This article originally appeared in Food in Canada
and is republished with the permission of the
Canada's food laws are undergoing a major overhaul. Through
the CFIA's Food Labelling Modernization Initiative, and Health
Canada's Regulatory Roadmap for Health Products and Food, the
government is tackling an ambitious portfolio of legislative
changes, which include modernizing our food labelling regime. One
of the biggest challenges with this initiative will be balancing
the wants and needs of a diverse Canadian population with the
practical realities of what government, industry and science can
Two recently published reports on consumer perspectives
highlight some of the complex issues involved. Advertising
Standards Canada's (ASC) 2013 Consumer Perspectives on
Advertising provides the results of a survey of over 1,500
Canadians, and the Consumers Council of Canada's (CCC) Food
Information, Labelling and Advertising reports the findings of a
panel of six Canadian consumer groups.
ASC's report indicates that consumers want to be informed
about products, but don't want to be misled by claims that
aren't accurate or truthful. CCC's report outlines eight
key recommendations to help better serve consumers. These
recommendations include mandatory labelling for foods that have
been irradiated, produced using nanotechnology or contain
genetically modified organisms (GMOs), and disclosure of quantities
of highlighted ingredients. The report also outlines that consumers
want food labels to help them make informed choices, but that the
cost of labelling and advertising must not impose undue financial
burden on consumers.
Seems straightforward, but the challenge lies in the fact that
collectively what consumers want can be contradictory. For example,
based on the ASC survey, 85 per cent of Canadians take issue with
advertising text that is too small to read — but who
determines what is too small? Studies indicate, for example, that
more than half of seniors have difficulty reading labels properly,
even when wearing corrective lenses. How can industry add mandatory
statements and more health information while also increasing the
legibility of text?
More information can also be confusing. Since the introduction
of mandatory labelling for allergens, it is common to see "may
contain" statements indicating that an allergen may be present
in a food. Some consumers find this confusing, but with modern
scientific testing techniques that can find allergens at
increasingly minute amounts, industry is put in a difficult
position, as a failure to indicate the potential presence of an
allergen can lead to a costly recall if one is found. Labelling for
allergens is mandatory due to the premise that undeclared allergens
pose a health risk. However, where a safety or public health
concern has not been identified, the need for mandatory labelling
should be given careful consideration. Is it really helpful to
consumers to see products labelled "May contain GMOs"
where it is just too costly or logistically difficult for
manufacturers to confirm that all ingredients are not GMO? Even
truthful information has limited utility without context.
It is also important to remember the economic impact of
introducing labelling requirements, as the increased costs of
compliance will be passed on to the consumer. While some consumers
are willing and able to pay a premium to more easily compare
products or know that the foods they consume are non-GMO, mandatory
labelling schemes force all Canadians to absorb the additional
Looking at the success of the organic certification regime,
perhaps what consumers really need are more voluntary labelling
standards, especially where the information is not crucial in the
evaluation process for a majority of Canadians and does not aid in
assessing the safe consumption of the food. Canadians could also
benefit from education to help inform their decision making and
build confidence in our food regulatory system. Given that the
government has made a clear commitment to modernizing Canada's
food labelling laws, it is important for industry to work closely
with regulators to ensure that focus is put on areas and
initiatives that will bring meaningful change for consumers as a
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