Volume 13, Number 4 - April 2012

Hello from Food Label News. We’re pleased to continue the popular topic about the differences between U.S. and Canadian labels in our feature article this month. We also cover the issue of dual declarations on a Nutrition Facts Panel in our series enjoyed by our readers and help a start-up company with formulation and labeling requirements in the Reader Q&A. Happy Spring!

In this issue you'll find:


"From my brief conversation and after reviewing the newsletters on the website, it is obvious that Food Consulting Company knows labeling requirements from top to bottom."

– James H. McFerrin, 
Legal Counsel

It's Tricky: Canadian label for "Made in USA"

Examples of Nutrition Facts Labels:
Part 7 of 10

Reader Q&A: Preservatives as “natural”?

Helpful links to keep you current


Karen C. Duester, President

It's Tricky: Canadian label for "Made in USA"

In the world of products that are made in the U.S. and sold in Canada, one might think that simply adding a French translation to the English ingredient statement would do the trick. But creating such a label is a bit more tricky.

As we’ve previously reported in Food Label News, it is not possible to create a single label that satisfies the needs of both U.S. and Canada, even if it is bilingual English/French. There are several key differences in ingredient standards of identity and reporting requirements. Here are some of those differences:

Some ingredients such as enriched flour and baking powder do not require a parenthetical declaration of sub-ingredients in Canada but they do in the U.S. For example: enriched flour (wheat flour, niacin, reduced iron, thiamin mononitrate, riboflavin, folic acid).

If a sub-ingredient is present in another ingredient at a level less than 10%, then a parenthetical declaration of sub-ingredients is not required in Canada, however it still is required in the U.S.

In Canada, margarine is required to have Vitamins A and D added. Canadian standards of identity for margarine and shortening include a list of “may contain” components and if a product contains other components that fall outside of those in the “may contain” clause, those components could disqualify the food from being labeled as margarine or shortening in Canada. When margarine or shortening meets the standard of identity in Canada, it does not require a parenthetical declaration of sub-ingredients; in the U.S., these ingredients must always be listed with a parenthetical declaration of sub-ingredients.

See U.S. and Canadian ingredient differences in a side-by-side comparison. In addition,  there are also important differences for claims, allergens and Nutrition Facts.

Helpful Links

CFR Title 21 for
FDA-regulated foods

CFR Title 9 for
USDA-regulated foods

FDA Food Labeling Guide

FTC Enforcement Policy on Food Advertising

USDA Policy Book for Food Standards and Labeling

Canadian Food & Drug Regulations

CFIA Guide to Food Labelling and Advertising

Silliker/Food Consulting Company Label Claims Guide

Join Food Label Community for key takeaways from FDA's March 5-6 food labeling webinar and other news

Reader Favorites

Food Labels in U.S. & Canada: The same and different

Such nuances between Canadian and U.S. label regulations highlight the need to be extra careful in your research and label development. See side panel (above right) for helpful resources to get you started.

Examples of Nutrition Facts Labels: Part 7 of 10

Requirements for Nutrition Facts in the U.S. vary based on several factors. This series continues with examples of dual declaration on Nutrition Facts labels.

Dual declaration Nutrition Facts are always optional. Scenarios where the dual declaration format are used include: 1) food requiring further preparation, e.g., sauce mix dry and prepared; 2) typically eaten with another food, e.g., cereal and cereal with milk; 3) to show an additional serving size, e.g., entrée portion and appetizer portion.

See the helpful how-to examples for each scenario described above as well as other examples of Nutrition Facts labels.

Reader Q&A

Find answers to our readers' questions or send us your question for an upcoming issue.


I plan on distributing a jarred tomato sauce to my friends, family and through a farmer’s market. I want to label it as “All Natural.” However, the bulk tomato sauce I buy has some preservatives added to extend the shelf life. Must I include the preservatives in my label even though I cook it for hours? 
R.C., Florida, Food Entrepreneur


Yes, if preservatives are used in a product or as a sub-ingredient of another ingredient, they must be declared on the label. Therefore, if you want to have an all natural product, you will need to source a bulk tomato product that does not contain preservatives. Read more.

At Your Service

Food Consulting Company, founded in 1993, provides nutrition analysis, food labeling and regulatory support to ensure 100% compliance with FDA regulations. With well over 1,500 clients worldwide, we’re pleased to provide information to address your food labeling needs.

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© 2012. Food Consulting Company, Del Mar, CA. All rights reserved.