A Close Look at Canadian Supplemented FoodsBlog
By Dorothy Hong
The amended regulations for Supplemented Foods in Canada Food and Drug Regulations were published on July 21, 2022, and the manufacturers are given the transition until December 31, 2025, to meet the amended regulations. In this blog, let us take a close look at two aspects of the supplemented foods – 1) permissible foods and ingredients and 2) specific and general labeling requirements.
Food Categories Permitted as Supplemented Foods (SFs)
In order to support manufacturers in marketing their food as an acceptable SF, Health Canada provides the list of permitted supplemented food categories, along with descriptions for each food category. With descriptions of these food categories, food manufacturers are able to identify what foods belong to the permitted categories and what else are not within the scope of these categories. For example,
- Single-serving prepackaged ground coffee products to be brewed are permitted to market as an SF vs. ground coffee to be brewed and available in packages other than single-serving prepackaged format, and whole coffee beans are not permitted.
Different from conventional foods, only foods belonging to the food categories set forth in the list can be Supplemented Foods. Therefore, a product cannot be an SF if it does not belong to a permitted food category in the list unless an amendment to this list is requested and approved by Health Canada.
Permitted Supplemented Ingredients (SIs)
In order to support manufacturers in developing a safe and compliant SF, Health Canada provides the list of Permitted Supplemental Ingredients, along with their maximum levels for the permitted supplemented food categories. For example,
- Vitamin C is able to be added up to 756 mg in any food categories in the permitted food category list (with the exception that carbonated/non-carbonated water beverages that contain added caffeine and a total amount of caffeine from all sources of more than 150 ppm)
Different from fortified foods, minimum amounts of SIs in the SFs are not prescribed, as SIs are not added to SFs for nutritional purposes. In addition, the maximum levels prescribed for the corresponding SIs are set forth in a risk-based approach but not recommended levels for addition. The maximum amounts apply to the quantity declared on the label, including contributions from all added and naturally occurring sources in the product. For example,
- The amount of vitamin C in a non-carbonated water-based beverage is contributed by directly adding Vitamin C as a SI, the vitamin C in the food ingredient, e.g., orange juice and ascorbic acid used as a preservative.
In addition, Health Canada provides a list of vitamins and mineral nutrients currently not acceptable for addition to SFs at any level, most of which are associated with risks for the general population or for a specific vulnerable population for whom it is unlikely that cautionary labeling would be an effective risk mitigation tool. For example,
- Supplemental iron intake could be a hazard for individuals with undiagnosed hemochromatosis.
Read part two of this blog series on Cautionary Statment and Supplemented Food Caution Identifier (SFCI).