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In January 2026, the Canadian Food Inspection Agency (“CFIA”) released the What we heard report: Consultation on proposed guidance on how to label and represent plant-based alternatives to egg products (the “Report”) summarizing stakeholder feedback on its proposed guidance respecting the labelling and representation of plant‑based alternatives to egg products. The report follows a 90‑day public consultation conducted between July and October of 2024 and builds on the CFIA’s October 2024 release of its Proposed guidance: How to label and represent plant-based alternatives to egg products.
As discussed in our previous bulletin Clarity From the CFIA: New Proposed Guidance on Labelling Plant Based Alternatives to Eggs, the proposed guidance highlights that, as an overarching principle, labelling and representations about plant-based egg alternatives may not be false, misleading or deceptive. Labels and advertisements of plant-based alternatives to egg products must not confuse consumers with egg products subject to compositional standards or misrepresent the true nature of the food. The proposed guidance emphasizes the overall impression created by common names, claims and imagery: while egg‑associated terms or visuals may be used, they must be properly qualified and supported by complementary information to clearly convey the product’s plant‑based nature.
Overall, the consultation respondents supported the development of guidance to help distinguish plant‑based alternatives from standardized egg products and to reduce the risk of consumer confusion.
Some respondents urged the CFIA to adopt a stricter approach, including prohibiting the use of terms or visual elements traditionally associated with egg products. In response, the CFIA clarified an important legal point: “[…] it's important to note that there is no legal basis for the CFIA to prohibit the use of terms, images or packaging associated with egg products on plant-based alternatives to egg products”. Rather, the Safe Food for Canadians Regulations and Act and the Food and Drugs Act requires that such products be labelled in a way that they will not likely be mistaken for their traditional counterparts, such as eggs.
The CFIA reiterated in its Report that plant‑based alternatives to egg products (and all similar foods) must continue to use a common name that is non‑generic and descriptive of the food, consistent with existing regulatory requirements.
Finally, although some stakeholders suggested extending this framework to other plant‑based foods like dairy, fish and meat, they identified the need for the CFIA to consult on guidance specific to these products as each present unique characteristics.
The Report positions the consultation as a step toward finalizing the guidance, rather than expanding its scope or reopening broader policy questions.
Given the general support expressed during the consultation, the CFIA will move forward with finalizing the guidance in the coming months, taking into account the feedback received.
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