake version of a colour may be the common name of the colour (e.g., “tartrazine”) or alternatively “(naming the colour) lake”.
- Any food colour contained in any food preparation must declare the colour in the list of ingredients by the common name.
Canada will also allow for the use of the U.S. common name in conjunction with the common name; e.g., “Allura Red (Red 40)”.
Canada Labeling Compared to US Requirements
The US FDA is known to have extremely strict restrictions for food colours. So how do Health Canada’s new guidelines compare?
In the US, ingredients intended to impart colour must be approved individually. Under Canada’s new guidelines, common names may be used when juices are used for colour.
Certain colours may be approved in either the US or Canada but not the other. Until 2016, Spirulina was one such colour.
In the United States, with the notable exception of carmine or cochineal extract, colour additives exempt from certification (often casually referred to as “natural colours”) can be listed collectively as “artificial colours”, “artificial colour added”, “colour added”, or equally informative terms, without naming each one. These labels are not approved under the new Health Canada guidelines.
Is It Approved to Use “Fruit/Vegetable Juice for Colour”?
This is a common question my team gets: Can products made in or imported to Canada have labeling that reads “fruit juice” or “vegetable juice” for colour? The short answer is no. This was not permitted before the labeling changes, and it is most certainly not permitted under the new regulations. However, juice from an approved source can be used to colour and can be labeled using its common name. Check out these examples for black carrot, also known as purple carrot:
Vegetable Juice
Never Permitted
Colour
No Longer Permitted
Black Carrot (Colour)
No Longer Permitted
Purple Carrot (Colour)
No Longer Permitted
Anthocyanin
Always Permitted
Purple Carrot Juice Concentrate
Always Permitted
Black Carrot Juice Concentrate
Always Permitted
A colour preparation (often known alternatively as a “color system” in the United States) is a blend of ingredients designed to impart colour. This doesn’t mean that a label can read “fruit juice blend”. Powdered colours all have carriers, such as maltodextrin, that perform critical functions and need to be labeled as incidental ingredients. These can be treated either as an approved colour preparation, labeled as a single item (such as “Beta Carotene Powder”), or as a blend of multiple components labeled individually with their common names (such as “Beta Carotene, Maltodextrin”).
We’re Here to Help
As the food industry and governing regulatory bodies strive to create greater transparency for the information hungry consumers of today, Sensient’s dedicated global regulatory team is here to assist with any guidance regarding the upcoming labeling changes in Canada.
In our years of experience, labeling changes have often spurred great innovation in the industry.
Sensient Colors can help food manufacturers navigate the regulatory landscape and meet consumer demand for transparency. Our team is happy to answer any questions about compliance with the CFIA’s 2021 guidelines. Please feel free to start a conversation about natural colours or food colour regulation by requesting a consult below.