chapter 4 - ingredient verification – pdf

CHAPTER 4 INGREDIENT VERIFICATION

4.1 Objective . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

4.2 Scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

4.3 Required Forms, Equipment and References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

4.3.1 Forms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

4.3.2 Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

4.3.3 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

4.4 Inspection Procedures - at the Manufacturing Level . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

4.4.1 Select a Product . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

4.4.2 Complete the Ingredient Verification Worksheet . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

4.4.2.1 Record the Ingredients in Descending Order as per the Master Formula . . . . . . . . . . . 6

4.4.2.2 Verify the Ingredients Used (Raw Materials) and their Components . . . . . . . . . . . . . . . 7

4.4.2.3 Verify the List of Ingredients Declared on the Label . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

4.4.2.4 Verify the Declaration of Food Allergens, Gluten Sources and Added Sulphites . . . . . 17

4.4.2.5 Verify the Trans lation of the List of Ingredients . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

4.4.2.6 Final Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

4.5 Inspection Procedures - Other than at the Manufacturing Level . . . . . . . . . . . . . . . . . . . . . . . . . 19

4.5.1 Select a Product . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

4.5.2 Complete the Ingredient Verification Worksheet . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

4.5.2.1 Record the Ingredients and Components Declared on the Label . . . . . . . . . . . . . . . . . 21

4.5.2.2 Assess if the Ingredients Declared are Permitted in the Food . . . . . . . . . . . . . . . . . . . 21

4.5.2.3 Assess if the Components Declared are Permitted in the Ingredients . . . . . . . . . . . . . 23

4.5.2.4 Assess the Common Names Used for Declaring Ingredients and Components . . . . . 24

4.5.2.5 Assess the Descending Order of Ingredients and Components . . . . . . . . . . . . . . . . . . 25

4.5.2.6 Assess if the Components are Declared, W hen Required . . . . . . . . . . . . . . . . . . . . . . 26

4.5.2.7 Verify the Declaration of Food Allergens, Gluten Sources and Added Sulphites . . . . . 26

4.5.2.8 Verify the Trans lation of the List of Ingredients . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

4.5.2.9 Final Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

4.6 Unsatisfactory or Pending Inspection Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

4.7 Com plete and Distribute the Inspection Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Annex 4A

W orksheet 4-1: ingredient verification for processed products at the manufacturing LEVEL . . . . . . . . . 32

Page amended 2013/04/20, Manual published 2009/11/25

Processed Products - Product Inspection Manual




Annex 4B W orksheet 4-2: ingredient verification for processed products at other than the manufacturing level . 36

Annex 4C

Declaring ingredients subject to omissions, substitutions and variations . . . . . . . . . . . . . . . . . . . . . . . . 39

Annex 4D

Food additives, vitamins and m ineral nutrients . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

1) Food Additives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

2) Vitam ins and Mineral Nutrients . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

Annex 4E

Exemptions from Component Listings [B.01.009, Fdr] . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

1) Ingredients Exempt from Com ponent Listings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

2) Preparations and Mixtures Exempt from Component Listings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

3) Components and Components of Components of Preparations or Mixtures W hich Must ALW AYS be

Declared . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

4) Peanut Oil (all forms) Must ALW AYS be Declared . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56

Annex 4F

Common Names for Ingredients and Components . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

1) Mandatory Common Names . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

2) Optional Common Names . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60

3) Class Names . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

4) Chemical Names of Food Additives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64

Annex 4G

Enhanced Labelling of Food Allergens, Gluten Sources and Added Sulphites . . . . . . . . . . . . . . . . . . . . 65

1) Food Allergens and Gluten Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67

a) Added as Ingred ients . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67

b) Added to Ingredients that are NOT EXEMPT from Declaring their Components . . . . . . . . . . . . 68

c) Added to Ingredients that are EXEMPT from Declaring their Components . . . . . . . . . . . . . . . . 68

2) Sulphites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69

a) Sulphites Added as Ingredients . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69

b) Sulphites Added to Ingredients that are NOT EXEMPT from Declaring their Components

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69

c) Sulphites Added to Ingredients that are EXEMPT from Declaring their Components

MUST be Declared if Sulphites are Present at > 10 ppm in the Final Food . . . . . . . . . 70




3) Precautionary Statements for Food Allergens, Gluten Sources and Sulphites . . . . . . . . . . . . . . . . . 71

Annex 4H

Declaring W ater in the Ingredient List . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72

Annex 4I

Processing Aids . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73




4.1 Objective

To verify that:

i) domestic and imported1 processed products meet the compositional requirements prescribed

by the Processed Products Regulations (PPR) and/or the Food and Drug Regulations (FDR);

ii) the list of ingredients is complete, accurate, and in descending order of proportion by weight;

and

iii) the ingredients meet the applicable compositional requirements under the PPR and/or the

FDR.

4.2 Scope

This activity applies to all domestic and imported processed products that are prepackaged or in

bulk.

4.3 Required Forms, Equipment and References

4.3.1 Forms

• W orksheet 4-1: Ingredient Verification for Processed Products at the Manufacturing Level

(See Appendix 4A)

• W orksheet 4-2: Ingredient Verification for Processed Products at Other than the

Manufacturing Level (See Appendix 4B)

• Inspector Non-Compliance Report (Short Form) (CFIA / ACIA 5393)

• Notice of Detention (CFIA / ACIA 3256)

• Official Seal Tape - Yellow (CFIA / ACIA 4561)

• Notice of Release from Detention (CFIA / ACIA 3257)

4.3.2 Equipment

• Calculator

4.3.3 References

• Canada Agricultural Products Act (CAPA)

• Processed Products Regulations (PPR)

• Food and Drugs Act (FDA)

• Food and Drug Regulations (FDR)

• Lists of Permitted Food Additives

• The 2003 Guide to Food Labelling and Advertising (the Labelling Guide)

• Food Allergies and Allergen Labelling

• A Tool for Managing Allergen Risk in Food Products

• The Use of Food Allergen Precautionary Statements on Prepackaged Foods

• Policy for Differentiating Food Additives and Processing Aids

• Food Additive Dictionary

1 W hen inspections are conducted on the m anufacturer’s premises, inspectors have access to

master formulas, raw materials and they can observe products being made. However, when inspections

are conducted elsewhere (e.g., importer, distr ibutor), the inspection tasks differ. Therefore, task 4.4 in this

chapter covers the inspection procedures at the manufacturing level and task 4.5 covers the inspection

procedures other than at the manufacturing level. All other tasks apply equally, no matter where the

inspection is conducted.

http://laws.justice.gc.ca/en/C-0.4/index.html

http://laws.justice.gc.ca/en/C-0.4/C.R.C.-c.291/index.html

http://laws.justice.gc.ca/en/F-27/index.html

http://laws-lois.justice.gc.ca/eng/regulations/C.R.C.,_c._870/index.html

http://www.hc-sc.gc.ca/fn-an/securit/addit/list/index-eng.php

http://www.inspection.gc.ca/english/fssa/labeti/guide/toce.shtml

http://www.inspection.gc.ca/english/fssa/labeti/allerg/allergee.shtml

http://www.inspection.gc.ca/english/fssa/invenq/inform/toualle.shtml

http://www.hc-sc.gc.ca/fn-an/label-etiquet/allergen/precaution_label-etiquette-eng.php

http://www.hc-sc.gc.ca/fn-an/pubs/policy_fa-pa-eng.php

http://www.hc-sc.gc.ca/fn-an/alt_formats/hpfb-dgpsa/pdf/securit/dict_add-eng.pdf




4.4 Inspection Procedures - at the Manufacturing Level

W henever possible, perform an ingredient verification in conjunction with a label verification (as

explained in Chapter 3 - Label Verification).

To complete the ingredient verification, follow the steps described below.

4.4.1 Select a Product

Choose a food product that is subject to the PPR. For ease of reference, consult Table 11-1

in the Guide To Food Labelling and Advertising (the Labelling Guide). If a product is not

specifically listed in this Table, it may fall under a class of foods subject to a generic standard

of identity in Schedule II, PPR, as explained in task 1.7.4.2 of Chapter 1 - Introduction.

Prioritize your product selection by targeting a product:

i) with potential health and safety implications (e.g., undeclared priority allergens);

ii) with a known or suspected non-conformity (e.g., as a result of a complaint, spotted

during other inspection activities);

iii) for which a label verification is also being performed (as per Chapter 3 - Label

Verification);

iv) being processed during an In-Depth or Directed inspection;

v) that is new or has a new label; or las tly

vi) other reason deemed valid by the inspector.

4.4.2 Complete the Ingredient Verification Worksheet

A com plete evaluation of a processed product label can be a complex task. In order to help

the inspector’s process of evaluation, a worksheet has been developed. Following each

section of the worksheet will ensure all aspects of the label have been verified, step by step.

Each section is explained below and directly refers to W orksheet 4-1: Ingredient Verification

for Processed Products at the Manufacturing Level, found in Appendix 4A. This appendix also

contains an example of a completed worksheet, based on the product “strawberry jam”.

Steps to follow to complete Worksheet 4-1:

On the upper portion:

a) Record your name, the date of inspection, the name, address and registration number of

the registered establishment, and the product description. In the “Quantity of Labels” box,

record the number of labels for the selected product ( i.e., same product, same label,

same net quantity) that the establishment has in inventory.

b) Indicate the predominant Schedule, Table (if applicable) and Section of the PPR to which

the product is subject. Since a product may be subject to more than one schedule,

indicate the first schedule (i.e., the predominant schedule) to which the product is

subject.

Examples:

• Canned “apple juice” is subject to grade markings in Schedule I, Table I, Section

3 (predominant schedule) and to prescribed container sizes in Schedule III, Table

I, Section 3 of the PPR. You would indicate Schedule I, Table I, Section 3 on the

worksheet.




• “Strawberry jam” is subject to the “(naming the fruit) jam” standard of identity in

Schedule II, Section 2(1) and to prescribed container sizes in Schedule III, Table

III, Section 14 of the PPR. You would indicate Schedule II, Section 2(1) on the

worksheet.

For details on the application of the PPR and how to determ ine which schedule(s) apply

to a product, refer to task 1.7 in Chapter 1 - Introduction.

Each column or section of the worksheet is numbered to correspond to each specific task

described below.

Example: Column 1of the worksheet corresponds to task 4.4.2.1and column 2(A)

corresponds to task 4.4.2.2(A) below.

Once you have listed and assessed the ingredients and components, record your findings for

each part as satisfactory (S), unsatisfactory (U), not applicable (N/A), under evaluation or not

assessed, as applicable.

Note: Although the FDR contains no specific prohibition against descriptive information

regarding each ingredient in the list of ingredients, descriptions should only be

used in specific instances and m ust not be misleading. Exam ples of acceptable

practices include:

• Specifying the function of a food additive [e.g., “sodium benzoate (a

preservative)”, “citric acid (to maintain acidity)“].

• Highlighting an agricultural practice or nature of an ingredient (e.g., “organic

strawberries”, “fresh strawberries”).

• Including factual descriptions separately and distinctly from the list of

ingredients on any other part of the label (e.g., an asterisk placed after an

ingredient to reference additional information below the ingredient list).

4.4.2.1 Record the Ingredients in Descending Order as per the Master Formula

The master form ula is the manufacturer’s recipe, which provides the identity and quantity

of each ingredient used to prepare the product. Master formulas are confidentia l. Only

use them within the establishment to perform the ingredient verification. You should not

rem ove a form ula from the establishment or write exact quantities on your worksheet. If

you need to use exact amounts for calculations, write them on a separate piece of paper

and leave it with managem ent for disposal.




Example: Tasty Fruit Company’s Strawberry Jam

Tasty Fruit Com pany

Strawberry Jam Master Formula

115 kg Strawberries

20 L W ater

112 kg Sugar

0.65 kg Pectin

0.60 kg Lemon juice or 0.15 Kg citr ic acid

0.15 kg Sodium benzoate

248.4 kg Total weight (133.3 kg soluble solids)

Total yield = 205.0 kg

In column 1 of W orksheet 4-1, record (on separate lines) each ingredient in descending

order of proportion by weight, before they are combined to make the final food. If the

form ula indicates certa in ingredients by volume, you m ust convert these volum es to

weight to determine the proper descending order of the ingredients (e.g., one cup of

apple juice weights more than one cup of flour so you must list the juice first).

Example: Using Tasty Fruit Company’s master formula, the descending order

would be: strawberries, sugar, water, pectin, lemon juice or citric acid,

sodium benzoate.

W here appropriate, manufacturers may substitute, vary or omit certain ingredients from

their formula based on availability, pricing, etc., as per B.01.011 of the FDR. For details,

see Part 1 - Declaring Ingredients that are Subject to Omissions, Substitutions and

Variations in Appendix 4C. W hen listing the ingredients on the worksheet, record these

potential variations, if any are identified in the formula.

Example: If lemon juice and citric acid were used interchangeably at least once

during the year, you would write “lemon juice or citric acid” in column 1

of the worksheet.

4.4.2.2 Verify the Ingredients Used (Raw M aterials) and their Components

Components are ingredients of ingredients (i.e., 2nd generation ingredients in the final

food).

A) List the Ingredients Used and their Components

To confirm the accuracy of the master formula and to determine the components of

the ingredients, ask to see the actual ingredients used. These ingredients are

usually located in the mixing/processing area of the establishment or in the storage

room. The name of the ingredient and its components are either listed on the

container of the ingredient itself or on a specification sheet provided by the supplier

of the ingredient.

In column 2(A) of Worksheet 4-1, list (on separate lines):

• the actual ingredients used and their components;

• any food allergens, gluten sources and added sulphites that are declared on the

ingredient’s label (as components of components and beyond, in a “Contains”

statement or in a precautionary statement). These will be assessed at task

4.4.2.4; and




• any other useful information from the ingredient packages and specification

sheets (e.g., brand nam e, nam e and address declared on the label). This will

specifically identify the raw materials you have seen and help pinpoint any future

substitutions in the raw materials, which may affect the compliance of the

ingredient and/or product, as well as the accuracy of the label.

Example: In the mixing area, you notice two of the actual ingredients used are

different from those specified in Tasty Fruit Company’s master

formula (recorded in column 1 of the worksheet):

• “Pectin preparation containing sugar, pectin and fumaric acid” is

used rather than “pure pectin”; and

• “Lemon juice from concentrate containing water, concentrated

lemon juice, lemon oil and sulphites” is added rather than “pure

lemon juice”.

In column 2(A), you would list “strawberries, sugar, water, pectin

preparation [ABC Brand] (sugar, pectin and fumaric acid), lemon juice

from concentrate [XYZ Brand] (water, concentrated lemon juice,

lemon oil and sulphites) and sodium benzoate”.

(B) Assess if the Ingredients and Amounts Added are Permitted

If possible, observe a batch of product as it is being prepared to confirm the actual

amount of each ingredient added. If this is not possible, use the company’s make

sheet (i.e., the form employees complete when they prepare a batch of product) from

a previous production run or the batch formula used by employees on the floor.

Observe the handling and storage conditions for any of the food allergens, gluten

sources and sulphites (see 4.4.2.4) that may be present in the fac ility. In the

“com ments” section of W orksheet 4-1, identify any potential areas of cross-

contamination with these substances via personnel, storage, equipment, etc.

Example: The establishment produces peanut butter, using some of the same

equipment that is used for mak ing jam. Peanuts are one of the food

allergens and the sharing of equipment increases the potential for

allergen cross-contamination. You should make a note of this in the

“comments” section of the worksheet.

Assess the ingredients listed in columns 1 and 2(A) for compliance with the

compositional requirements prescribed for the food by the PPR and/or the FDR.

For details on the use of ingredients other than food additives, vitamins or

mineral nutrients, see Chapter 1:

• 1.7.3.3 - “Ingredients Permitted in Graded Products”;

• 1.7.4.3 - “Ingredients Permitted in Foods Subject to Standards of Identity”; or

• 1.7.5.1 - “Ingredients Permitted in Foods Subject Only to Prescribed Container

Sizes”.




Notes:

1) Contrary to popular belief, flavour enhancers are ingredients, not food

additives. They are permitted in foods that allow the addition of spices

and/or seasonings. Since flavour enhancer are not listed in the

Regulations, they are listed here for convenience:

• calcium guanylate

• calcium inosinate

• calcium ribonucleotides

• disodium guanylate

• disodium inosinate

• hydrolyzed plant protein

• monopotassium glutam ate

• monosodium glutam ate

• sodium ribonucleotides

2) Subsection 29.(2) of the PPR requires that when sugar, invert sugar,

dextrose or glucose in dry form is added to the frozen fruits listed in Table

IV of Schedule IV, the minimum percentage of those ingredients that must

be added is as prescribed in that Table.

For details on the use of food additives, vitamins and mineral nutrients, see

Appendix 4D.

If the ingredient(s), including food additives, vitamins and m ineral nutrients, added to

the product are not listed in the PPR, CFIA may have granted a Test Market

Authorization (TMA) to the com pany for the use of the ingredient(s) in their specific

product. Before taking enforcement action, ask the company if they have obtained a

TMA.

For more details on TMAs see Chapter 13 - Test Market Authorizations.

In column 2(B) of Worksheet 4-1, indicate whether or not the ingredients listed in

columns 1 and 2(A) are allowed in the food and respect the prescribed levels, as per

the PPR and/or FDR. If you find discrepancies between the actual ingredients added

and the ingredients identified in the master recipe, compare each ingredient, or

amount of ingredient, to the regulatory requirements for the food. If both meet the

requirements, assess your findings as satisfactory (S). If one or both ingredients do

not meet the requirements, assess your findings as unsatisfactory (U).

In the “comm ents” section of Worksheet 4-1, record any discrepancies between

the actual ingredients added and the ingredients identified in the master formula.

If any standardized products present omissions of ingredients required by the

regulations, these omissions must also be recorded in the “comments” section.

Example:

Strawberry jam is subject to the “(Nam ing the fruit) Jam ” standard of identity in

Schedule II, Section 2(1), PPR. Therefore, the Tasty Fruit Company’s strawberry

jam must contain strawberries (at least 45% in the finished product), water and

sugar, and may contain pectin, pectin preparation, an acid ingredient and a

preservative.




Note: Strikeouts have been added in the worksheet example (Appendix 4A) to indicate that column 2(B) does not apply to com ponents and colum ns 2(C) and (D) do not apply to

ingredients.

W hen comparing the actual amount of each ingredient added to the amount

specified in the master formula, you notice all amounts correspond, except for

the strawberries. Assessing each ingredient in columns 1 and 2(A), you would

conclude that:

(i) Strawberries are permitted (m andatory ingredient).

• According to the master formula, the fruit content of the final product

is:

115 kg fruit x 100 = 56 %

205.0 kg jam

• The actual am ount added to the batch is 110 kg, so the actual fruit

content of the final product is:

110 kg fruit x 100 = 54 %

205.0 kg jam

Both am ounts (54% and 56% ) meet the standard for percentage of fruit.

Therefore, you would indicate satisfactory (S) in column 2(B) for the

strawberries and record the discrepancy in the “comments” section of the

worksheet.

(ii) Sugar and water are permitted (mandatory ingredients) with no prescribed

amounts. Therefore, you would indicate satisfactory (S) in column 2(B) for

these ingredients.

Note : Even though water is a mandatory ingredient in jam, the

moisture content in some fruits can be sufficient to make

jam. Therefore, if you encounter a product that meets the

jam standard except for the addition of water, consider the

product compliant.

(iii) Pectin (master formula) or pectin preparation (actual ingredient used) is a

permitted food additive. The amount permitted by the PPR is the amount of

pectin needed to reasonably compensate for any deficiency in the natural

pectin content of the fruit. The amount of pectin permitted by the FDR (via

List 4 of the Permitted Food Additives, as explained in Appendix 4D) is

indicated as “good manufacturing practice” (i.e., suffic ient quantity to obtain

the effect needed). Therefore, you would indicate satisfactory (S) in column

2(B) for the pectin.

(iv) Lemon juice (master formula), lemon juice from concentrate (actual

ingredient used) and citric acid (master formula) are permitted because

they are listed under “acid ingredient” in Schedule II, Section 1 of the PPR.

In the PPR, there is no prescribed am ount for the addition of juice or c itric

acid. Since citric acid is a food additive, the Lists of Permitted Food

Additives must be consulted to confirm the amount of citric acid permitted.

In List 10 - Permitted pH Adjusting Agents (item C.14), the maximum level

of use for citric acid in strawberry jam is indicated as “good manufacturing

practice” (i.e., sufficient quantity to obtain the effect needed). Based on the




master formula, juice or citric acid are added. Since juice is the actual

ingredient used during the inspection, the m anufacturer confirmed that citr ic

acid is still added to the product at least once a year. Therefore, in column

2(B) you would indicate satisfactory (S) for these ingredients. In the

“com ments” section of the worksheet, you would record that “citric acid is

occasionally used during the year instead of lem on juice from concentrate

(as per the master formula)”.In the "Com ments" section of the worksheet, it

would be listed as "citric acid is used occasionally during the year instead of

lemon juice from concentrate as indicated in the recipe."

(v) Sodium benzoate:

• The PPR allows the addition of a preservative but does not specify

which one. In List 11 - Perm itted Preservatives (Class 2, item S.1),

sodium benzoate is permitted in the sam e foods as listed for benzoic

acid. Under benzoic acid (item B.1), jam is listed in Colum n II.

Therefore, sodium benzoate is allowed in jam.

• Column III (List 11, item B.1) prescribes a maximum amount of 1000

ppm for sodium benzoate (calculated as benzoic acid).

In order to determ ine if the amount of sodium benzoate added to

Tasty Fruit Company’s jam is acceptable, you would need to:

1) Convert the kilograms of sodium benzoate added to parts per

million present in the final food using the following form ula:

1 mg1 ppm =

1 kg

Since 0.15 kg (150, 000 mg) of sodium benzoate is added, then:

150,000 mg sodium benzoate P ppm =

205 kg jam

P = 732 ppm

Therefore, 732 ppm of sodium benzoate is present in the jam.

2) Convert sodium benzoate to benzoic acid using their molecular

weights, as explained in Part 1(d) of Appendix 4D:

C ppm reference chem ical = x ppm added chemical

A

where: “C” is the molecular weight of the reference chemical

(i.e., the molecular weight of benzoic acid), and

“A” is the m olecular weight of the added chem ical (i.e.,

the molecular weight of sodium benzoate)




122.12 g/mol P x 732 ppm ppm benzoic acid =

144.11 g/mol sodium benzoate

P = 620 ppm benzoic acid

732 ppm of sodium benzoate works out to 620 ppm of benzoic

acid, which is less than the maximum allowable amount of 1000

ppm. Therefore, you would indicate satisfactory in column 1(B)

for the sodium benzoate.

C) Assess if the Components are Perm itted in the Ingredients

Ingredients are foods on their own and must meet the respective compositional

requirements established in the PPR, FDR and other applicable legislation.

Therefore, components of ingredients must be permitted in the ingredient to which

they are added. Components of an ingredient do not need to be permitted in the final

food.

In column 2(C) of Worksheet 4-1, indicate whether or not each component is

perm itted in the corresponding ingredient.

Example: The pectin preparation is an unstandardized food in the FDR.

Therefore, it may contain any ingredients (including sugar) and any of

the food additives permitted in unstandardized foods for the specified

purpose (including pectin and fumaric acid, as per the Lists of

Perm itted Food Additives). Therefore, you would indicate satisfactory

(S) in column 2(C) for sugar, pectin and fumaric acid. Even though

fumaric acid cannot be added directly to jam , it is permitted in pectin

and pectin is permitted in jam.

D) Assess if the Components are Exempt from Being Declared on the Label

Components of ingredients must be declared in the list of ingredients of the final

food, unless they are exempt, as explained in Appendix 4E.

In column 2(D) of Worksheet 4-1, indicate whether or not each component listed in

column 2(A) is exempt from being declared in the list of ingredients of the final food.

Examples:

• A “pectin preparation” is a “food additive preparation”. As explained in

Appendix 4E, B.01.009(2) of the FDR exem pts components of food additive

preparations from being declared in the list of ingredients of the final food,

except those components listed in B.01.009(3) and (4) of the FDR, and

components that are food allergens or gluten sources (present at any level

in the final food) or added sulphites (if present at 10 ppm or more in the

final food) (see Appendix 4G). In this example, you must determine if each

component is specifically listed in B.01.009(3) or (4), or if it has an effect on

the final food (i.e., on the jam), as per B.01.009(3)(f). Assessing each

com ponent listed in column 2(D), you would conclude that:

< Sugar is not specifically listed in B.01.009(3) or (4). Based on the

direct addition of sugar and the naturally occurring sugars in the

strawberr ies, the amount of sugar that the pectin preparation adds to

the jam does not affect the final food. Therefore, sugar is exempt from




being declared as a component of the pectin preparation.

< Pectin is a gelling agent. It is not specifically listed in B.01.009(3) or

(4), but it affects the texture of the jam, so it must be declared, as per

B.01.009(3)(f).

< Fumaric acid is a pH adjusting/water correcting agent. It is not listed in

B.01.009(3) or (4), but it affects the acidity of the jam, so it must be

declared, as per B.01.009(3)(f).

• “Lem on juice from concentrate” is not listed in B.01.009(1) or (2), FDR.

Therefore, its components are not exempt from being declared in the list of

ingredients of the jam.

4.4.2.3 Verify the List of Ingredients Declared on the Label

Because the list of ingredients on a label informs consumers about the content of a

product, the list must accurately ref lect the com position of the product.

A) List the Ingredients and Components Declared on the Label

In column 3(A) of Worksheet 4-1, record (on separate lines):

• the ingredients and their components, as they appear on the label; and

• any food allergens, gluten sources and added sulphites that are declared in a

“Contains” statement or in a Precautionary statement (these statements are

explained in Appendix 4G and will be assessed at task 4.4.2.4).

Example: The label declares “Ingredients: strawberries, sugar, lemon juice,

pectin, fum aric acid, sodium benzoate. May contain peanuts.”

Therefore, that is what you would record in column 3(A).

B) Assess the Descending Order of Ingredients and Components

1) Ingredient Declaration

Ingredients must be shown in descending order of their proportion by weight

or as a percentage of the prepackaged product. The proportion or percentage is

based on the amount of each of the ingredients before they are com bined to

form the fina l product.

Exceptions:

a) The following ingredients can be declared in any order at the end of the list

[B.01.008(4), FDR]:

i) spices, seasonings and herbs, except salt2;

ii) flavours and artificial flavours;

iii) flavour enhancers;

iv) food additives, except ingredients of food additive preparations or

mixtures of substances for use as a food additive;

v) vitamins;

2 As an ingredient and/or component, salt must always be declared in descending order of

proportion by weight.




vi) salts of vitamins or derivatives of vitamins;

vii) mineral nutrients; and

viii) salts of mineral nutrients.

b) Some ingredients can be grouped together and declared collectively as

general comm on names. In these cases, the sum of the grouped

ingredients is used to determine the proportion in the final food. For details,

see Part 1 - Mandatory Common Names, Part 2 - Optional Common

Names and Part 3 - Class Names in Appendix 4F;

c) The proportion of water can be considered before or after the product is

cooked. Furthermore, it may be considered as a processing aid if it

completely evaporates during processing (see Appendix 4H); and

d) Processing aids are exempt from being declared on the label (see

Appendix 4I).

2) Component Declaration

Components that are not exempt from being declared must be shown in

descending order of their proportion by weight in the ingredient to which they

are added. There are two options which can be used to achieve this:

Option 1:

Nam ing the ingredient and immediately declaring its components, in

descending order. W ith th is option, com ponents are either declared in

brackets, or preceded by a colon or the word “containing”.

Examples:

• ...lemon juice from concentrate (water, concentrated lemon juice,

lemon oil, sulphites), ...

• ...lemon juice from concentrate: water, concentrated lemon juice,

lemon oil, sulphites; ...

• ...lemon juice from concentrate containing water, concentrated

lemon juice, lem on oil, sulphites; ...

Option 2:

Listing the components as if they were direct ingredients.

Example: ...water, concentrated lemon juice, lem on oil, sulphites...

This option saves space in the list of ingredients since the actual ingredient

added (i.e., lemon juice from concentrate) is not declared and the comm on

components are grouped together and listed only once, in descending

order, based on their combined weight in the final food. W hen this option is

used, it must be used for all ingredients and components listed on the label.

In order to determine the proper descending order of the components in the

final food, a company must know the proportions of the components used

by his ingredient supplier.

Example:

In the list of ingredients of the jam, “lemon juice from concentrate”

could be declared as follows:




• Original Ingredients - Using Option 1:

Strawberries, sugar, water, pectin, lemon juice from concentrate

(water, concentrated lemon juice, lemon oil, sulphites), fumaric

acid, sodium benzoate.

• Simplified Ingredients - Using Option 2:

Strawberries, sugar, water, pectin, concentrated lemon juice,

lemon oil, sulphites, fumaric acid, sodium benzoate.

In column 3(B) of Worksheet 4-1, indicate whether or not the order of ingredients

declared on the label [listed in column 3(A)] matches the order you listed in columns

1 and 2(A) of the worksheet, taking into consideration the exemptions discussed

above.

Example: By comparing columns 2(A) and 3(A), your assessment in column

3(B) would be:

2(A)

Ingredients

Used

3(A)

Ingredients

on the Label

3(B)

9

Order

Explanation

strawberries strawberries S The order is the same.

sugar sugar S The order is the same.

water - - W ater is not declared on the label.

Since water completely evaporates

during processing, it is exempt from

being declared on the label, as

explained in 4.4.2.3 (B)(1)(d) above.

pectin lemon juice S The order of declaration is reversed

between pectin and lemon juice.

However, pectin is a food additive so it

may be declared at the end of the list

of ingredients in any order, as

explained in 4.4.2.3 (B)(1)(a)(iv)

above.

lemon juice

from

concentrate

pectin S

sodium

benzoate

fumaric acid S Fumaric acid is a component of the

pectin preparation which must be

declared on the jam label. Fum aric

acid is a food additive so it may be

declared in any order at the end of the

list of ingredients.

- sodium

benzoate

S Sodium benzoate is a food additive. It

may be declared in any order at the

end of the list of ingredients.

Legend: S = satisfactory

C) Assess the Common Names Used for Declaring Ingredients and Components

Each ingredient and component must be declared by its comm on name. The

acceptable comm on name of a food may not necessarily be an acceptable comm on




nam e for the same food when used as an ingredient or component.

As explained in Part 1 of Appendix 4F, some mandatory ingredient/component

nam es are prescribed by B.01.010(3)(a), FDR. If not prescribed therein, then the

comm on name is:

a) the optional com mon name prescribed by B.01.010(3)(b), FDR (see Part 2 in

Appendix 4F);

b) the class nam e permitted by B.01.010(4), FDR (see Part 3 in Appendix 4F);

c) the bold faced name in the FDR (see 1.7.6 in Chapter 1 - Introduction) or the

chemical name shown in one of the Lists of Permitted Food Additives (see Part 4

in Appendix 4F);

d) the name prescribed by any other statute (e.g., Dairy Products Regulations); or

e) the name by which the ingredient/com ponent is commonly known (see 1.7.4.2 in

Chapter 1 - Introduction).

In column 3(C) of Worksheet 4-1, indicate whether or not the ingredients and their

components are listed on the label by their proper comm on names.

In the “comments” section of the worksheet, record any:

• ingredients listed in colum ns 1and 2(A) that are not declared on the label,

and not exempt; and

• components listed in column 2(A) that are not declared on the label and

are not exempt from being declared (as identified in column 2(D) of the

worksheet).

Example:

You would indicate in column 3(C), the common names used on the label as

follows:

• "Strawberries": satisfactory

• "Sugar": satisfactory

• "Lemon juice": unsatisfactory. Then, you would indicate the following

in the “comments” section of the worksheet:

< "Lemon juice from concentrate (containing water, concentrated

lemon juice, lemon oil and sulphites) is added but not declared

on the jam label. The components of the juice are not exempt

from being declared. Lemon juice is declared on the label but not

added.”

< “Citric acid is not declared on the label (as a substitute for lemon

juice from concentrate)”.

• "Pectin": satisfactory




Note:

Even though a "pectin preparation" was added rather than "pure

pectin", components may be declared as if they were direct

ingredients, as per 4.4.2.3 (B)(2)(c) above.

• “Fum aric acid”: satisfactory

Note:

Fumaric acid is a component of the pectin preparation that has

an effect on jam. It must be declared as if it was added as an

ingredient.

• "Sodium benzoate": satisfactory

4.4.2.4 Verify the Declaration of Food Allergens, Gluten Sources and Added Sulphites

As seen in task 4.4.2.2 (D), some com ponents are exempt from being declared on the

label of prepackaged foods, and, as per task 4.4.2.3 (C), ingredients and components

must be declared by their comm on names.

However, B.01.010.1 to B.01.010.3 of the FDR exclude food allergens, gluten sources

and added sulphites from component exemptions listed in B.01.009 (1) and (2) and

require additional labelling when the com mon nam es of ingredients or com ponents are

hidden sources of food allergens, gluten sources and added sulphites.

Assess if food allergens, gluten sources and added sulphites present3 in the food are

clearly indicated, by their prescribed source names, in the list of ingredients, or at the end

of the list of ingredients in a “Contains” statem ent. For details, see Appendix 4G .

In section (4) of Worksheet 4-1, place an “x” or a checkmark to indicate the presence

of food allergens, gluten sources and added sulphites in the food (if any), based upon

column 2(A) and on the “comm ents” section of the worksheet. If food allergens, gluten

sources and/or added sulphites are:

• not present3, mark your findings as not applicable (N/A). Proceed to task 4.4.2.5.

• present3, refer to column 3(A) of W orksheet 4-1 to assess if food allergens, gluten

sources and/or added sulphites are declared by their prescribed source name in the

list of ingredients and/or in a “Contains” statement. If they are:

i) declared, mark your findings as satisfactory (S).

ii) not declared, mark your findings as unsatisfactory (U).

3 Present means:

• Food allergens and gluten sources are detectable, by current methodology, or are known

to be intentionally added* to the food, regardless of amount present in the final food.

• The final food contains 10 ppm or more of sulphites as a result of being added*.

* Added as ingredients, components, components of components, etc, or as hidden sources of

ingredients, components, etc. (e.g., sodium caseinate is a hidden m ilk allergen).




suspected of being present3 but not declared, i.e., you are unable to confirm the

amount of added sulphites present in the final food, through calculation or laboratory

analysis (i.e., satisfactory if less than 10 ppm; or unsatisfactory if 10 ppm or more), mark

your findings as under evaluation.

Example: Sulphites added to the lemon juice from concentrate are not declared

in the list of ingredients of Tasty Fruit Company’s jam. In this case, the

amount of sulphites present is irrelevant since all the components of

the juice shall be declared on the label jam.

Note: If more than one food allergen, gluten source and/or sulphites was assessed,

mark your overall assessment in section (4) as:

• Satisfactory (S) if they were all assessed as (S); or

• Unsatis factory (U) if one or m ore were assessed as (U). Add a circle

around the allergen, gluten source and/or sulphites that are unsatisfactory;

and/or

• Under evaluation if the amount of sulphites present is unknown.

4.4.2.5 Verify the Translation of the List of Ingredients

Assess whether or not the French list of ingredients on the label corresponds to the

English list. The order in which ingredients are listed must be the same in both

languages. However, since some ingredients may be listed in any order at the end of the

list, as explained in task 4.4.2.3(B) above, those ingredients should be declared in the

same order in both languages to avoid confusion.

If you are unsure of the proper legal translation of ingredients, you can use the

regulations as translation tools:

• Food products and their ingredients are listed in the same order in both the

English and French versions of the PPR and of the FDR;

Examples:

< “Apple juice” in listed in Schedule I, Table I, Section 3 of the PPR. In the

French version (same section), “jus de pommes” is listed.

< “Sugar” is listed in B.18.001 of the FDR. In the French version of B.18.001,

“sucre” is listed.

Note: The Regulations may not be able to provide all the translations

needed, especially when a food is subject to a standard of identity. For

example, strawberry jam falls under the standard “(nam ing the fruit)

jam” in Schedule II, Section 2.(1), PPR. So, if you checked Schedule

II, Section 2.(1) in the French PPR, you would find “confiture de (nom

du fruit)” rather than “confitures aux fraises”.




• Food additives are listed alphabetically and an item num ber is assigned to each

additive within each English Lists of Permitted Food Additives. These lists are

explained in Appendix 4D. In the French Lists, the food additives are listed in order of

their item number (same item num bers as in the English FDR lists) rather than in

alphabetical order.

Example: The first two additives listed in List 1 of the Permitted Food Additives

are “calcium aluminum silicate” (item number C.1) and “calcium

phosphate” (item number C.2). To determine the French translation

for these two additives, go to item s C.1 and C.2 in the French List.

The translations are “silicate double d’aluminium et de calcium” (C.1),

and “phosphate tricalcique” (C.2):

Item No

English List French List

Additive Names Additive Names

C.1 calcium alum inum silicate silicate double d’aluminium et de calcium

C.2 Calcium phosphate tribasic phosphate tricalcique

In section (5) of Worksheet 4-1, indicate whether or not the French list of ingredients

corresponds with the English list. Record any discrepancies in the “comments” section

of the worksheet. If you are not bilingual and the applicable regulations do not allow you

to assess the translation, you should use a translation tool (e.g., Termium which is

available on CFIA’s internal website). If you still do not feel confident assessing the

French list of ingredients, you can indicate “not assessed”.

4.4.2.6 Final Assessment

If all columns and sections of Worksheet 4-1 are marked as satisfactory (S) and no

concerns are noted in the “comm ents” section of the worksheet, select the box for

“Complies with the PPR and the FDR” in the final assessment area at the bottom of the

worksheet. Proceed to task 4.7 - Complete and Distribute the Inspection Report.

If one or more of the columns or sections of Worksheet 4-1 contain an unsatisfactory

(U) rating and/or concerns are noted in the “comm ents” section of the worksheet, select

the box for “Does not comply with the PPR and the FDR” in the final assessment area

at the bottom of the worksheet. Proceed to task 4.6 - Unsatisfactory or Pending

Inspection Results.

If section (4) of Worksheet 4-1 is marked as under evaluation (i.e., the amount of

added sulphites present in the final food is unknown), select the box for “Pending” in the

final assessment area at the bottom of the worksheet. Proceed to task 4.6 -

Unsatisfactory or Pending Inspection Results.




4.5 Inspection Procedures - Other than at the Manufacturing Level

W henever possible, perform an ingredient verification in conjunction with a label verification (as

explained in Chapter 3 - Label Verification).

W hen examining a product at the importer/distributor level rather than at the manufacturing level,

you likely do not have access to the recipe and to the ingredients used. Therefore, you can

examine the list of ingredients for glaring errors. You can also request the regulated party to

obtain more information from the m anufacturer and/or you can subm it products for laboratory

analysis when needed.

By comparing the list of ingredients declared on the label to the com positional requirem ents

prescribed by the PPR and/or FDR, you can verify if all ingredients and components:

• declared on the label are perm itted in the food or in the ingredient (as applicable);

• declared on the label seem to be listed in proper descending order;

• declared on the label seem to be identified by the proper common names; and

• required by the standards are declared (i.e., no mandatory ingredients missing).

To complete the ingredient verification, follow the steps described below.

4.5.1 Select a Product

Choose a food product that is subject to the PPR. For ease of reference, consult Table 11-1

in the the Labelling Guide. If a product is not specifically listed in this Table, it may fall under a

class of foods subject to a generic standard of identity in Schedule II, PPR, as explained in

task 1.7.4.2 of Chapter 1 - Introduction.

Prioritize your product selection by targeting a product:

i) with a known or suspected non-conformity (e.g., as a result of a complaint, spotted

during other inspection activities);

ii) for which a label verification is also being performed (as per Chapter 3 - Label

Verification);

iii) that is new or has a new label; or

iv) that is not identified in (i) to (iii) above (at your discretion).




4.5.2 Complete the Ingredient Verification Worksheet

A com plete evaluation of a processed product label can be a complex task. In order to help

the inspector’s process of evaluation, a worksheet has been developed. Following each

section of the worksheet will ensure all aspects of the label have been verified, step by step.

Each section is explained below and directly refers to W orksheet 4-2: Ingredient Verification

for Processed Products at other than the Manufacturing Level, found in Appendix 4B. This

appendix also contains an example of a completed worksheet, based on the product

“canned sliced pears in pineapple juice from concentrate”.

Steps to follow to complete Worksheet 4-2:

On the upper portion:

a) Record your name, the date of inspection, the regulated party’s name, address and type

of operation (i.e., where you are conducting the inspection), and the product description.

In the “Quantity of Labels or Lot Size” box, record either the number of labels (i.e., same

product, same label, same net quantity) or the lot size (if the product is pre-labelled at

someone else’s premises) that the regulated party has in inventory.

b) Indicate the predominant Schedule, Table (if applicable) and Section of the PPR to which

the product is subject. Since a product may be subject to more than one schedule,

indicate the first schedule (i.e., the predominant schedule) to which the product is

subject.

Examples:

• Canned “sliced pears in light fruit juice syrup” is subject to:

< Schedule I, Table I, Section 37 (i.e., grade markings);

< Schedule III, Table I, Section 1 (i.e., prescribed container sizes);

< Schedule IV , Table I, Section A-16, (i.e., minimum net and drained

weights); and

< Schedule IV , Table III, Section 2(6) of the PPR (i.e., percent soluble

solids).

You would indicate Schedule I, Table I, Section 37 on the worksheet.

• Canned “condensed tomato soup” is subject to Schedule III, Table III, Section 3

of the PPR. You would indicate that on the worksheet.




Note: For details on the application of the PPR and how to determine which schedule(s) apply to a

product, refer to task 1.7 in Chapter 1 - Introduction.

Each column of the worksheet is numbered to correspond to each specific task described

below.

Example: Column (1) of the worksheet corresponds to task 4.5.2.1 below

Once you have listed and assessed the ingredients and components, record your findings as

satisfactory (S), unsatisfactory (U), not applicable (N/A), under evaluation or, not assessed,

as applicable.

4.5.2.1 Record the Ingredients and Components Declared on the Label

In column (1) of Worksheet 4-2, record (on separate lines):

• the ingredients and their components (i.e., the ingredients of the ingredients, or, the

2nd generation ingredients), as they appear on the label;

• any ingredient substitutions, variations or omissions, if any are identified in the list of

ingredients, as explained in Appendix 4C; and

• any food allergens, gluten sources and added sulphites that are declared in a

“Contains” statement or in a Precautionary statement (these statements are

explained in Appendix 4G and will be assessed at task 4.5.2.7 below.

Example: The ingredients declared on the label of canned sliced pears in light

fruit juice syrup are: “pears , water, sugar, grape ju ice from concentrate

(water, concentrated grape juice, vitamin C), citric acid”. Therefore,

that is what you would record in column (1).

4.5.2.2 Assess if the Ingredients Declared are Permitted in the Food

Assess the ingredients listed in column (1) for compliance with the compositional

requirements for the food prescribed by the PPR and/or the FDR.

For details on the use of ingredients other than food additives, vitamins or mineral

nutrients , see Chapter 1, tasks:

• 1.7.3.3 - “Ingredients Permitted in Graded Products”;

• 1.7.4.3 - “Ingredients Permitted in Foods Subject to Standards of Identity”; or

• 1.7.5.1 - “Ingredients Permitted in Foods Subject Only to Prescribed Container

Sizes”.

For details on the use of food additives, vitamins and mineral nutrients, see

Appendix 4D.




If the ingredient(s), including food additives, vitamins and mineral nutrients, added to the

product are not listed in the PPR, CFIA may have granted a Test Market Authorization

(TMA) to the company (e.g., domestic manufacturer, importer, broker) for the use of the

ingredient(s) in their specific product. Before taking enforcement action, ask the

company if a TMA was issued.

For more details on TMAs see Chapter 13 - Test Market Authorizations.

Since you are not on the manufacturers premises, you may not have access to the

master formula (i.e., the recipe) and to the information on each specific ingredient added

to the food. Therefore, flexibility in how ingredients and components are declared in the

list of ingredients can make your assessment a bit challenging. This is especially true

when components are declared in the list of ingredients as if they were direct ingredients,

as explained in 4.5.2.3 (option 2) below.

In column (2) of the W orksheet 4-2, indicate whether or not the ingredients listed in

column (1) are allowed in the food, as per the PPR and/or the FDR.

In the “comments” section of the worksheet, record any ingredients required by the

applicable standard, but are not shown in the list of ingredients (if any).

Example:

Canned “sliced pears in light fruit juice syrup” is subject to Schedule I, Table I,

Section 37 the PPR. Therefore, the canned pears:

• shall be packed in a packing media consisting of (as per Section 28.(1), PPR):

(a) water;

(b) fruit juice(s), fruit juice(s) from concentrate; or

(c) a syrup consisting of water, fruit ju ice(s), fruit ju ice(s) from concentrate, in

combination with sugar, invert sugar, honey, dextrose or glucose, in dry or

liquid form, or any combination thereof

• shall be the product prepared by heat processing properly prepared fresh fruit (as

per Schedule I, Table I, Section 1, PPR); and

• may contain c itric acid for m ore effective processing (as per Schedule I, Table I,

Section 37.(6), PPR).

Note: Strikeouts have been added in the worksheet example (Appendix 4B) to

indicate that column (2) does not apply to components and column (3) does

not apply to ingredients.

Assessing each ingredient listed in colum n (1), you would conclude that:

(i) Pears are permitted (mandatory ingredient) in canned pears.

(ii) W ater is permitted.




(iii) Sugar is permitted.

(iv) Grape juice from concentrate is permitted.

Note: W ater, concentrated grape juice and vitamin C are components

of the grape juice from concentrate. They will be assessed in

task 4.5.2.3.

(v) Citric acid is permitted.

Therefore, you would indicate satisfactory (S) in column (2) for the pears, water,

sugar, grape juice from concentrate, and citric acid.

4.5.2.3 Assess if the Components Declared are Permitted in the Ingredients

Components are ingredients of ingredients (i.e., 2nd generation ingredients). Ingred ients

are foods on their own and must m eet the respective compositional requirem ents

established in the PPR, FDR and other applicable legislation. Therefore, components of

ingredients must be permitted in the ingredient to which they are added. Components of

an ingredient do not need to be permitted in the final food.

Com ponents that are not exempt from being declared (see 4.5.2.6 below) must be

shown in descending order of their proportion by weight in the ingredient to which they

are added. There are two options which can be used to achieve this:

Option 1: Nam ing the ingredient and immediately declaring its components, in

descending order. The components are either declared in brackets, or

preceded by a colon or the word “containing”.

Examples:

• ..., grape juice from concentrate (water, concentrated grape juice,

vitam in C), ...

• ..., grape juice from concentrate: water, concentrated grape juice, vitamin C

• ..., grape juice from concentrate containing water, concentrated grape juice,

vitam in C, ...

Option 2: Listing the components as if they were direct ingredients.

Example: ...water,..., concentrated grape juice,... vitamin C

This option saves space in the list of ingredients since the actual ingredient added

(i.e., grape juice from concentrate) is not declared and the com mon com ponents are

grouped together and listed only once, in descending order, based on their combined

weight in the final food. W hen this option is used, it must be used for all ingred ients

and components listed on the label. In order to determine the proper descending

order of the components in the final food, a company must know the proportions of

the components used by his ingredient supplier.

Example: In the list of ingredients of the canned sliced pears in light fruit juice




syrup, “grape juice from concentrate” could be declared as follows:

• Original Ingredients - Using Option 1:

Pears, water, sugar, grape juice from concentrate (water,

concentrated grape juice, vitamin C), citric acid.

• Simplified Ingredients - Using Option 2:

Pears, water, sugar, concentrated grape juice, vitam in C, citr ic

acid.

If option 2 is used (i.e., declaring components as ingredients), you may need to

request the regulated party to obtain clarification from the manufacturer as it may be

impossible to determine if the component is an ingredient or a component in the final

food. This is especially important when components are permitted in the ingredient

but not permitted in the final food.

Example: Vitamin C is permitted in the grape juice from concentrate (as per

Schedule II, Section 16 of the PPR) but is not permitted in canned

pears (as per Schedule I, Table I, Section 37 of the PPR). Even

though vitamin C is declared as if it was an ingredient in canned

pears, it is added through the grape juice from concentrate which in

turn is permitted in canned pears.

In column (3) of the W orksheet 4-2, indicate whether or not the components listed in

column (1) are allowed in the ingredient to which it is added, as per the PPR and/or the

FDR

Example: In grape juice from concentrate, water and concentrated grape juice

are permitted (mandatory ingredients) and vitamin C is also permitted

(optional ingredient). Therefore, you would indicate satis factory (S) in

column (3) for the water, concentrated grape juice and vitamin C.

4.5.2.4 Assess the Comm on Names Used for Declaring Ingredients and Com ponents

Each ingredient and component m ust be declared by its com mon name. The acceptable

comm on name of a food may not necessarily be an acceptable comm on name for the

sam e food when used as an ingredient or component.

As explained in Part 1 of Appendix 4F, some mandatory ingredient/component names

are prescribed by B.01.010(3)(a), FDR. If not prescribed therein, then the comm on name

is:

a) the optional com mon name prescribed by B.01.010(3)(b), FDR (see Part 2 in

Appendix 4F);

b) the class nam e permitted by B.01.010(4), FDR (see Part 3 in Appendix 4F);




c) the bold faced name in the FDR (see 1.7.6 in Chapter 1 - Introduction) or the

chem ical name shown in one of the Lists of Permitted Food Additives(see Part 4 in

Appendix 4F);

d) the name prescribed by any other statute (e.g., Dairy Products Regulations); or

e) the name by which the ingredient/com ponent is commonly known (see 1.7.4.2 in

Chapter 1 - Introduction).

In column (4) of Worksheet 4-2, indicate whether or not the ingredients and their

components appear to be listed on the label by their proper comm on names.

Example:

Assessing each ingredient and component listed in column (1), you would conclude

that all comm on names used appear to meet the regulatory requirements. In column

(4), you would indicate:

• “Pears”: satisfactory

• “W ater”: satisfactory

• “Sugar”: satisfactory

• “Grape juice from concentrate”: satisfactory

• “(W ater)”: satisfactory

• “(Concentrated grape juice)”: satisfactory

• “(Vitamin C)”: satisfactory

• “Citric acid”: satisfactory

4.5.2.5 Assess the Descending Order of Ingredients and Com ponents

Ingredients must be shown in descending order of their proportion by weight or as a

percentage of the prepackaged product. The proportion or percentage is based on the

amount of each of the ingredients before they are com bined to form the fina l product.

Exceptions:

a) The following ingredients can be declared in any order at the end of the list

[B.01.008(4), FDR]:

i) spices, seasonings and herbs, except salt4;

4 As an ingredient and/or component, salt must always be declared in descending order of

proportion by weight.




ii) flavours and artificial flavours;

iii) flavour enhancers;

iv) food additives, except ingredients of food additive preparations or m ixtures of

substances for use as a food additive;

v) vitamins;

vi) salts of vitamins or derivatives of vitamins;

vii) mineral nutrients; and

viii) salts of mineral nutrients.

b) Some ingredients can be grouped together and declared collectively as general

com mon names. In these cases, the sum of the grouped ingredients is used to

determine the proportion in the final food. For details, see Part 1 - Mandatory

Com mon Names, Part 2 - Optional Common Names and Part 3 - Class Names in

Appendix 4F; and

c) The proportion of water can be considered before or after the product is cooked.

Furthermore, it may be considered as a processing aid if it completely evaporates

during process ing (see Appendix 4H).

In column (5) of Worksheet 4-2, indicate whether or not the ingredients appear to be

listed in descending order of proportion by weight on the label.

Example:

Assessing the list of ingredients declared on the label of the canned sliced pears in

light fruit juice syrup, the ingredients appear to be listed in descending order (i.e., you

would expect to see pears declared as the first ingredient, followed by the fruit juice

syrup ingredients and you would expect food additives to be declared at the end of

the list of ingredients). Therefore, you would indicate satisfactory (S) in column (5) of

the worksheet.

4.5.2.6 Assess if the Components are Declared, When Required

Components of ingredients must be declared in the list of ingredients of the final food

unless they are exempt, as explained in Appendix 4E.

Since you are not at the m anufacturer’s premises, it is impossible to determ ine if all

com ponents are listed for each ingredient, when required. However, s ince ingredients

and components must be shown in descending order of their proportion by weight (as

explained in 4.5.2.5) and must be declared by their proper comm on name (as explained

in 4.5.2.4), you can examine the list of ingredients for glaring errors. If you suspect

errors, you can ask the company to request more information from their supplier or have

the product tested if required.




In column (6) of Worksheet 4-2, indicate whether or not the components appear to be declared in the list

of ingredients of the final food (when required).

In the “comments” section of the worksheet, record any ingredients for which

components are required to be declared but are not shown in the list of ingredients (if any).

Example:

In the list of ingredients declared on the canned pears in light fruit juice syrup label,

grape juice from concentrate is the only ingredient for which no exemptions apply for

component listing. Therefore, unless you have reason to believe that the citr ic acid

contains components that are not exempt from being declared (as explained in

Appendix 4E), you would indicate satisfactory (S) in colum n (6) of the worksheet.

4.5.2.7 Verify the Declaration of Food Allergens, Gluten Sources and Added Sulphites

As seen in task 4.5.2.6, some components are exempt from being declared on the label of

prepackaged foods, and, as per task 4.5.2.4, ingredients and components must be

declared by their comm on names.

However, B.01.010.1 to B.01.010.3 of the FDR exclude food allergens, gluten sources and

added sulphites from component exemptions listed in B.01.009 (1) and (2) and require

additional labelling when the comm on names of ingredients or components are hidden

sources of food allergens, gluten sources and added sulphites.

Assess if food allergens, gluten sources and sulphites present5 in the food are clearly

indicated, by their prescribed source names, in the list of ingredients, or at the end of the

list of ingredients in a “Contains” statement. For details, see Appendix 4G.

In section (7) of Worksheet 4-2, place an “x” or a checkmark to indicate which food

allergens, gluten sources and added sulphites are declared in the list of ingredients and/or

in a “Contains” statement or are suspected to be present in the food but not declared,

based upon sections (1) and (6) and upon the “com ments” section of the worksheet. If

food allergens, gluten sources and added sulphites are:

• not declared and not suspected of being present5, mark your findings as not

applicable (N/A). Proceed to task 4.5.2.8.

5 Present means:

• Food allergens and gluten sources are detectable, by current methodology, or are known

to be intentionally added* to the food, regardless of amount present in the final food.

• The final food contains 10 ppm or more of sulphites as a result of being added*.

* Added as ingredients, components, components of components, etc, or as hidden sources of

ingredients, components, etc. (e.g., sodium caseinate is a hidden m ilk allergen).




• declared, refer to column (1)of W orksheet 4-2 to assess if food allergens, gluten

sources and/or added sulphites are declared by their prescribed source name in the

list of ingredients and/or in a “Contains” statement. If they are:

i) declared by their prescribed source name, mark your findings as satisfactory (S).

ii) not declared by their prescribed source name, mark your findings as unsatisfactory

(U).

• not declared but suspected of being present5 [e.g., the source of lecithin is not

declared so it m ay be a soy or egg allergen], request the regulated party to obtain

more information from the m anufacturer. If an imm ediate answer is not provided, mark

your findings as under evaluation.

Note: If more than one food allergen, gluten source and/or sulphites was assessed, mark your overall assessment in section (7) as:

• Satisfactory (S) if they were all assessed as (S); or

• Unsatisfactory (U) if one or more were assessed as (U). Add a circle around

the allergen, gluten source and/or sulphites that are unsatisfactory; and/or

• Under evaluation if one or more were assessed as potentially present without

certainty (ie, doubtful) and if none were rated as unsatisfactory (U) and if

information is missing.

4.5.2.8 Verify the Translation of the List of Ingredients

Assess whether or not the French list of ingredients on the label corresponds to the

English list. The order in which ingredients are listed must be the same in both languages.

However, since some ingredients may be listed in any order at the end of the list, as

explained in task 4.5.2.5 above, those ingredients should be declared in the same order in

both languages to avoid confusion.

If you are unsure of the proper legal translation of ingredients, you can use the regulations

as translation tools:

• Food products and their ingredients are listed in the same order in both the English

and French versions of the PPR and of the FDR;

Examples:

< “Apple juice” is listed in Schedule I, Table I, Section 3 of the PPR. In the

French version (same section), “jus de pommes” is listed.




< “Sugar” is listed in section B.18.001 of the FDR. In the French version of

B.18.001, “sucre” is listed.

Note: The Regulations may not be able to provide all the translations needed,

especially when a food falls under a standard of identity. For example,

strawberry jam falls under the standard “(nam ing the fruit) jam” in

Schedule II, Section 2.(1), PPR. So, if you checked Schedule II, Section

2.(1) in the French PPR, you would find “confiture de (nom du fruit)”

rather than “confitures aux fraises”.

• Food additives are listed alphabetically and an item num ber is assigned to each

additive within each English Lists of Permitted Food Additives. In the French Lists, the

food additives are listed in order of their item number (same item num bers as in the

English lists) rather than in alphabetical order.

Example: The first two additives listed in List 1 of the Permitted Food Additives

are “calcium aluminum silicate” (item number C.1) and “calcium

phosphate” (item number C.2). To determine the French translation for

these two additives, go to items C.1 and C.2 in the French List. The

translations are “silicate double d’aluminium et de calcium” (C.1), and

“phosphate tricalcique” (C.2):

Item No

English List French List

Additive Names Additive Names

C.1 calcium alum inum silicate silicate double d’aluminium et de calcium

C.2 Calcium phosphate tribasic phosphate tricalcique

In section (8) of Worksheet 4-2, indicate whether or not the French list of ingredients

corresponds with the English list. Record any discrepancies in the “comments” section

of the worksheet. If you are not bilingual and the applicable regulations do not allow you

to assess the translation, you should use a translation tool (e.g., Termium which is

available on CFIA’s internal website). If you still do not feel confident assessing the French

list of ingredients, you can indicate “not assessed”.

4.5.2.9 Final Assessment

If all columns and sections of Worksheet 4-2 are marked as satisfactory (S) and no

concerns are noted in the “comm ents” section of the worksheet, select the box for

“Complies with the PPR and the FDR” in the final assessment area at the bottom of the

worksheet. Proceed to task 4.7 - Complete and Distribute the Inspection Report.

If one or more of the columns or sections of Worksheet 4-2 contain an unsatisfactory (U)

rating and/or concerns are noted in the “comm ents” section of the worksheet, select the

box for “Does not comply with the PPR and the FDR” in the final assessment area at

the bottom of the worksheet. Proceed to task 4.6 - Unsatisfactory or Pending Inspection

Results.




If section (7) of Worksheet 4-2 is marked as under evaluation (i.e., the amount of added

sulphites present in the final food is unknown), select the box for “Pending” in the final

assessment area at the bottom of the worksheet. Proceed to task 4.6 - Unsatisfactory or

Pending Inspection Results.

4.6 Unsatisfactory or Pending Inspection Results

Take appropriate action based on the nature of the non-compliance. For guidance, refer to Chapter

11 of this manual or consult with your Supervisor.

If you discover a potential health and safety concern, such as unsatisfactory or pending inspection

results forfood allergens, g luten sources or sulphites, im mediately:

a) detain all suspect product;

b) determine if the product has been distributed;

c) contact your Supervisor. Depending on the issue, you, or your Supervisor, can consult the

Program Officer, Processed Products Program Specialist, Investigation Specialist and\or

Regional Recall Coordinator to determine the next steps (e.g., request a health risk

assessment, subm it samples for laboratory analysis6, etc); and

d) docum ent your findings in the Issues Managem ent System (IMS).

For pending results, update the “final assessment” section of the worksheet to reflect the decision

received (i.e., once a health risk assessment is finalized, de-select the box for “Pending” and select

the box for “Complies with the PPR and the FDR” or “Does not comply with the PPR and the FDR”,

as applicable). Summarize the assessment in the “comments” section of the worksheet.

Proceed to task 4.7.

4.7 Complete and Distribute the Inspection Report

Once back at the office, Enter all the verification findings in the Multi Commodity Activities Program

(MCAP). Print thereport from MCAP.

Prepare a cover letter to :

• State that the Report is enclosed; and

• Request the regulated party to submit a written corrective action plan, with in a specified time

frame, for all non-com pliance issues (if applicable).

6 For a sulphite analysis, follow the procedures outlined in Processed Products - Product

Sampling Plans. Use the sample numbers from the sulphites sampling plan F100 (for domestic products)

ou F101 (for imported products). If no sample numbers are assigned to you, contact your Processed

Products Program Specialist. Follow the corrective action outlined in the sampling plan.

For all other allergen analysis, contact your Processed Products Program Specialist.




Mail, fax or email the report and the cover letter to the regulated party as soon as possible. The

completed Label Verification W orksheet should not be provided to the regulated party as it is not an

official form.

Keep a copy of the report, the cover letter, the Label Verification W orksheet and the corresponding

label for your files. D istr ibute copies internally as per your region’s protocol.

Appendix 4ACHAPTER 4 INGREDIENT VERIFICATION



Worksheet 4-1: ingredient verification for processed products at the manufacturing level

EXAMPLE Inspector: John Doe Date: 39948

Establishment’s Name & Address: Tasty Fruit Company, 123 Main Street, Ottawa, ON, A1A 1A1 Establishm ent Registration Number: 123

Com mon Name of the Product: Strawberry Jam Net Quantity: 250 mL

Brand Name: Tasty Fruit Quantity of Labels: 6000

Name and Address on the Label: 123 Main Street, Ottawa, ON A1A 1A1 Lot Code: 123SJ345

Product is Subject to the PPR, in Schedule: II Table (if applicable): VIII Section: 2(1) S = Satisfactory U = Unsatisfactory N/A = Not Applicable

CHAPTER 4 INGREDIENT VERIFICATION Appendix 4A



(1) Ingredients Identified in the Formula (2) Ingredients Used and their Components (3) List of Ingredients on the Label

Descending Order as per the

Master Formula

(A)

Ingredients Used

and their Components

(B)

Ingredient

& Amount Added are Permitted

(C)

Component Permitted

(D)

Component Exempt

(A)

Ingredients and Components

Declared on the Label

(B)

9 Order

(C)

Common Name

S U S U Yes No S U S U

strawberries strawberries X strawberries X X

sugar sugar X sugar X X

water water X lemon juice X X

pectin pectin preparation [ABC brand] X pectin X X

(sugar) X X fumaric acid X X

(pectin) X X sodium benzoate X X

(fumaric acid) X X

lemon juice or citric acid lemon juice from concentrate [XYZ brand] X May contain peanuts X X




Master Formula

(A)

Ingredients Used


(B)

Ingredient

& AmountAdded arePermitted

(C)

ComponentPermitted

(D)

ComponentExempt

(A)



(B)

Order

(C)

CommonName




(water) X X

(concentrated lemon juice) X X

(lemon oil) X X

(sulphites) X X

sodium benzoate sodium benzoate X

(4) Food Allergens, Gluten Sources and Added Sulphites Present in the Product N/A Under Evaluation S U

Nuts Sesame seeds Eggs Soybeans Shellfish Gluten Sources: Barley, Oats, Rye, Triticale, Wheat X X


___________________________________________________________________________________________




Inspector: Date:

Establishment’s Name & Address: Establishm ent Registration Number:

Com mon Name of the Product: Net Quantity:

Brand Name: Quantity of Labels:

Name and Address on the Label: Lot Code:

Product is Subject to the PPR, in Schedule: Table (if applicable): Section: S = Satisfactory U = Unsatisfactory N/A = Not Applicable



Master Formula

(A)

Ingredients Used


(B)

Ingredient


(C)

ComponentPermitted

(D)

ComponentExempt

(A)



(B)

9 Order

(C)

CommonName


Worksheet 4-1: ingredient verification for processed products at the manufacturing LEVEL

Amended May 24, 2013






Master Formula

(A)

Ingredients Used


(B)

Ingredient


(C)

ComponentPermitted

(D)

ComponentExempt

(A)



(B)

9 Order

(C)

CommonName





Master Formula

(A)

Ingredients Used


(B)

Ingredient


(C)

ComponentPermitted

(D)

ComponentExempt

(A)



(B)

Order

(C)

CommonName




(4) Food Allergens, Gluten Sources and Added Sulphites Present in the Product N/A Under Evaluation S U

Nuts Sesame seeds Eggs Soybeans Shellfish Gluten Sources: Barley, Oats, Rye, Triticale, Wheat

Peanuts W heat / T riticale Milk Crustaceans Fish Mustard Seeds Sulphites

(5) Translation Assessment Not Assessed S U

The French list of ingredients declared on the label corresponds to the English list

COM MENTS:




Master Formula

(A)

Ingredients Used


(B)

Ingredient


(C)

ComponentPermitted

(D)

ComponentExempt

(A)



(B)

9 Order

(C)

CommonName




Complies with the PPR and FDR Does not comply with the PPR and FDR PendingFINALASSESSMENT:




Master Formula

(A)

Ingredients Used


(B)

Ingredient


(C)

ComponentPermitted

(D)

ComponentExempt

(A)



(B)

9 Order

(C)

CommonName




Note: The term “ingredients” includes food additives, vitamins and mineral nutrients.

Worksheet 4-2: ingredient verification for processed products at other than the manufacturing level

CHAPTER 4 INGREDIENT VERIFICATION Appendix 4B



EXAMPLE Inspector: John Doe Date: 39948

Regulated Party’s

Name and Address: Processed Fruits Inc, 456 Main Street, Ottawa, ON, A1A 1A1

Type of Operation:

(ex: Importer, Distributor) Importer

Common Name of

the Product: Canned sliced pears in light fruit juice syrup Net Quantity: 398 mL

Brand Name: Lot Code: 82010

Name and Address

on the Label:

Imported by Processed Fruits Inc ., 456 Main Street,

Ottawa, ON, A1A 1A1

Quantity of Labels

or Lot Size: 1000

Product is Subject to

the PPR, in Schedule: I

Table:

(if applicable) I Section: 37 N/A = Not Applicable S = Satisfactory U = Unsatisfactory

(1)

Ingredients and Components Declared on the Label

(2)

Declared Ingredient

Permitted

(3)

Declared Component

Permitted

(4)

Common Name

(Ingredient/Component)

S U S U S U

pears X X

water X X

sugar X X

grape juice from concentrate X X

(water) X X

(concentrated grape juice) X X

(vitamin C) X X

citr ic acid X X




(5) List of Ingredients in Descending Order S U

Ingredients appear to be declared in descending order of proportion by weight X

(6) Components Declared When Required S U

Components of ingredients appear to be declared when not exempt by Regulations X

(7) Food Allergens, Gluten and Added Sulphites that are:

(a) Declared on the Label or (b) Not Declared but Suspected of Being Present in the Product N/A

Under Evaluation

S U

Nuts Sesame Seeds Eggs Soybeans Shellfish Gluten Sources

Peanuts W heat/T riticale Milk Crustaceans Fish Mustard Sulphites X


French list of ingredients declared on the label corresponds to the English list X

COMMENTS

FINAL ASSESSMENT: X Complies with the PPR and FDR Does not comply with the PPR and FDR Pending





Inspector: Date:

Regulated Party’s

Name and Address:

Type of Operation:

(ex: Importer, Distributor)

Common Name of

the Product: Net Quantity:

Brand Name: Lot Code:

Name and Address

on the Label:

Quantity of Labels

or Lot Size:

Product is Subject to

the PPR, in Schedule:

Table:

(if applicable) Section: N/A = Not Applicable S = Satisfactory U = Unsatisfactory

(1)

Ingredients and Components Declared on the Label

(2)

Declared Ingredient

Permitted

(3)

Declared Component

Permitted

(4)

Common Name

(Ingredient/Component)

S U S U S U

Worksheet 4-2: ingredient verification for processed products at other than the manufacturing level

Amended May 31, 2013




Complies with the PPR and FDR Does not comply with the PPR and FDR Pending

(5) List of Ingredients in Descending Order S U

Ingredients appear to be declared in descending order of proportion by weight

(6) Components Declared When Required S U

Components of ingredients appear to be declared when not exempt by Regulations

(7) Food Allergens, Gluten and Added Sulphites that are:

(a) Declared on the Label or (b) Not Declared but Suspected of Being Present in the ProductN/A

UnderEvaluation

S U

Nuts Sesame Seeds Eggs Soybeans Shellfish Gluten Sources

Peanuts W heat/T riticale Milk Crustaceans Fish Mustard Sulphites


French list of ingredients declared on the label corresponds to the English list

COM MENTS:

FINAL ASSESSMENT:


Appendix 4CCHAPTER 4 INGREDIENT VERIFICATION



Declaring ingredients subject to omissions, substitutions and variations

B.01.011 of the FDR allows flexibility when declaring ingredients that are subject to omissions, substitutions

and variations. Words such as “and/or”, “may contain”, “*proportions in brackets may vary” need to be used

accordingly.

W here it is an acceptable manufacturing practice7 for a manufacturer to omit from his prepackaged product

any food that is ordinarily an ingredient or component, or substitute in whole or in part in his prepackaged

product any other food for a food that is ordinarily an ingredient or component, the list of ingredients for the

12 month period comm encing from the time the label is applied to the prepackaged product may show as

ingredients or components the foods that may be omitted and the foods that may be used as substitutes if:

• all the foods that may be used as ingredients or com ponents throughout the 12 month period are

shown in the list of ingredients;

• it is clearly stated as part of the list of ingredients that the food shown as an ingredient or

component may not be present or that another food may be substituted for a food shown as an

ingredient or component; and

• the foods that may be omitted or substituted are grouped with the same class of foods that are used

as ingredients or components and the foods within each such group are listed in descending order

of the proportion in which they will probably be needed during the 12 month period.

W here it is an acceptable manufacturing practice for a manufacturer to vary the proportions of ingredients

or components of his prepackaged product, the list of ingredients for the 12 month period comm encing from

the time the label is applied to the prepackaged product may show the ingredients or components in the

same proportions throughout the 12 month period if:

• it is clearly stated as part of the list of ingredients that the proportions indicated are subject to

change; and

• the ingredients or com ponents are listed in descending order of the proportion in which they will

probably be used during the 12 month period.

Examples:

• Om issions

Peaches in a light syrup that consists of water, sugar and som etim es glucose. An acceptable

list of ingredients is:

7 An acceptable manufacturing practice is a change in formulation that will not affect the product’s

compliance to a compositional standard in the PPR and/or FDR. The change must be appropriately

reflected in the list of ingredients (e.g., use of words such as “and/or”, “may contain”, “proportion may

vary”).

CHAPTER 4 INGREDIENT VERIFICATION Appendix 4C



Ingredients: Peaches, water, sugar, may contain glucose.

• Substitutions:

Peaches in fruit juices where orange juice is always present in the greatest proportion and

either apple juice or pear juice is used. Apple juice is used more frequently than pear juice. An

acceptable list of ingredients is:

Ingredients: Peaches, orange juice; apple juice or pear juice.

• Om issions and/or substitutions:

Peaches in a light syrup that consists of water, sugar and may contain glucose and/or glucose-

fructose (i.e., either glucose is added, or glucose-fructose is added, or both are added, or none

are added, at least once during the year). An acceptable list of ingredients is:

Ingredients: Peaches, water, sugar, may contain glucose and/or glucose-fructose.

• Variations

A m ixture of pickled vegetables containing carrots, cauliflower, cucumbers, olives, hot peppers

and onions is packed in 750 mL jars. The first two ingredients are batched in roughly the same

proportions, usually with more carrots added than cauliflower but with the poss ibility that more

cauliflower is added in the jars, from time to time, due to manufacturing inconsistencies. An

acceptable list of ingredients is:

Ingredients: Carrots*, cauliflower*, cucumber, hot peppers, water, vinegar, olives, onions,

salt, sp ices, calcium chloride. * order may vary.

Appendix 4DCHAPTER 4 INGREDIENT VERIFICATION



Food additives, vitamins and m ineral nutrients

1) Food Additives

A food additive is defined as “any substance the use of which results, or may reasonably be expected to

result, in it or its by-products becoming a part of or affecting the characteristics of a food.” [B.01.001,

FDR and Section 2, PPR].

The following are NOT considered to be food additives:

• food ingredients such as salt, spices, seasonings, flavour preparations, vinegar;

• vitamins, mineral nutrients and amino acids (other than those listed in Health Canada’s Lists of

Perm itted Food Additives);

• agricultural chemical and veterinary drugs (these are adulterants!);

• food packaging m aterials and components thereof.

Food additives can be declared in proper descending order within the list of ingredients or in any

order at the end of the list. In the list of ingredients, it is acceptable to voluntarily include an additive’s

function, in brackets, e.g., “sodium benzoate (a preservative)”.

a) Food Additives Permitted in Foods

Food additives can only be added to foods in which they are permitted, for the specified purpose,

and up to the maximum level of use, as prescribed in Health Canada’s Lists of Permitted Food

Additives. These lists are the official repository of food additives permitted for use in, or on, foods

marketed in Canada. The lists are incorporated by reference in the Food and Drugs Act.

There are 15 Lists of Perm itted Food Additives. The lists are divided based on the food additive

function as follows:

List No. Food Additive Function(s)

1 List of Permitted Anticaking Agents

2 List of Permitted Bleaching, Maturing and Dough Conditioning Agents

3 List of Permitted Colouring Agents

4 List of Permitted Em ulsifying, Gelling, Stabilizing, and Thickening Agents

5 List of Permitted Food Enzymes

6 List of Permitted Firm ing Agents

7 List of Permitted Glazing and Polishing Agents

8 List of Permitted Food Additives with Other Generally Accepted Uses

9 List of Permitted Sweeteners

10 List of Permitted pH Adjusting Agents, Acid-Reacting Materials, W ater Correcting

Agents

11 List of Permitted Preservatives

12 List of Permitted Sequestering Agents

13 List of Permitted Starch Modifying Agents

14 List of Permitted Yeast Foods

CHAPTER 4 INGREDIENT VERIFICATION Appendix 4D



15 List of Permitted Carrier or Extraction Solvents

Some food additives have multiple functions and therefore will appear in more than one of the

above mentioned lists. For a quick reference of the functions for which each additive has been

approved for use in Canada, you can refer to Health Canada’s Food Additive Dictionary. Even

though it is not a legal document and may not contain recent additions to the Lists of Permitted

Food Additives, you may find it useful.

Food additives that are permitted to be added directly to Processed Products are found in the

following lists:

List 3 - Perm itted Colouring Agents

Factors such as processing, storage and seasonal variation can make the colour of foods

unfam iliar or unattractive. Colouring agents are used to give food an appetizing appearance.

Examples: beet red in jam with pectin, caramel in relish, tartrazine in relish

In the list of ingredients, colours can be declared by their actual common names or collectively

as “colour” [B.01.010(3)(b), FDR].

List 4 - Perm itted Em ulsifying, Gelling, Stabilizing, and Thickening Agents

These additives are sometim es called Texture Modifying Agents. They contribute to or m aintain

a desirable consistency and keep food com ponents together.

Emulsifiers permit small droplets of one liquid to remain dispersed in another liquid, when

the two would norm ally separate (like oil and water).

Example: polysorbate 80 in relishes and pickles

Gelling agents trap water so that the product becom es more solid (think of gelatin

desserts).

Example: pectin in jam

Stabilizers are similar in function to emulsifiers, but stabilizers keep two dissimilar

substances together in a different way. Stabilizers thicken the liquid portion of a food to

keep small particles or globules from floating or sinking.

Example: guar gum in canned asparagus with a butter- or oil-based sauce

Thickeners increase the viscosity of products by trapping some of the water (less than

gelling agents).




Example: locust bean gum in relishes

The terms stabilizer and thickener are often used interchangeably because their mechanisms

of action are similar. Many additives act as both a thickener and a stabilizer.

List 5 - Permitted Food Enzymes

Enzymes are complex proteins that catalyse chemical reactions without becoming part of the

reaction. The enzymes are either isolated from their original sources, such as bromelaine from

pineapples, or are produced by micro-organisms (often moulds). The most common use for

enzymes in processed products is for clarifying juices by breaking down some of the larger

carbohydrate molecules.

Examples: amylase, cellulase and pectinase in fruit juices

List 6 - Perm itted Firm ing Agents

As the name suggests, firming agents are chemicals that maintain the texture of products that

would normally soften and becom e unappealing during processing. This class of additives is

used almost exclusively in processed products to keep fruits and vegetables firm during heat

treatm ent.

Example: calcium chloride in canned vegetables, pickles and olives

List 8 - Permitted Food Additives with Other Generally Accepted Uses

Food additives that function differently from those in the other lists are grouped here.

Examples:

• Antifoaming agents keep products from becoming too frothy during processing and

packaging and make handling easier (e.g., dimethylpolysiloxane in jams, jellies and

marm alades)

• Colour retention agents are used to prevent the loss of co lour during process ing (e.g.,

ferrous gluconate in ripe olives)

List 9 - Permitted Sweeteners

Despite the nam e, this group does not include the com mon caloric sweeteners such as sugar,

glucose and honey. The term sweeteners pertains strictly to artificial, or non-caloric sweeteners

like aspartame, sucralose and sugar alcohols. These sweeteners are currently not permitted in

processed products, unless the product has been granted a Test Market Authorization (TMA).

For more information on TMAs, refer to Chapter 13 - Test Market Authorizations.




List 10 - Permitted pH Adjusting Agents, Acid-Reacting Materials and W ater Correcting

Agents

These additives are grouped together because they often act synergistically (i.e., the total

effect is more than the sum of the parts). pH adjusting agents are used in processed products

to regulate the acidity of the product in order to control microorganisms, or to influence

characteristics such as flavour, texture and colour. pH adjusting agents are often used in fruit

products to compensate for a lack of natural acidity.

Example: citric ac id in jam s, jellies, m arm alades and some canned fruits

List 11 - Permitted Preservatives

Preservatives are split into four classes based on function and application. Preservatives from

classes 1 and 2 are used in processed products.

Class 1 Preservatives:are used in certain fruit and vegetable products to inhibit spoilage

bacteria.

Example: ascorbic acid in canned peaches

Class 2 Preservatives:are anti-microbial chemicals, applied mainly to fruit and vegetable

products. They inhibit the growth of bacteria, yeasts and moulds.

Examples: benzoic and sorbic acids in jams, jellies, marmalades and pickles

List 12 - Permitted Sequestering Agents

Also known as chelators, sequestering agents combine with free metal ions in food products to

form non-reactive complexes. This helps prevent colour, flavour or texture changes and

oxidation reactions.

Example: ethylenediaminetetraacetic acid (EDTA) and its salts, in certain canned

beans, to prevent darkening due to tin.

b) Food Additives Permitted in Processed Products

If a class of food additives is referenced in the PPR without naming the specific additive(s)

permitted, you must determine whether the food is subject to a standard under Division 11 of the

FDR and then refer to Lists of Permitted Food Additives to determine which additives are permitted.

W hen a food is subject to a standard in Division 11 of the FDR, the sym bol [S] will appear between

the provision number and the name of the food. These standardized processed products must

contain only the food additives permitted in the standardized food by the FDR and PPR.

Example: Canned W hite Potatoes (sliced) are subject to grade markings in Schedule I, Table




I, Section 42, PPR. According to Schedule I, Table I, Section I, PPR, a firming

agent is permitted in graded canned vegetables but the PPR does not specify

which one is permitted. Therefore, you must refer to:

• Division 11, FDR:

Canned white potatoes are standardized under “B.11.002. [S]. Canned

Vegetables”. According to B.11.002, a firming agent is permitted in canned

vegetables but it does not specify which firming agent is permitted.

• The Lists of Permitted Food Additives:

According to List 4 - Permitted Firming Agents, four firming agents are

permitted in standardized “canned vegetables”. They are calcium chloride,

calcium citrate, calcium phosphate monobasic and calcium sulphate.

W hen a processed product is not subject to a standard in the FDR, it is an unstandardized food.

In this case, the food may contain any additives permitted in unstandardized foods in the FDR, as

long as the additives are also permitted by the PPR.

Example: “Canned Scalloped Potatoes” are subject to a standard of identity in Schedule II,

Section 24, PPR (i.e., “Canned Vegetables with Sauce, Butter, Butter Sauce,

Cheese Sauce or Tomato Sauce”). This standard of identity in the PPR permits a

firming agent, but does not specify which one is permitted. Therefore, you must

refer to:

• Division 11, FDR:

Canned scalloped potatoes do not meet any standards in Division 11

because the com mon nam e and composition of this product are very

different from any of the products listed. Therefore, canned scalloped

potatoes is an unstandardized food.

• The Lists of Permitted Food Additives:

According to List 4 - Permitted Firming Agents, nine firming agents are

permitted in “unstandardized foods”. They are aluminum sulphate,

amm onium aluminum sulphate, calcium chloride, calcium citrate, calcium

gluconate, calcium phosphate dibasic, calcium phosphate monobasic,

potassium aluminum sulphate and sodium aluminum sulphate.

Since ingredients are foods on their own, a food additive not permitted in a processed product may

be permitted in one of the ingredients of the product. In such a case, the additive would be

perm itted in the processed product as a component of the ingredient.




Example: Butylated hydroxyanisole (BHA), a C lass 4 preservative, cannot be added to

Frozen French Fried Potatoes. However, BHA is permitted in vegetable oil [List 11

- Permitted Preservatives] and vegetable oil is permitted in French fr ies [Schedule

I, Table II, Section 31, PPR]. Therefore BHA is indirectly permitted in Frozen

French Fried Potatoes as a com ponent of the vegetable oil.

c) Maximum Level of Use of Food Additives in Processed Products

W hen a food additive is permitted in a product, as explained in (b) above, the m aximum level of use

is prescribed by the PPR and/or the Lists of Permitted Food Additives. These maximum limits apply

to the product as sold, unless otherwise stated. The specific reference in the PPR and/or the Lists

of Permitted Food Additives needs to be reviewed to determine whether the maximum level of use

is based on the weight of the product (before or after processing), the weight of one or more

specific ingredients, etc.

Example:

As per List 6 - Permitted Firming Agents, the maximum level of use for calcium chloride in:

• pickles is 0.4% (i.e., applies to the finished product, as sold)

• olives is 1.5% of the brine (i.e., applies to the brine portion, as prepared, before filling)

The maximum level of use is expressed in one of the following ways:

• In parts per million (ppm):

One ppm means there is 1 part of food additive for every 1 million parts of finished product,

based on weight.

1 ppm = 1 mg / kg

= 1 µg / g

Example: A m aximum of 150 ppm of Ponceau SX (a food colour) is a llowed in

Maraschino Cherr ies [List 3 - Permitted Colouring Agents, item 6].

If the ppm is based on a reference chemical rather than the actual food additive used, refer to

“Converting Food Additives in Terms of Reference Chemicals” in (d) below.

Example: The maximum level of sulphurous acid permitted in frozen sliced apples is

500 ppm calculated as sulphur dioxide [ List 11 - Permitted Preservatives,

Class 2, item S.10].

OR

• On a percentage (% ) basis:

Example: A maximum of 0.4% of calcium chloride is allowed in pickles and relishes [




List 6 - Perm itted Firm ing Agents, item C.1].

The percentage is calculated on a weight basis unless otherwise stated.

If the percentage is based on a reference chemical rather than the actual food additive used,

refer to “Converting Food Additives in Terms of Reference Chemicals” in (d) below.

Example: The maximum level of calcium chloride perm itted in canned apples is

0.026% calculated as calcium [List 6 - Perm itted Firm ing Agents, item C.1].

OR

• In terms of “Good Manufacturing Practices”:

A “good manufacturing practice” level is the amount of food additive required in the food during

manufacturing and process ing to accomplish the intended purpose [B.01.044, FDR].

Example: A “good manufacturing practice” level of pectin in:

(1) “strawberry jam” is the level of pectin needed to compensate for the

amount of natural pectin lost during processing.

(2) “strawberry jam with pectin” is the amount needed to obtain the desired

consistency. Since this product contains less fruit than “strawberry jam”,

the am ount of pectin needed is greater than the am ount needed in

“strawberry jam” [List 4 - Permitted Emulsifying, Gelling, Stabilizing, and

Thickening Agents, item P.1].

(d) Converting Food Additives in Terms of Reference Chemicals

As mentioned above, some of the Lists of Permitted Food Additives prescribe the maximum level of

use for certain additives in terms of reference chemicals rather than the actual food additive used.

In these cases, you must use molecular weights to convert the levels permitted for the reference

chemical to the level permitted for the actual additive being used. Table 4D-1 provides the

molecular weights of the food additives permitted in processed products which require a

convers ion. In some cases, a chem ical may exist in several forms (anhydrous, m onohydrate, etc.)

and you need to determine which form is being added to the food.

W hen the maximum level permitted is expressed in parts per million, the mathematical formula is:

ppm reference chem ical = C

A x ppm added chemical

where: “C” is the molecular weight of the reference chem ical;

“A” is the molecular weight of the added chemical; and

“ppm added chemical” is the level calculated from the product formulation.




Example:

According to List 11 - Permitted Preservatives, Class 2, item S.10, the maximum level of

sodium metabisulphite permitted in frozen apples is 500 ppm, calculated as sulphur dioxide.

The manufacturer’s recipe indicates that 300 g sodium m etabisulphite is added to frozen sliced

apples and the final yield of frozen sliced apples is 250 kg.

In order to determine if the amount of sodium metabisulphite added is acceptable:

First, convert the 300 g (300,000 mg) of sodium m etabisulphite to parts per million of

sodium metabisulphite added to the final food:

1 ppm = 1 mg

kg

P ppm = 300,000 mg sodium metabisulphite

250 kg frozen apples

P = 1200 ppm of sodium m etabisulphite is added to the frozen apples

Then, convert of sodium metabisulphite to sulphur dioxide:

ppm reference chem ical = C

A x ppm added chemical

Based on Table 1D-1 below and on the above calculation:

C, the molecular weight of sulphur dioxide, is 64.1 g/mol;

A, the molecular weight of sodium m etabisulphite, is 190.1 g/mol; and

1200 ppm sodium metabisulphite is added.

P ppm sulphur dioxide =

64.1 g/mol

190.1 g/mol x 1200 ppm sodium metabisulphite

P = 405 ppm sulphur dioxide

The calculated concentration of sulphur dioxide, 405 ppm, is less than 500 ppm , therefore

the am ount of sodium metabisulphite added to the rec ipe is satis factory.

W hen the maximum level permitted is expressed on a percentage basis, the mathematical

formula is:




% reference chem ical = C

A x % added chemical

where: “C” is the molecular weight of the reference chem ical;

“A” is the molecular weight of the added chemical; and

“% added chemical” is the level calculated from the product formulation.

Example:

According to List 6 - Permitted Firming Agents, item C.1, the limit for calcium chloride

(monohydrate) in canned apples is 0.026%, calculated as calcium. The recipe used by an

establishment indicates that 200 g calcium chloride (monohydrate) is added to canned apples

and the final yield of canned apples is 300 kg.

In order to determine if the amount of calcium chloride (monohydrate) added is acceptable:

First, calculate the percentage of calcium chloride (monohydrate) present in the final food:

0.20 kg calcium chloride

300.0 kg canned apples x 100 = 0.066% calcium chloride added

Then, convert the percentage of “calcium chloride (monohydrate)” to percentage of

“calcium”:

% reference chem ical = C

A x % added chemical

Based on Table 1D-1 below and on the above calculation:

C, the molecular weight of calcium, is 40.1 g/m ol;

A, the molecular weight of calcium chloride (monohydrate), is 129.0 g/mol; and

the % calcium chloride added is 0.066%.

% calcium = 40.1

129 x 0.066%

= 0.021% calcium

The calculated amount of calcium, 0.021%, is less than the maximum limit of 0.026%.

Therefore, this am ount of calcium chloride added satis factory.

Table 4D-1: Summary of Molecular W eights for Food Additives W hich Require Conversion to a

Reference Chemical, as per the Lists of Permitted Food Additives:




A ² for conversion

calculation ÷C

Additive MW

(g/mol) Calculated as

MW

(g/mol)

Prescribed Limit

[Applicable List of

Permitted Food

Additives]

calcium chloride:

• anhydrous

• monohydrate

• dihydrate

• tetrahydrate

• hexahydrate

111.0

129.0

147.0

183.1

219.1

calcium 40.1 Various percentages

[List 6, item C.1]

calcium citrate:

• anhydrous

• tetrahydrate

498.4

570.5

calcium 40.1 0.026 %

[List 6, item C.2]

calcium disodium

ethylenediaminetetraacetate

(tetrahydrate)

446.3 anhydrous

calcium disodium

EDTA*

374.3 130 or 365 ppm

[List 12, item C.2]

calcium disodium EDTA

(tetrahydrate)

446.3 anhydrous

calcium disodium

EDTA*

374.3 130 or 365 ppm

[ List 12, item C.3]

calcium lactate:

• anhydrous

• pentahydrate

218.2

308.3

calcium 40.1 0.035 %

[ List 6, item C.3A]

calcium phosphate

monobasic:

• anhydrous

• monohydrate

234.1

252.1

calcium 40.1 0.026 %

[List 6, item C.5]

calcium sulphate:

• anhydrous

• dihydrate

136.1

172.2

calcium 40.1 0.026 %

[List 6, item C.6]

potassium benzoate

(trihydrate)

214.3 benzoic acid 122.1 1000 ppm

[List 11, Class 2, item P.1]

potassium bisulphite 121.2 sulphur dioxide 64.1 90 or 500 ppm

[List 11, Class 2, item P.2]

potassium metabisulphite 222.3 sulphur dioxide 64.1 90 or 500 ppm

[ List 11, Class 2, item P.3]


A² for conversion

calculation ÷C

AdditiveMW

(g/mol)Calculated as

MW

(g/mol)

Prescribed Limit

[Applicable List of

Permitted Food

Additives]



sodium benzoate 144.1 benzoic acid 122.1 1000 ppm

[ List 11, Class 2, item S.1]

sodium bisulphite 140.1 sulphur dioxide 64.1 90 or 500 ppm


sodium dithionite 174.1 sulphur dioxide 64.1 90 or 500 ppm


sodium metabisulphite 190.1 sulphur dioxide 64.1 90 or 500 ppm


sodium salt of methyl-p-

hydroxy benzoic acid

174.1 methyl-p-hydroxy

benzoate

152.1 1000 ppm


sodium salt of propyl-p-

hydroxy benzoic acid

202.2 propyl-p-hydroxy

benzoate

180.2 1000 ppm


sodium sulph ite 126.1 sulphur dioxide 64.1 90 or 500 ppm


stannous chloride:

• anhydrous

• dihydrate

189.6

207.6

tin 118.7 25 ppm

[ List 8, item S.13]

sulphurous acid 82.1 sulphur dioxide 64.1 90 or 500 ppm


* EDTA = ethylenediaminetetraacetate

2) Vitamins and Mineral Nutrients

All vitamins and m ineral nutrients can be declared in their proper descending order in the list of

ingredients or in any order at the end of the list.

a) Addition of Vitamin C

The FDR and PPR permit the addition of vitamin C to certain foods subject to the PPR. When

vitamin C is added, a minimum level must be added, as prescribed by the PPR and/or the FDR,




and as summ arized in Table 4D-2 below.

The acceptable sources of vitamin C are ascorbic acid, sodium ascorbate, calcium ascorbate

and ascorbyl-6-palmitate.

• Ascorbic Acid:

The biologically active form of ascorbic acid is L-ascorbic acid . W hen added as a vitam in (if

permitted), it can be declared in the list of ingredients as “ascorbic acid”, "vitamin C" or

“ascorbic ac id (vitam in C)”.

The non-biologically active form of ascorbic acid is D-ascorbic acid . It can only be added to

foods as a preservative (when permitted), and must be declared as “ascorbic acid”. Because

D-ascorbic acid does not have any biological activity, it is usually cheaper and a company may

be tempted to use it in place of true vitamin C (L-ascorbic acid). Check ingredient labels and

specification sheets carefully if you suspect that this is happening.

• Sodium Ascorbate, Calcium Ascorbate and Ascorbyl-6-Palmitate:

W hen added as a source of vitamin C, “sodium ascorbate”, “calcium ascorbate” and “ascorbyl-

6-palmitate” must be declared as such in the list of ingredients. Vitam in C may be declared, in

brackets, following the chemical name.

Table 4D-2: Minimum Levels of Biologically Active Vitamin C as Prescribed by the PPR and/or the

FDR

Product Minimum Level

per 100 mL PPR and/or FDR References

Juices:

Apple Juice 35 mg* Schedule I, Table I, Subsection 3.(2)(g), PPR

Concentrated Apple Juice 35 mg* Schedule I, Table I, Subsection 4.(2), PPR

Apple Juice from

Concentrate

35 mg* Schedule I, Table I, Subsection 5.(3), PPR

Grape Juice 18 mg* Schedule II, Subsection 14.(1)(l), PPR

Concentrated Grape Juice

or Grape Juice Concentrate

18 mg* Schedule II, Subsection 15(k), PPR

Grape Juice from

Concentrate

18 mg* Schedule II, Subsection 16(j), PPR

Mixed Vegetable Juices 17.5 mg - Part IV, Subsection 31(v), PPR

- D.01.009 and Schedule K, FDR

Nectars:

Apricot Nectar 17.5 mg - Schedule II, Section 40, PPR





Peach Nectar 17.5 mg - Schedule II, Section 40.1, PPR


Pear Nectar 17.5 mg - Schedule II, Section 40.1, PPR


Prune Nectar 17.5 mg - Schedule II, Section 41, PPR


* within 12 months of packing, as determined by the indophenol method.

The maxim um level of vitamin C that may be added to the foods listed in Table 4D-2 is 52.6 mg of

ascorbic acid per 100 mL of product [D.01.011 and Schedule K, FDR]. There are no maximum

levels prescribed by the PPR.

The concentration of vitam in C in a product diminishes during process ing and over time as it reacts

with oxygen, light and other fac tors. Because of this, manufacturers often add extra ascorbic acid

(called overage) to their products. This practice ensures that the vitamin C content declared on the

label is present in the food until the end of the shelf life. Up to 150% overage (i.e., up to 78.9

mg/100 mL) of vitamin C is acceptable in juices and nectars, depending on the processing method,

packaging material and shelf life of the product. If more than 150% of vitamin C is added, the

company must be able to provide scientific proof that these higher levels are required to meet the

label claim .

b) Addition of Vitamins (Other than Vitamin C) and Mineral Nutrients

No vitamin (other than vitamin C) and no mineral nutrient may be added directly to products subject

to the PPR.

However, since ingredients are foods on their own, vitamins and mineral nutrients not permitted in a

processed product may be permitted in one of the ingredients of the processed product, as per the

Table in D.03.002 of the FDR. In th is case, the vitam in or m ineral nutrient is incidently permitted in

the processed product as a component of the ingredient.

Example: Vitamin D cannot be added to Canned Scalloped Potatoes. However, vitamin D is

added to whole milk [Table in D.03.002, item 10, FDR] and a milk based sauce is

perm itted in scalloped potatoes [Schedule II, Section 24, PPR]. Therefore, Vitam in

D is indirectly permitted in the scalloped potatoes as an ingredient in the milk.

c) Vitamins and Mineral Nutrients Added as Food Additives

W hen vitamins or mineral nutrients are added to a product for a food additive function, they are

subject to the Lists of Permitted Food Additives (see Part 1of this Appendix). A vitamin or mineral

nutrient claim (or mention) cannot be made based on this addition.

Example: In frozen fruit, ascorbic acid is permitted as a preservative [List 11, Class 1, item

A.2]. “Ascorbic acid” must be declared as such in the list of ingredients. No

mention of vitamin C is permitted in the list of ingredients.

Note: Health Canada is currently reviewing the vitamin and mineral fortification requirements

under the FDR.




Appendix 4E

Exemptions from Component Listings [B.01.009, Fdr]

Ingredients listed in B.01.009(1) and (2) of the FDR are foods on their own and carry a complete list of

ingredients when sold as prepackaged foods on the retail market. When added as ingredients in other

foods, they must be declared as ingredients, but with a few exceptions, their ingredients are exempt from

being declared as components in the final food.

1) Ingredients Exempt from Component Listings

B.01.009(1) of the FDR exempts certain ingredients or classes of ingredients from the requirement of

having their com ponents declared on the label of the food to which they are added, except for:

• all forms of peanut oil (see Part 4 below); and

• com ponents, com ponents of components, and so on (i.e., 2nd generation ingredients, 3 rd generation

ingredients and beyond) that are:

• food allergens or gluten sources (present at any level in the final food); or

• added sulphites (if present at 10 ppm or more in the final food).

For details, see Appendix 4G.

Ingredients that are exempt from com ponent listings [in B.01.009(1) of the FDR] appear in Table 4E-1

with some editorial changes. Always refer to the actual Regulations for the latest version.

CHAPTER 4 INGREDIENT VERIFICATION Appendix 4E



Table 4E-1: Ingredients Exempt from Com ponent Declaration

Ingredients Exempt from Component Listings

1. butter

2. margarine

3. shortening

4. lard

5. leaf lard

6. monoglycerides

7. diglycerides

8. rice

9. starches and modified starches

10. standardized breads (B.13.021 to B.13.029)

11. flour

12. soy flour

13. graham flour

14. whole wheat flour

15. baking powder

16. standardized milks (B.08.003 to B.08.027)

17. chewing gum base

18. standardized sweetening agents (B.18.001 to B.18.018)

19. cocoa, low-fat cocoa

20. salt

21. standardized vinegars (B.19.003 to B.19.007)

22. standardized alcoholic beverages (B.02.001 to B.02.136)

23. standardized cheese (Division 8), if the total amount <10% of the end product

24. standardized jams, marmalades and jellies (B.11.201 to B.11.241) if the total amount < 5% of the end product

25. olives, pickles, relish and horseradish if the total amount <10% of the end product

26. standardized vegetable or animal fats or oils (Division 9), and hydrogenated, modified or interesterified vegetable or animal fats or oils, if the total amount <15% of the end product

27. Prepared or preserved meat, fish, poultry meat, meat by-product or poultry by-product if the total amount <10% of the end product

28. alimentary paste made without egg or non-wheat flour

29. bacterial culture

30. hydrolyzed plant protein

31. carbonated water

32. whey, whey powder, concentrated whey, whey butter and whey butter oil

33. mould culture

34. chlorinated water and fluorinated water

35. gelatin

36. toasted wheat crumbs used in or as a binder, filler or breading in or on a food product

Example:

Prepackaged salt sold in stores must declare a list of ingredients [e.g., salt, calcium silicate (an

anticaking agent), potassium iodide (a mineral nutrient)]. However, when salt is added as an

ingredient in other foods, only the word “salt” needs to be declared since salt is listed as item 20 in

B.01.009(1) of the FDR and none of its components are peanut oil (see Part 4 below), food




allergens, gluten sources or added sulphites (see Appendix 4G)

2) Preparations and Mixtures Exempt from Component Listings

B.01.009(2) of the FDR exempts the preparations or mixtures in Table 4E-2 from declaring:

• their components (2nd generation ingredients) except for :

< components listed in B.01.009(3) (see Part 3 below);

< all forms of peanut oil (see Part 4 below); and

< components that are

< food allergens or gluten sources (present at any level in the final food); or

< added sulphites (if present at 10 ppm or more in the final food) (see Appendix 4G).

• the components of their com ponents (3 rd generation ingredients), except for those listed in

B.01.009(3) (see Part 3 below) and those that are sources of food allergens, gluten and added

sulphites (see Appendix 4G).

Table 4E-2: Preparations or Mixtures Exempt from Com ponent Listings

Preparations or Mixtures Exempt from Component Listings

1. food colour preparations

2. flavouring preparations

3. artificial flavouring preparations

4. spice mixtures

5. seasoning or herb mixtures

6. vitamin preparations

7. mineral preparations

8. food additive preparations

9. rennet preparations

10. food flavour-enhancer preparations

11. compressed, dry, active or instant yeast preparations

3) Components and Com ponents of Components of Preparations or Mixtures Which Must

ALWAYS be Declared

B.01.009(3) of the FDR requires the declaration of the following components or components of

com ponents when they are added through the preparations or m ixtures listed in B.01.009(2) (see Part 2

above). These components or components of components listed in Table 4E-3 must be declared by

their comm on names in the list of ingredients of the food to which they are added as if they were direct

ingredients of that food.




Table 4E-3: Components and Com ponents of Com ponents of Preparations or Mixtures W hich m ust Always

be Declared

Components and Components of Components of

PREPARATIONS or MIXTURES which must ALWAYS be Declared

a) salt

b) glutam ic acid or its salts

c) hydrolyzed plant protein

d) aspartame

e) potassium chloride

f) any ingredient or component that performs a function in, or has any effect on, that food

Example: Tomatoes, tomato juice, calcium chloride, and a spice blend are added to canned

whole tomatoes. The spice blend contains a mixture of spices, salt and calcium

silicate. The com ponents of the spice blend are exempt from being declared on the

tomato label as per B.01.009(2), item 4, FDR. However, salt must be declared as if it

was added directly to the tomatoes, as per B.01.009(3)(a). The list of ingredients must

be: tomatoes, tom ato juice, ca lcium chlor ide, sp ices, salt.

Note: If salt is also added directly to the formula, the correct descending order of salt as an

ingredient in the fina l food is determined by using the combined weight of the added salt

and the salt in the spice blend.

B.01.009(3)(f) of the FDR requires that any ingredient or component which performs a function in a

food must be declared.

Examples:

• A preservative added to a food additive preparation in a quantity sufficient to preserve only the

food additive preparation is exempt from being declared in the list of ingredients of the final

food, as per B.01.009(2), item 8. However, if the preservative also has an effect on the final

food, it must be declared in the list of ingredients of the final food, as per B.01.009(3)(f).

• If colour added to a flavour preparation does not change the colour of the fina l food, “colour” is

exempt from being declared as a component of the final food, as per B.01.009(2), item 2. If the

colour in the flavour preparation changes the colour of the final food, “colour” must be declared,

as per B.01.009(3)(f).

It is not always easy to determine whether or not an ingredient or component has any effect on a

food, unless the ingredient supplier provides this information. However, flavour enhancers are

deemed to always have an effect on the final food. Flavour enhancers are not food additives. They

are considered to be ingredients and are permitted in foods which allow the use of spices and

seasonings. The following ingredients are flavour enhancers:

• calcium guanylate

• calcium inosinate

• calcium ribonucleotides

• disodium guanylate




• disodium inosinate

• hydrolyzed plant protein *

• monopotassium glutam ate

• monosodium glutamate *

• sodium ribonucleotides

* These two flavour enhancers are also specifically mentioned in B.01.009(3), FDR. The

abbreviation MSG is not acceptable for use in the list of ingredients, although it may be used in

optional information, elsewhere on the label (e.g., a "No MSG Added" claim).

Example: A seasoning preparation containing calcium inosinate (a f lavour enhancer) is

added to mincemeat. The components of seasoning are exempt from being

declared on the label of the final food, as per B.01.009(2), item 5, FDR. However,

flavour enhancers affect the taste of the final food and therefore have an effect on

the final food. Consequently, calcium inosinate must be declared, by name, in the

list of ingredients of the final food as if it was added directly to the food, as per

B.01.009(3)(f).

4) Peanut Oil (all forms) Must ALWAYS be Declared

B.01.009(4) of the FDR requires that the components listed in Table 4E-4, when contained in any

ingredient (including the ingredients listed in B.01.009(1) and (2) of the FDR, as discussed in Parts 1

and 2 above) must always be shown in the list of ingredients.

Table 4E-4: Components W hich must Always be Declared in the List of Ingredients

ALWAYS DECLARE

a) peanut oil

b) hydrogenated peanut oil

c) modified peanut oil

Example:

A natural flavour which contains peanut oil is added to canned green beans with seasoning.

"Flavouring preparations" are exempt from showing their components on the label of the final food

except for those components listed in B.01.009(3) and (4). Therefore, "peanut oil" must be shown

in the ingredient list of the canned green beans with seasoning.

Appendix 4FCHAPTER 4 INGREDIENT VERIFICATION



Com mon Names for Ingredients and Com ponents

The common nam e of a food must be used to identify the same food when added as an ingredient or

component, unless otherwise specified below.

1) Mandatory Common Names

B.01.010(3)(a) of the FDR (reproduced in Table 4F-1, with minor editorial changes) prescribes

mandatory common names for some ingredients and components. When the ingredients and

components listed in Colum n I are added to foods, they must be declared by the comm on name

prescribed in Colum n II. Always refer to the actual Regulations for the latest version.

Table 4F-1: Mandatory Common Names for Some Ingredients and Components

Item Column I - Ingredient or Component Column II - Mandatory Common Name

1 any oil, fa t or tallow described in

B.09.002, except lard, leaf lard or suet

the name of the meat from which the oil, fat or

tallow is obtained plus "oil", "fat" or "tallow"

2

shortening or m argarine containing fats

or oils, except shortening or margarine

containing coconut oil, palm oil, palm

kernel oil, peanut oil, or cocoa butter

"shortening" or "margarine" modified by

"vegetable oil" or "marine oil" or by the common

name of the vegetable, animal or marine oil or

fat used

3

shortening or margarine containing

coconut oil, palm oil, palm kernel oil,

peanut oil, or cocoa butter

"shortening" or "margarine" modified by the

comm on name of the vegetable oil or fat used

4 meat the name of the meat

5 poultry meat the name of the poultry

6 fish the name of the fish

7 plant protein product the name of the plant plus "protein product"

8 hydrolyzed plant protein "hydrolyzed" plus the name of the plant plus

"protein"

9 any protein isolate

the name of the source of the protein plus

"prote in" or the com mon name of the protein

isolate

10 any meat by-product described in

B.14.003, other than gelatin

the name of the meat plus "by-product" or the

name of the meat plus the name of the meat

by-product

11 any poultry meat by-product described in

B.22.003

the name of the poultry plus "by-product" or the

name of the poultry plus the nam e of poultry

meat by-product

12

any oil or fat referred to in B.09.002 that

has been hydrogenated or partially

hydrogenated, including tallow, but not

including lard

"hydrogenated" plus the name of the meat from

which the oil, fat or tallow is obtained, plus "oil",

"fat" or "tallow"

CHAPTER 4 INGREDIENT VERIFICATION Appendix 4F

Item Column I - Ingredient or Component Column II - Mandatory Common Name



13

any oil or fat referred to in B.09.002,

including tallow, that has been modified

by the complete or partial removal of a

fatty ac id

"modified" plus the name of the meat from

which the oil, fat or tallow is obtained, plus "oil",

"fat" or "tallow"

14

one or more vegetable fats or oils that

have been hydrogenated or partially

hydrogenated except coconut oil, palm

oil, palm kernel oil, peanut oil, or cocoa

butter

"hydrogenated vegetable oil" or "hydrogenated

vegetable fat" or "hydrogenated" plus the

specific name of the oil or fat

15


peanut oil, or cocoa butter that has been

hydrogenated or partially hydrogenated

"hydrogenated" plus the specific nam e of the oil

or fat

16

one or m ore marine fats or oils that have

been hydrogenated or partially

hydrogenated

"hydrogenated marine oil" or "hydrogenated

marine fat" or" hydrogenated" plus the specific

name of the oil or fat

17

one or more vegetable fats or oils that

have been modified by the complete or

partial removal of a fatty acid, except


peanut oil, or cocoa butter

"modified vegetable oil" or "modified vegetable

fat" or "modified" plus the specific name of the

oil or fat

18


peanut oil, or cocoa butter that has been

modified by the complete or partial

removal of a fatty acid

"modified" plus the specific name of the oil or

fat

19

one or m ore marine fats or oils that have

been modified by the complete or partial

removal of a fatty acid

"modified marine oil" or" modified" plus the

specific name of the oil or fat

20 starch the name of the plant plus starch

21 modified starch modified plus the name of the plant plus starch

22 lecithin the name of the source of the lecithin plus

23 crustacean the name of the crustacean

24 shellfish the name of the shellfish

Example: “Margarine” is a bold face term in B.09.016, FDR and therefore the m andatory

comm on name for the food. However, when margarine is used as an ingredient or

component, its mandatory ingredient/component name is prescribed by B.01.010(3)(a)

item s 2 and 3. Consequently, the word m argarine m ust be modified by the applicable

terms prescribed in Colum n II (e.g., “vegetable oil margarine”, “corn oil margarine”,

“palm oil margarine”, “peanut oil margarine”). W hen a food such as margarine is made

from a combination of different fats and oils, margarine may be shown in the list of

ingredients with the specific information about the fa ts or oils , in brackets, immediately

following the word margarine [e.g., “margarine (hydrogenated vegetable oil and/or

lard)”].

Note: Items 20 - 24 were added to B.01.010(3)(a) in 2012 to eliminate the potential for hidden

sources of food allergens and gluten (for details, see Appendix 4G). Examples:




• Starches and modified starches may be derived from different plant sources.

Mandatory comm on names include wheat starch, corn starch, etc. W heat is a food

allergen and a gluten source.

• Lecithin may be derived from soy or egg. The mandatory common names are soy

lecithin and egg lecithin, as applicable. Soy and eggs are both food allergens.

2) Optional Common Names

B.01.010(3)(b) of the FDR prescribes optional collective comm on names for ingredients and

components, which may be used provided none of the individual ingredients or components is shown

separately in the list of ingredients by its common name. B.01.010(3)(b) is reproduced in Table 2F-2,

with m inor editorial changes. W hen the ingredients and components listed in Colum n I are added to

foods, a company has the choice to either use the optional collective names listed in Column II or the

individual com mon names of each specific ingred ient or component.

W hile these names are permitted, if they depict ingredients which are not exempt from a component

declaration, the components must also be shown in the list of ingredients (i.e., in addition to the optional

com mon name).

Table 4F-2: Optional Common Names for Some Ingredients and Components

Item Column I

Ingredient or Component

Column II

Optional Common Name

1 one or more vegetable fats or oils , except coconut oil,

palm oil, palm kernel oil, peanut oil, or cocoa butter vegetable oil or vegetable fat

2 one or more m arine fats or oils marine oil

3 one or more of the colours listed in List 3 - Permitted

Colouring Agents colour

4

one or more substances prepared for their flavouring

properties and produced from animal or vegetable raw

materials or from food constituents derived solely from

animal or vegetable raw m aterials

flavour

5

one or more substances prepared for their flavouring

properties and derived in whole or in part from

components obtained by chemical synthesis

artificial flavour, imitation

flavour or simulated flavour

6 one or more spices, seasonings or herbs except salt spices, seasonings or herbs

7

any of the following in liquid, concentrated, dry, frozen or

reconstituted form: butter, buttermilk, butter oil, milk fat,

cream, milk, partly skimmed milk, skim m ilk and any

other component of milk the chemical composition of

which has not been altered and that exists in the food in

the same chemical state in which it is found in milk

milk ingredients


ItemColumn I


Column II




7.1

any of the following in liquid, concentrated, dry, frozen or

reconstituted form: calcium-reduced skim milk (obtained

by the ion-exchange process), casein, caseinates,

cultured milk products, milk serum proteins, ultrafiltered

milk, whey, whey butter, whey cream and any other

component of milk the chemical state of which has been

altered from that in which it is found in m ilk

modified milk ingredients

7.2

one or more ingredients or components set out in item 7

combined with any one or more ingredients or

com ponents set out in item 7.1

modified milk ingredients

8

any combination of disodium phosphate, monosodium

phosphate, sodium hexametaphosphate, sodium

tripolyphosphate, tetrasodium pyrophosphate and

sodium acid pyrophosphate

sodium phosphate or

sodium phosphates

9 one or more species of bacteria bacterial culture

10 one or more species of mould mold culture or mould culture

11 preparation contain ing rennin rennet

12 milk coagulating enzymes from Endothia parasitica,

Mucor miehei or Mucor pusillus Lindt microbial enzym e

13

one or m ore substances the function of which is to impart

flavour and that are obtained solely from the plant or

animal source after which the flavour is named

the name of the plant or animal

source p lus the word "flavour"

14

toasted wheat crumbs m ade by cooking a dough

prepared with flour and water, which may be unleavened,

or chemically or yeast leavened, and which otherwise

complies with the standard in B.13.021 or B.13.022

toasted wheat crumbs

15 that portion of chewing gum, other than the coating, that

does not impart sweetness, flavour or colour gum base

16 sugar, liquid sugar, invert sugar or liquid invert sugar,

singly or in combination sugar

17

glucose syrups and isomerized glucose syrups, singly or

in combination, where the fructose fraction #60% of the

sweetener on a dry basis

glucose-fructose

18

glucose syrups and isomerized glucose syrups, singly or

in combination, where the fructose fraction > 60% of the

sweetener on a dry basis

fructose syrup

19 sugar and/or glucose-fructose sugar/glucose-fructose

20 water to which carbon dioxide is added carbonated water

21

one or more of the following food additives: potassium

bisulphite, potassium metabisulphite, sodium bisulphite,

sodium metabisulphite, sodium sulphite, sodium

dithionite, sulphurous acid and sulphur dioxide

sulphites, sulphiting agents,

sulfites or sulfiting agents

22

dem ineralized water or water otherwise treated to

remove hardness or impurities, or fluoridated or

chlorinated water

water


ItemColumn I


Column II




23

wine vinegar, spirit vinegar, alcohol vinegar, white

vinegar, grain vinegar, malt vinegar, cider vinegar or

apple vinegar, singly or in combination

vinegar




Examples:

• Flavourings derived directly or indirectly from animal or vegetable raw materials may be listed

as "flavour" (item 4 above) or “natural flavour” (adm inistrative decision). Artific ial or synthetic

flavours are specifically excluded from this provision. These are captured in item 5.

• Colours can be declared collectively as “colour” (item 3 above), or separately, by the common

names listed in List 3 - Permitted Colouring Agents (the lists of Perm itted food additives are

discussed in Appendix 4D). In addition to the Canadian com mon name, it is administratively

permitted to declare the U.S. and/or European Union (EU) equivalents in the list of ingredients.

Table 4F-3 lists some of the common colours allowed in Canada.

Table 4F-3 : Common Colours Allowed in Canada and their U.S. and European Union (EU) Equivalents

Canada U.S. Equivalent EU Index No. Equivalent

Am aranth not permitted E123

Erythrosine FD & C Red #3 E127

Ponceau SX FD & C Red #4 not permitted

Citrus Red. No. 2 Citrus Red #2 not permitted

Allura Red FD & C Red #40 E129

Sunset Yellow FCF FD & C Yellow #6 E110

Tartrazine FD & C Yellow #5 E102

Fast Green FCF FD & C Green #3 not permitted

Brilliant Blue FCF FD & C Blue #1 E133

Indigotine FD & C Blue #2 E132

Annatto Bix in, Norbixin E160b

$-Carotene $-Carotene E160a

$-Apo-8'-Carotenal $-Apo-8'-Carotenal E160e

Ethyl $-apo-8'-carotenoate Ethyl $-apo-8'-carotenoate E160f

Canthaxanthin Canthaxanthin E161g

Carbon Black Hydrocarbon E153

Charcoal Charcoal not permitted

Titanium Dioxide Titanium Dioxide E171

Example: “Tartrazine” can be declared as “tartrazine”, “tartrazine (colour)”, “tartrazine (FD&C

Yellow No.5)”, “tartrazine (E102)”, “colour”, “colour (tartrazine)”, “colour (FD&C Yellow

No.5)” or “colour (E102)”.

If you are unsure about a colour dec lared in the ingredient list or found in a master form ula, check List 3

- Permitted Colouring Agents (the lists of Permitted food additives are discussed in Appendix 4D), or

contact your Supervisor, Program Officer or Processed Products Program Specialist.

3) Class Names

In B.01.010(4) of the FDR, “class” refers to a group of foods, ingredients or components that are

similar or share common characteristics, so that a single term can encompass all of the items.




W hen a food contains ingredients of the sam e class, those ingredients m ay be shown in the list of

ingredients by a c lass nam e, provided the following conditions are m et:

i) the ingredients m ust consist of m ore than one component;

ii) the ingredients must not be listed in the table to B.01.009(1) (i.e., ingredients exempt from

component dec laration, also shown in Table 4E-1);

iii) the components of these ingredients must be shown in brackets immediately following the class

nam e of the ingredients; and

iv) the components must be shown in descending order of their collective proportion (i.e., based on the

total amount of each com ponent).

Examples:

• Fruit preparations (concentrated pear and grape purees, concentrated grape juice, sugar, water,

colour)

• Fruit juices from concentrate (water, orange juice concentrate, pineapple juice concentrate, sugar)

• Frozen fruits (apples, apricots, raspberries, sugar)

• Dehydrated vegetables (carrots, peas, onions, sulphites)

4) Chemical Names of Food Additives

The chemical names of the food additives shown in any of the Lists of Permitted Food Additives (see

Appendix 4D) are acceptable for use in the list of ingredients. Abbreviations are not permitted, except

for butylated hydroxyanisole (BHA), butylated hydroxytoluene (BHT), tertiary butyl hydro quinone

(TBHQ), and ethlylenediaminetetraacetate (EDTA).

Example: “Sodium benzoate” is listed in List 11 - Permitted Preservatives (Class 2, item S.1) and

is the appropriate comm on name for the additive.

For the purpose of clarity and transparency, and in order to avoid any public confusion, manufacturers

are encouraged to identify food additives on the label using the name appearing in the Lists of

Permitted Food Additives. However, synonymous nam es listed in the document entitled “Food Additives

and their Synonyms” are acceptable as well.

Appendix 4GCHAPTER 4 INGREDIENT VERIFICATION



Enhanced Labelling of Food Allergens, Gluten Sources and Added Sulphites

To remove the potential for hidden food allergens, gluten sources and added sulphites on the label of

prepackaged foods, enhanced labelling regulations cam e into force on August 4 th, 2012.

As a result, B.01.010.1 to B.01.010.3 of the FDR exclude food allergens, gluten sources and added

sulphites from component exemptions listed in B.01.009 (see ) and require additional labelling when the

comm on names of ingredients or components (see Appendix 4F) are hidden sources of food allergens,

gluten sources and added sulphites.

These enhanced regulations prescribe:

• how to identify each food allergens, gluten sources and added sulphites (i.e., the source name that

must be used);

• where they must be declared (i.e., in the list of ingredients, or at the end of the list of ingredients in a

“Contains” statement); and

• when they must be declared (i.e., when present* as a result of being added as ingredients,

components, components of components, etc. Enhanced labelling applies to all generations of

ingredients).

* Present means:

• when food allergens and gluten sources are detectable, by current methodology, or are known

to be intentionally added to the food, regardless of amount present in the final food; and

• when sulphites are added and present at 10 ppm or more in the final prepackaged food.

Note: The enhanced labelling regulations do not rem ove the requirement to declare

sulphites under 10 ppm when sulphites are added as ingredients, or to ingredients

that are not exempt from component declaration. These sulphites must be

declared regardless of amount present in the final food. As scientific data indicates

the probability of an adverse reaction to sulphites below 10 ppm is m inim al,

enhanced labelling requirements only apply when sulphites are added and present

at 10 ppm or more in the final food.

Exceptions (relevant to processed fruit and vegetable products):

As per B.01.010.1(3), B.01.010.1(4) and B.01.010.2(4), the enhanced labelling requirements do not

apply to food allergens, gluten sources or added sulphites present in:

• Prepackaged foods as a result of cross-contamination. Cross-contamination must be controlled by

using Good Manufacturing Practices. If necessary, precautionary statements may be used (as

explained in Part 4 below);

• Prepackaged foods packaged from bulk on retail premises that do not declare a list of ingredients;

• Prepackaged individual portions of food that are served by a restaurant or other comm ercial

enterprise with meals or snacks that do not declare a list of ingredients; and

• Prepackaged individual servings of food that are prepared by a com missary and sold by automatic

vending machines or mobile canteens that do not declare a list of ingredients.

CHAPTER 4 INGREDIENT VERIFICATION Appendix 4G



Column 1 of Table 4G-1 below summ arizes the definitions of food allergens, gluten sources and sulphites

as defined in B.01.010.1(1) and B.01.010.2(1) of the FDR. Column 2 indicates the prescribed source names

for these substances that must be used in the list of ingredients or in the “Contains” statem ent.

Table 4G-1: Definitions and Source Names for Food Allergens, Gluten Sources and Sulphites

Column 1 - Definition Column 2 - Prescribed Source Name

almonds

:m

orfs

n

oic

tarf

niet

orp r

n

o

e ,

g

n

r ie

e

t ll o

A r

p

d d

o

e

o if

F i

do

m ,ni

etor

py

n

a ,.e .i

Brazil nuts

cashews

hazelnuts

macadam ia nuts

pecans

pine nuts

pistachios

walnuts

same as column 1

(in singular or plural form) [B.01.010.1(6)(a)]

peanuts peanuts or peanut [B.01.010.1(6)(a)]

sesame seeds sesame seeds, sesame seed or sesame [B.01.010.1(6)(b)]

wheat and triticale wheat and triticale [B.01.010.1(6)(c)]

eggs eggs or egg [B.01.010.1(6)(a)]

milk milk [B.01.010.1(6)(c)]

soybeans soybeans, soybean, soya or soy [B.01.010.1(6)(d)]

crustaceans name of the crustacean [B.01.010.1(6)(e)]

shellfish name of the shel

lfish [B.01.010.1(6)(e)]

fish name of the fish [B.01.010.1(6)(e)]

mustard seeds mustard seeds, mustard seed or mustard [B.01.010.1(6)(f)]

Gluten

i.e, gluten protein, modified gluten protein, or gluten

protein fractions from the grain of these cereals or

the grain of their hybridized strains:

barley barley [B.01.010.1(7)(a) and (b)]

oats oats [B.01.010.1(7)(a) and (b)]

rye rye [B.01.010.1(7)(a) and (b)]

triticale triticale [B.01.010.1(7)(a) and (b)]

wheat wheat [B.01.010.1(7)(a) and (b)




Ad

de

d S

u lp

hi t

e s

.i e

., t

he

ad

ditio

n o

f o

n

e

o r

m o

r

e o

f th

es

e f

oo

d a

dd

itiv

es

:

Group A Common Names*

potassium bisulphite

potassium metabisulphite

sodium bisulphite

sodium metabisulphite

sodium sulph ite

Prescribed source names for the list of ingredients:

• same as the comm on names in column 1; or

• one of the optional common names listed in

B.01.010(3)(b) of the FDR (i.e., sulfites, sulfiting agents,

sulphites or sulphiting agents).

Prescribed source nam es for the ”Contains” statem ent:

• sulfites, sulfiting agents, sulphites or sulphiting agents

[B.01.010.2(6)]

Group B Common Names*

sodium dithionite

sulphur dioxide

sulphurous acid

Prescribed source names for the list of ingredients:

• if one of the comm on names in column 1 is used, it must

be followed, in brackets, by one of these source names

(i.e., sulfites, sulfiting agents, sulphites or sulphiting

agents) unless a source name is shown in the “Contains”

statement; or

• one of the optional comm on names (i.e., sulfites, sulfiting

agents, sulphites or sulphiting agents).

Prescribed source nam es for the ”Contains” statem ent:


[B.01.010.2(6)]

* Optional Common Names : Food additives from Groups A and B may collectively be

declared in the list of ingredients by any of these optional comm on names: sulfites, sulfiting

agents, sulphites or sulph iting agents [B.01.010(3)(b), item 21, FDR].

The definitions of food allergen and gluten include any protein, modified protein, or protein fractions from

the item s listed in column 1 of Table 4G-1. The definition of added sulphites include food additives listed in

Groups A and B in column 1. Therefore, the common name of som e ingredients and components added in

foods may not be recognized as an allergen or gluten source.

Examples:

• Milk allergens include cream, butter, sodium caseinate, whey powder, etc.

• Egg allergens include liquid albumen (i.e., egg whites), egg lecithin, etc.

• Wheat allergens and wheat gluten include flour, durum, spelt, kamut, wheat starch, etc.

• Added sulphites include food additives from Group B. These do not contain the word “sulphite”.

To help consumers make safe food choices, the FDR prescribes source names that must be declared

when a source of food allergen, gluten or added sulphites is present in a prepackaged food (as shown in

column 2 of Table 4G-1). These source names must appear in the list of ingredients or in a “Contains”

statement. W hen a “Contains” statement is used, all food allergens, gluten sources and added sulphites (>

10 ppm) must be listed, even if they are already listed in the list of ingredients.

The enhanced labelling requirements for prepackaged foods are summ arized as follows:




1) Food Allergens and Gluten Sources

a) Added as Ingredients

Just like all ingredients, any food allergens and gluten sources added directly to a product must be

declared in the list of ingredients by their comm on names.

i) If the comm on name of the ingredient added is the same as the prescribed source name listed

in column 2 of Table 4G-1, no additional labelling is required. The “Contains” statem ent is

optional.

Example: Ingredients: ..., wheat, milk, eggs; or

..., wheat, milk, eggs. Contains wheat, milk and egg.

ii) If the ingredient added is a food allergen or gluten source, but the common name of the

ingredient added is not one of the prescribed source names listed in column 2 of Table 4G-1,

the prescribed source name of the food allergen or gluten source must also be declared either

in brackets fo llowing the common name of the ingredient added or in the “Contains” statement.

Example: Spelt, sodium caseinate and liquid albumen are acceptable comm on names

for ingredients. However, they are hidden sources of food allergens and

gluten. Therefore, the prescribed source names must also be declared as

follows:

Ingredients: ..., spelt (wheat), sodium caseinate (milk), liquid albumen

(egg); or

..., spelt, sodium caseinate, liquid albumen. Contains wheat,

milk and egg.

Note: If the food is a single ingredient food that does not declare a list of ingredients, the

comm on name of the food is also considered to be the list of ingredients.

Therefore, the prescribed source name of the food allergen or gluten source

should also be declared either in brackets following the common nam e of the food

or in a “Contains” statement.

b) Added to Ingredients that are NOT EXEM PT from Declaring their Components

W hen food allergens and gluten sources are added to ingredients that are not exempt from

declaring their components, they must be declared, by their comm on names. This applies

regardless of the quantity of food allergens and gluten sources present in the final food.

i) If the comm on name of the component added is the same as the prescribed source name

listed in column 2 of Table 4G-1, no additional labelling is required.

Example: Salad dressing is not exempt from component listing in B.01.009(1) or (2),

FDR. Therefore, if salad dressing (contain ing canola oil, egg whites, etc) is




added to a sauce, all its components, including egg whites, must be declared

in the list of ingredients of the sauce:

Ingredients: ..., salad dressing (..., egg whites, ...).

ii) If the component added is a source of a food allergen or gluten, but the comm on name of the

component added is not one of the prescribed source names listed in column 2 of Table 4G-

1 above, the prescribed source name of the food allergen or gluten source must also be

declared either in brackets following the common nam e of the component added or in the

“Contains” statement.

Example: Another acceptable common name for egg white is liquid album en. If liquid

albumen was declared as one of the salad dressing’s components, egg must

be declared as the prescribed source name as follows:

Ingredients: ..., salad dressing [..., liquid albumen (egg), ...]; or

..., salad dressing (..., liquid albumen, ...). Contains egg.

c) Added to Ingredients that are EXEM PT from Declaring their Components

W hen food allergens and gluten sources are added to ingredients that are exempt from declaring

their components, these food allergens and gluten sources must be declared by their prescribed

source names listed in column 2 of Table 4G-1. This declaration must appear in the list of

ingredients (in brackets fo llowing the ingredient to which it is added), or in a “Contains” statem ent,

regardless of the amount present in the final food. All other components remain exempt from

declaration.

Example: W hen m argarine and baking powder are added as ingredients in other foods, their

com ponents are exem pt from being declared [B.01.009(1), item s 2 and 15, FDR].

If canola oil margarine (containing whey powder, etc) and baking powder

(containing wheat starch, etc) are added as ingredients, only the allergen sources

must be declared as components, and this, by their prescribed source names.

Therefore, whey powder and wheat starch must be declared as milk and wheat

respectively (i.e., the prescribed source names). The options are:

Ingredients: ..., canola oil margarine (milk), baking powder (wheat); or

..., canola oil margarine, baking powder. Contains m ilk and wheat.

2) Sulphites

a) Sulphites Added as Ingredients

Just like all ingredients, sulphites added directly to a product must be declared in the list of

ingredients by their actual comm on names (as listed in column 1, Groups A and B in Table 4G-1) or

collectively by one of their optional comm on names (listed in the last row of Table 4G-1). If the final

food contains:

i) less than 10 ppm of added sulphites, no additional labelling is required.




Example: Ingredients: ..., sodium metabisulphite, sulphur dioxide; or

..., sulphites8.

ii) 10 ppm or more of added sulphites, the prescribed source name must be declared in the list of

ingredients or in the “Contains” statement. As stated in column 2 of Table 4G-1:

• The prescribed source names for the list of ingredients are:

• the common names of the food additives listed in Group A in column 1;

Example: Ingredients: ..., sodium metabisulphite

• one of the optional comm on names listed in the last row of Table 4G-1; or

Example: Ingredients: ..., sulphites8

• if one of the com mon names of the food additives listed in Group B, column 1 is used, it

must be followed, in brackets, by one of these prescribed source names (i.e., sulfites,

sulfiting agents, sulphites or sulphiting agents) unless a source name is shown in the


Example: Ingredients: ..., sulphur dioxide (sulphites8); or

..., sulphur dioxide. Contains sulphites8

• The prescribed source names for the “Contains” statement are:


b) Sulphites Added to Ingredients that are NOT EXEM PT from Declaring their Components

W hen sulphites are added to ingredients that are not exempt from declaring their components under

B.01.009(1) or (2), FDR, the sulphites must be declared in the list of ingredients by their actual

comm on names (see colum n 1, Groups A and B in Table 4G-1) or collectively by one of their

optional comm on names (see the last row of Table 4G-1). If the final food contains:

i) less than 10 ppm of added sulphites, no additional labelling is required.

Example: Lemon juice from concentrate is not exempt from com ponent listing. If the

juice is added as an ingredient, all its components, including sulphites from

Groups A or B, must be declared in the list of ingredients of the final food:

Ingredients: ..., lemon juice from concentrate (.., sodium metabisulphite);

..., lemon juice from concentrate (..., sulphur dioxide); or

..., lemon juice from concentrate (..., sulphites8)

ii) 10 ppm or more of added sulphites, the prescribed source name must be declared in the list

of ingredients or in the “Contains” statement. As stated in column 2 of Table 4G-1:

8The term sulphites may be replaced by sulfites, sulfiting agents or sulphiting agents.




• The prescribed source names for the list of ingredients are:

• the common names of the food additives listed in Group A of column 1;

Exam ple: ..., lemon juice from concentrate (.., sodium metabisulphite);

• one of the optional comm on names listed in the last row of Table 4G-1; or

Example: ..., lemon juice from concentrate (.., sulphites8);

• if one of the comm on names of the food additives listed in Group B of column 1 is used,

it must be followed, in brackets, by one of these prescribed source names (i.e., sulfites,

sulfiting agents, sulphites or sulphiting agents) unless a source name is shown in the


Example: ..., lemon juice from concentrate [..., sulphur dioxide (sulphites8)]; or

..., lemon juice from concentrate [..., sulphur dioxide]. Contains sulphites8

• The prescribed source names for the “Contains” statement are:


c) Sulphites Added to Ingredients that are EXEM PT from Declaring their Components

MUST be Declared if Sulphites are Present at > 10 ppm in the Final Food

As explained in Appendix 4E, some ingredients are exempt from declaring their components.

However, the enhanced labelling regulations require that sulphites added to any of these ingredients

be declared if the sulphites are present at 10 ppm or more in the prepackaged food. The applicable

prescribed source name listed in column 2 of Table 4G-1 must be declared in the list of

ingredients of the final food (either in brackets following the ingredient to which it is added or at the

end of the list of ingredients), or in the “Contains” statem ent.

Example: Glucose is exempt from com ponent listing in B.01.009(1), item 18, FDR. If glucose

(containing sulphites from Groups A or B) is added to canned peaches, and the final

food contains at least 10 ppm added sulphites, the sulphites must be declared as

follows:

Ingredients: Peaches, glucose (sulphites8), ...;

Peaches, glucose, ... sulphites8; or

Peaches, glucose.... Contains sulphites8.

Note: A “Contains” statement should not be used when less than 10 ppm of sulphites are present

in the final food.

3) Precautionary Statements for Food Allergens, Gluten Sources and Sulphites

The presence of food allergens, gluten sources and sulphites in foods cannot always be avoided. Cross-

8 The term sulphites may be replaced by sulfites, sulfiting agents or sulphiting agents.




contamination can occur at any level of production (e.g., at the facility being inspected, at the ingredient

supplier’s premises). To help industry address this issue, refer them to “A Tool for Managing Allergen

Risk in Food Products” on the CFIA website.

If, despite all reasonable precautions, the potential cross-contamination with food allergens, gluten

sources and sulphites in the food is unavoidable, a precautionary statement may be used on the labels

of prepackaged foods.

Precautionary statements:

• must be truthful;

• must not be used in lieu of adherence to legal requirements and/or good manufacturing practices;

• must not be used for food allergens, gluten sources and sulphites added directly or indirectly to a

food as they must be declared in the list of ingredients or in the “Contains”statem ent (as explained in

Parts 1 to 3 above); and

• should appear at the end of the list of ingredients, or after the “Contains” statement (if one is used).

“Contains” statements are explained in Parts 1 to 3 above.

Health Canada and the CFIA now recommend the use of only one precautionary statement on food

labels:

• “may contain [X ]”

where X is the source name of the food allergen, gluten source of sulphites (as per column 2 of

Table 4E-5 above).

For details, refer to “The Use of Food Allergen Precautionary Statements on Prepackaged Foods” on

Health Canada’s website.

Appendix 4HCHAPTER 4 INGREDIENT VERIFICATION



Declaring Water in the Ingredient List

W hen declaring water in the ingredient list, the proper descending order can be determined before or after

the product is cooked. If the water added:

(a) remains in the finished product, in whole or in part, it must be declared; or

(b) completely evaporates during processing, it is considered a processing aid and can be omitted from

the ingredient list.

Calculate the amount of added water in the finished product using the following formula:

Weight of Residual Water (X) = Weight of final food - Weight of raw ingredients (except w ater)

If X = positive value, water is an ingredient and must be declared.

If X = zero or a negative value, water is considered a processing aid and is exempt from being

declared.

Examples:

1) W ater added to restore a dehydrated or concentrated ingredient to its orig inal form. Since water is

present in the final food, it must be declared:

X = 2 kg (Weight of final food) - 0.5 kg [Weight of raw ingredients (except water)]

= + 1.5 kg W ater must be declared

2) W ater added to a product partially evaporates during cooking. Since water is present in the final

food, it must be declared:

X = 2 kg - 1.8 kg

= + 0.2 kg W ater must be declared

In this example, residual water contributes 200 g to the final food. Since the proper descending order

of water can be considered before or after the product is cooked, water could be declared based on

the amount added, or it may be declared further down the list, based on the 200 g residual water.

3) W ater added to a batch of jam. The water evaporates during cooking and the final moisture content

of the jam is less than the initial moisture content of the fruit and other ingredients (except water)

combined. Since there is no residual water remaining from the water initially added to the formula,

the company has the option to omit water from the list of ingredients of the jam.

CHAPTER 4 INGREDIENT VERIFICATION Appendix 4H



X = 2 kg - 2.2 kg

= - 0.2 kg W ater is exempt from being declared (a processing aid)

Other Scenario:

A pickle manufacturer dilutes vinegar (12% acetic acid) with water to make a 5% acetic acid solution. Since

vinegar is exem pt from declaring its components (as per B.01.009(1), item 21, FDR), the manufacturer has

the option of declaring “water and vinegar” or just “vinegar” providing the diluted solution contains at least

4.1% acetic acid (minimum for vinegar, as per B.19.001, FDR). Even though water is not permitted in pickles

(Schedule II, Section 38, PPR), it is permitted via the dilution of vinegar to a proper concentration, and via the

use of sugar in liquid form. Also, cucumbers are often ferm ented in a brine composed of water and salt,

which adds some water content.

Appendix 4ICHAPTER 4 INGREDIENT VERIFICATION



Processing Aids

A substance added to a food is either a food ingredient, a food additive or a processing aid.

1) Definitions

The FDR and the PPR define “ingredient” and "food additive" as follows:

"Ingredient" means an individual unit of food that is combined as an individual unit of food with one

or more individual units of food to form an integral unit of food that is sold as a prepackaged product

Note: Ingredients are discussed in detail throughout this chapter.

"Food additive" means any substance, the use of which results, or may reasonably be expected to

result, in it or its by-products becoming a part of or affecting the characteristics of a food. The

substances excluded from the definition of food additive are:

• any nutritive material that is used, recognized or commonly sold as an article or ingredient of

food

• vitamins, minerals and amino acids, unless shown in one of the Lists of Permitted Food

Additives

• spices, seasonings, flavouring preparations, essential oils, oleoresins and natural extractives

• agricultural chemicals, unless shown in one of the Lists of Permitted Food Additives

• food packaging materials and com ponents

• drugs administered to animals that may be consumed as food

Note: Food additives are discussed in detail in Appendix 4D

The FDR and the PPR do not define, or even mention, “processing aid”. These substances fall outside

the regulatory definitions of "ingredient" and "food additive". In summary, a:

“Processing aid”:

• is a substance added to a food for a technological effect during processing;

• does not effect the intrinsic characteristics of the finished product; and

• is not present, including its by-products, in or on the finished product or is present at insignificant

and nonfunctional levels.

2) Legal Requirements and Use of Processing Aids

Substances used as processing aids must be of suitable food-grade quality and safe for its intended

use. Food allergens, gluten sources and sulphites should not be used as processing aids as they may

pose a health risk to consumers with food allergies and sensitivities. Like all substances used with food,

the use of a processing aid is ultimately controlled by section 4, FDA.

Note: For details on food allergens, g luten sources and sulphites, see Appendix 4G of this

chapter.

Processing aids are exempt from being declared in the list of ingredients of the finished product since

CHAPTER 4 INGREDIENT VERIFICATION Appendix 4I



they fall outside the regulatory definitions of "ingredient" and "food additive". The FDR and PPR only

require the declaration of ingredients, including food additives, on labels applied to finished products.

Determ ining whether a substance is an ingredient, a food additive or a processing aid is not always easy.

The decision tree in Flowchart 4H can be used to identify food additives and processing aids based on

the regulatory definition of food additive. The questions in the tree should be answered by the principles

outlined under "Principles for using the decision tree" in Health Canada’s Policy for Differentiating Food

Additives and Processing Aids.

Example: Depending on the conditions surrounding the use of dimethylpolysiloxane (an

antifoaming agent), it can either be a food additive (List 8 - Permitted Food Additives

with Other Accepted Uses) or a process ing aid. If dimethylpolysiloxane is used to

prevent or minimize foaming:

• in the water used to process potatoes, the technical effect is on the water, not on

the potatoes (i.e., the effect is on process ing, not on the finished product). If there

are no or negligible residues of the antifoaming agent or its by-products in, or on,

the finished potato product, the antifoaming agent is considered to be a processing

aid.

Note: The antifoaming agent may or may not be permitted in the finished

food. If it isn't permitted by List 8 - Permitted Food Additives with

Other Accepted Uses, it is the com pany’s responsibility to consult

with Health Canada.

• during the final filling stage of a jam , the antifoam ing agent is a food additive since it

is present in the finished product. Therefore, dimethylpolysiloxane must be

permitted in the finished product by List 8 - Permitted Food Additives with Other

Accepted Uses and by the compositional requirements for the food under the FDR

and/or PPR (as applicable). Furthermore, dimethylpolysiloxane must be declared on

the label of the finished product.

The final decision as to whether or not a substance is a food additive or a processing aid rests with the

Bureau of Chemical Safety at Health Canada. Industry may request the Bureau to conduct a case-by-

case pre-market assessment and offer advisory comm ents on the status of a substance as a food

additive or a process ing aid, and its acceptability for use in food manufacturing or processing. Requests

can be addressed to:

Chief

Chemical Health Hazard Assessment Division

Bureau of Chem ical Safety, Food D irectorate

Health Products and Food Branch

Health Canada

Address Locator: 2201C

Sir Frederick G. Banting Research Centre

251 Sir Frederick Banting Driveway

Ottawa, ON K1A 0K9

CFIA inspectors should treat all substances added to a food as being ingredients or food additives (as

applicable), unless:




• the substance is listed in Table 4H (i.e., recognized as a processing aid);

• the company can provide evidence that the substance is not an ingredient and qualifies as a

processing aid; or

• the company can provide a copy of the letter of opinion from Health Canada showing the substance

is not a food additive and qualifies as a processing aid.

Note: For assistance on case-by-case assessments, inspectors can contact their Program Officer

or Processed Products Program Specialist.

Table 4H: Some substances added as processing aids (as per section 2.8.3 of the Labelling Guide)

Item Substance

1 Hydrogen for hydrogenation purposes, currently exempt under B.01.008, FDR

2 Cleansers and sanitisers

3 Head space flushing gases and packaging gases

4 Contact freezing and cooling agents

5 W ashing and peeling agents

6 Clarifying or filtering agents used in the processing of fruit juice, etc.

7 Catalysts that are essential to the manufacturing process and without which, the final food product

would not exist (e.g., nickel and copper)

8 Ion exchange resins, membranes and molecular sieves that are involved in physical separation

and that are not incorporated into the food

9 Desiccating agents or oxygen scavengers that are not incorporated into the food

10 W ater treatment chemicals for steam production




Flowchart 4H: Decision tree to identify food additives and processing aids

chapter 4 - ingredient verification – pdf

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