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A new era of food in Canada—Supplemented Foods
April 18th 2022

A new era of food in Canada—Supplemented Foods


By Dorothy Hong

With growing awareness of the importance of maintaining a healthy lifestyle, Canadian consumers are eagerly looking for products with ingredients that support their specific wellness needs. In order to promote innovation in Canada to suit this increasing need, Health Canada has initiated a new era of food – supplemented food to meet the public expectation while continuously supporting the food industry to develop savvy but trusted food products.

What are supplemented foods?

Supplemented foods are foods containing one or more supplemental ingredients such as vitamins, mineral nutrients, amino acids, and other ingredients (e.g., caffeine, herbal extracts). Examples include:

  • Beverages with added mineral nutrients
  • Caffeinated energy drinks
  • Snack bars with amino acids

What are they not?

Supplemented foods can not be designed, advertised, or targeted toward vulnerable subpopulations, including infants, children under 4 years, breastfeeding women, and pregnant women. Certain foods under Food & Drug Regulations (i.e., foods for special dietary use, alcoholic beverages, and novel foods) are not permitted to be marketed as supplemented foods.


Before 2012, products such as caffeinated energy drinks (CEDs) were introduced into the Canadian market as natural health products (NHPs) through the Natural Health Product Regulations (NHPR). Beginning in late 2011, Health Canada recategorized these NHPs as foods based on product format, history of use, and representation to consumers’ perception. With the condition that these products contain ingredients at levels considered safe for consumption, they were allowed to be sold temporarily as foods under Temporary Marketing Authorization Letters (TMALs).

TMALs for all these products were set to expire by Dec 31st, 2021. Therefore, in June 2021, Health Canada consulted with food science experts on the Proposed Regulations for supplemented foods, which was published in the Canada Gazette, Part I (CGI). Health Canada’s goal was to integrate Supplemented Foods with Food and Drug Regulations (FDRs) by adding Supplemented Ingredients to foods. In the meantime, products with existing TMALs are still able to be sold legally in the Canadian market until this proposed regulation is finalized.

Differences of supplemented foods and fortified foods

Consumers often confuse fortified foods and supplemented foods, as both include added ingredients like vitamins, minerals, and amino acids. However, we distinguish them from one another based on the intent of these additions:

  • Fortified foods are fortified on a mandatory or voluntary basis for public health purposes, including prevention or correction of a deficiency in the population, e.g., Vitamin D added milk; restoring levels of nutrients lost during processing, e.g., enriched wheat flour. Therefore, fortified foods are usually suitable for the general population.
  • Supplemented Foods are those with added vitamins, mineral nutrients, and amino acids up to the regulated levels to achieve a specific physiological or health effect. e.g., caffeinated energy drinks for temporary mental alertness, and beverages with added mineral nutrients for hydration. Therefore, they may not be suitable for the general population.

What’s next?

The proposed regulations are expected to be finalized in Spring 2022. Subscribe to our blog to stay up to date on updated regulations and what they mean for food manufacturers.

Mérieux NutriSciences provides consulting services to help navigate the world of Supplemented Foods, including permitted food categories, Supplemented Ingredients (SIs), and corresponding labeling requirements set forth in final regulations. Learn more about these services below:


Dorothy Hong

Regulatory Specialist, Labeling Compliance, and Regulatory Service

Mérieux NutriSciences

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