Bottom Line: The comment period recently closed (September 20, 2012) on the Canadian Food Inspection Agency's ("CFIA") second round of consideration for its proposed Guidelines for Highlighted Ingredients and Flavours ("Guidelines"). After a decade's delay, it is hoped that final Guidelines will follow soon.

'Highlighting', of course, refers to giving prominence on a product label to certain flavours and/or ingredient(s) – i.e., "made with fruit", or "strawberry flavoured ice cream".

Highlighting could take the form of written claims, the common name declaration and/or illustrated vignettes of the flavour or ingredient. While highlighting certain ingredients can help consumers know what a product will taste like, highlighting runs the risk of being misleading as to what is actually in the product, or how much of an ingredient is present.

While they are certainly still subject to revision, the draft Guidelines seek to clarify compliance for foods that highlight ingredients viewed as beneficial or desirable. Things to watch out for under the Guidelines include ingredients present in small quantities that are highlighted without more information, and formulations where the quantity of the highlighted ingredient is bolstered by ingredients that are similar in characteristic.

If this all sounds familiar, it is because we were in the same boat about ten years ago, when CFIA put out a call for comments and consulted with the industry on this very same issue. Unfortunately, formal guidance was never published following that first round of consultation. With comments on round two now closed, CFIA will hopefully finalize formal guidance to nail this down.

Things to watch out for under the Guidelines include ingredients present in small quantities that are highlighted without more information, and formulations where the quantity of the highlighted ingredient is bolstered by ingredients that are similar in characteristic.

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