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Alliancefor Food Label Reform

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									   Alliance
   pour la réforme de l’
                                                      for Food Label Reform
                        étiquetage des produits alimentaires

                                                                                  September 14, 2001
Mr. Ronald Burke
Bureau of Food Regulatory, International and Interagency Affairs
Health Canada
Room 2395, Address Locator 0702C1
Health Protection Building
        s
Tunney’ Pasture
Ottawa, Ontario K1A 0L2

Re: Nutrition Labelling, Nutrition Claims, and Health Claims; Canada Gazette, Part I
(published June 16, 2001)


Dear Mr. Burke:

        The Alliance for Food Label Reform1 would like to congratulate Health Canada and
Minister Rock for moving ahead with plans to introduce comprehensive food labelling reforms.
We are especially pleased with the decision to mandate that comprehensive nutrition information
be reported on most packaged foods in absolute values and as a percentage of the average
recommended daily intake, and that this information be displayed on labels in a uniform, easy-
to-read format.


Benefits of food label reforms

        Preventative health care is a forward thinking, cost-effective approach to enhancing the
health of the public. As Health Canada, and Agriculture and Agri-food Canada noted, poor diet


         1
         The Alliance for Food Label Reform is a coalition of 17 non-profit organizations
representing nearly two million consumers, scientists, physicians, nutritionists, and other health
professionals from all across Canada. The Alliance has urged Health Canada and Members of
Parliament, since 1997, to establish mandatory, comprehensive, easy-to-read nutrition
information on all food labels and to prevent the misleading use of health and nutrition
marketing claims for foods.



Alliance Coordinator:          Bill Jeffery, L.LB.,           Centre for Science in the Public Interest /
Coordonnateur de l’Alliance:                                 Centre pour la science dans l’intérêt public
 Suite 412, 1 rue Nicholas St., Ottawa, ON, K1N 7B7 ! Tél (613) 565-2140 ! Fax (613) 565-6520
                                                  -2-

is expected to cost the Canadian economy more than $76 billion during the next two decades.2
The proposed reforms to food labelling rules are expected to generate $5 billion in net savings
over the same period as a result of declining premature deaths and disabilities due to
cardiovascular disease, stroke, cancer, and diabetes. These predicted cost savings contrast very
favorably with the comparatively small $263 to $357 million in costs to industry for
implementing the label reforms.3


The opportunity and need for refinements to the proposal

        The proposed amendments to the Food and Drug Regulations represent an opportunity
for fundamental reform of food labels, and all reasonable steps should be taken to optimize this
opportunity to capture benefits not accounted for in the Regulatory Impact Analysis Statement as
published in the June 16, 2001 Canada Gazette notice. For instance, the regulatory proposal
should extend the scope of mandatory nutrition labelling rules to encompass all fresh meat,
poultry, seafood and in-store baked goods – some of which are chief sources of heart-disease-
promoting saturated and trans fats. This review could also be used as an opportunity to require
concise explanatory notes in nutrition claims to, for example, prevent consumers from getting the
false impression that “low fat” and “low sugar” foods are necessarily also “low calorie” foods.4

        It is also critical that the proposed regulatory amendments be revised to prevent the
proliferation of misleading claims -- especially in connection with the proposed “health claims”
which are currently prohibited outright under Canadian law. While the Alliance for Food Label
Reform has been a strong advocate of mandatory, nutrition labelling, we have been concerned
that some health and nutrition marketing claims may deceive consumers and impair, rather than
improve, the health status of Canadians. Two of the five proposed health claims are of particular
concern because they could mislead consumers. For example, the osteoporosis risk reduction
claim would, as proposed, be permitted on foods that are high in heart-disease-promoting
saturated fat. Putting the claim on these foods would mislead the public and, rather than benefit
the health of the public, it could increase the risk of other diseases and undermine the credibility
of the entire food label. Similarly, the cancer risk reduction claim would be allowed on foods
such as condiments, fruit jams, and fruit jellies that are high in sodium or contain very little fruits
or vegetables (the ingredients upon which the justification for the claim is based). We urge that

        2
         This estimate includes the diet-related costs (expressed in 2000 dollars) anticipated over
the period 2002-2022 for only four diagnostic categories: cancer, diabetes, heart disease and
stroke. See Agriculture and Agri-food Canada, Costs and Benefits of Nutrition Information,
(Ottawa: HC and AAFC, May 2000) at 4.
        3
            Ibid. at 4 and 6. See also, Canada Gazette, Part I, (June 16, 2001), Vol. 135, No. 24 at
2054-5.
        4
         For example, “low fat” claims should be accompanied, where appropriate, by the
statement: “Not a low calorie food.”
                                               -3-

these shortcomings be remedied before the regulations are finalized, not after they have caused
problems.


Specific recommendations for improving the regulatory proposal

      In particular, the proposed regulations could be vastly improved by taking the following
measures:

       •Close the loophole for labelling fresh meat, poultry, seafood, fruits and vegetables: If
       necessary, Health Canada should provide a three year grace period for complying with
       mandatory nutrition labelling rules for pre-packed, single-ingredient fresh meat, poultry,
       and marine, freshwater animal products, fruits, and vegetables rather than exempting them
       outright (i.e., delete proposed paragraphs B.01.401(2)(b)(ii), (iii) and (iv) and revise the
       transition provisions in subsection 34(3) of the proposal accordingly).5

       •Do not exempt in-store baked goods: In-store baked goods (including desserts high in
       trans and saturated fats, low-fibre breads, and high-calorie muffins) should not be exempt
       from the general requirement to provide nutrition information. We urge Health Canada to
       limit the proposed exemption for foods processed and prepared on-site at the retail
       premises (see proposed paragraph B.01.401(2)(b)(vi)) to foods that are made to order at
       the request of individual shoppers.

       •Ensure that nutrition information is provided on the basis of standardized serving sizes,
       not ranges: Standardization of serving sizes makes it easier for consumers to make
       nutrient comparisons among foods and ensures that companies do not use unrealistically
       small or large serving sizes to favourably portray the nutritional composition of their
       products. While Schedule M of the proposed regulations specifies standard reference
       amounts for 151 foods, it is not clear that these will be used as the basis of nutrition
       labelling (rather than merely nutrition and health claims). However, in October 2000,
       Minister Rock published Principles of Proposed Policy for Nutrition Labelling which
       states, in part: “Servings are based on ‘Reference Amounts’of food which are
       standardized quantities reflecting the amount of a food consumed at a single eating
       occasion. Reference amounts...will be included in the Food and Drug Regulations.”6



        5
          In particular, the additional year (beyond the standard two year implementation period)
will give the meat industry sufficient opportunity to create accurate databases for the common
cuts and species of products. The use of nutrition information in advertisements and industry
web-site marketing information suggests much progress has already been made.
        6
         See: < http://www.hc-sc.gc.ca/food-aliment/english/subjects/food_labelling_and
_claims/proposed_policy_nutrition_labelling.html >.
                                                -4-

       •Tighten rules for making health claims: Health Canada should tighten the eligibility
       rules for the use of health claims -- especially claims related to osteoporosis7 and cancer8 -
       - so that only foods low in saturated and trans fat, cholesterol, sodium, and added sugars
       would be eligible to make such claims. Excessive consumption of these nutrients is
       linked to heart disease and some forms of cancer, as well as obesity -- which is a risk
       factor for diabetes and coronary heart disease.

       Another possible approach would be to require that, in the case of the calcium/vitamin
       D–osteoporosis claim, a separate claim statement be used for products higher in saturated
       fat. Under this approach, the claim statement should be worded so that parents will know
       to buy different types of milk and other foods for their children (i.e., low fat for the adults
       and higher fat for the children), or so parents will know to gradually switch the family
       back to lower saturated fat dairy foods as their children reach the end of linear growth.
                                                                 s
       Following this approach would address Health Canada’ concern that limiting the claim to
       low fat products may impair the bone growth of children by indirectly decreasing their fat
       intake. We propose that high calcium/vitamin D foods that have more than 2 grams of
       saturated fat be required to disclose in the claim statement the amount of saturated fat in a
       serving of the food and advise adult consumers to choose foods lower in saturated fat.9




       7
          Under the current regulatory proposal, the calcium/vitamin D-osteoporosis claim would
be permitted on foods that are high in added sugars or heart-disease-inducing saturated fat (such
as ice-cream, milk shakes, high fat cheeses, and homogenized milk). High levels of saturated
fats increase the risk of heart disease in the adults who might be drawn to the osteoporosis
claims, thereby offsetting the benefits to bone health. Claims should be prohibited on these
foods or, if not, then the fact that they are high in saturated or trans fat should be disclosed in the
claim statement.
       8
          This claim raises two problems. First, it could be made about high sodium products,
such as pickles, which can increase the risk of another diet-related disease. Second, it can appear
on labels of some products (e.g., ketchup, relish, and fruit jams and jellies that must comply with
compositional standards set out in Division 11 of the current Food and Drug Regulations) for
which a customary and nutritionally desirable serving delivers only a very small amount of the
beneficial ingredients.
       9
         For instance, a calcium/vitamin D–osteoporosis claim could appear on packages of
homogenized milk, ice cream, or cheeses if the following modified claim statement were used:
“A healthy diet with adequate calcium and vitamin D, and regular physical activity, help to
achieve strong bones and may reduce the risk of osteoporosis. A serving of this food contains
(naming the percent)% of the recommended maximum daily intake of saturated fat. Adults who
choose foods lower in saturated fat may reduce their risk of heart disease.” [proposed
modification underlined]
                                                -5-

       •Control the use of all health -related claims: All claims -- including biological role
       claims,10 structure/function claims, and endorsements by 3rd party health charities --
       should be required to satisfy the same standards for claim substantiation, safety, pre-
       market approval, and labelling as those set out for health claims. These claims can be
       easily mistaken by consumers to be authorized health claims and should, therefore, be
       required to meet the same high standards.


Conclusion

        Health Canada has an opportunity to fashion new food labelling regulations that will
deliver maximum health benefits to Canadians and be regarded, by public health officials world-
wide, as the model to emulate -- much like the current Canadian tobacco regulations. We urge
Health Canada to review its proposal with the objective of ambitiously advancing the public’   s
health, in particular, by ensuring that nutrition information is on as many foods as possible,
including fresh meat, poultry, seafood, and in-store baked goods. At a minimum, the federal
government should not finalize weak eligibility rules for the use of health claims that could
promote unhealthful dietary practice and ultimately harm, rather than benefit, the health of
consumers.

        If Health Canada can design health claims messages and eligibility criteria that send
accurate, useful messages to consumers which can truly assist them in selecting more healthful
foods, it should require all eligible foods to make all applicable claims on their labels. Voluntary
health claims on a few products may simply mimic the problems of voluntary nutrition labelling.
By contrast, mandatory health claims for all eligible foods would ensure that consumers have
complete and consistent health information about all foods that qualify to make claims.11

       We also urge that Health Canada and the Canadian Food Inspection Agency have the
funds necessary to educate the public about the new labels, monitor compliance by
manufacturers, and take appropriate enforcement measures when necessary.

        If we can be of any assistance to your office in addressing these concerns, please do not
hesitate to contact us at (613) 565-2140.




        10
             These are permitted under proposed paragraph B.01.311(2)(b).
        11
           Foods that are eligible to make more than one claim on labels (e.g., most fruits and
vegetables) could either make all claims on each label or rotate the use of eligible claims. This
approach is analogous to warning labels that appear on cigarette packages except that, in this
case, all of the messages would be positive and would promote, rather than discourage, the sale
of foods bearing the label statement(s).
                                            -6-


Respectfully submitted,

[original signature by BJ]
_______________________________
Bill Jeffery, L.LB., Coordinator
Alliance for Food Label Reform


cc.    The Honourable Allan Rock, M.P., P.C., Minister of Health
       The Right Honourable Prime Minister Jean Chrétien, M.P., P.C.
       The Honourable Deputy Prime Minister Herb Gray, M.P., P.C., and
              Chair, Special Committee of Council
       The Honourable Anne McLellan, M.P., P.C., Minister of Justice and Attorney General
       and
              Vice-Chair, Special Committee of Council
       The Honourable Paul Martin, M.P., P.C., Minister of Finance and
              Member, Special Committee of Council
       The Honourable Lucienne Robillard, M.P., P.C., President of the Treasury Board and
              Member, Special Committee of Council
       The Honourable Lyle Vanclief, M.P., P.C., Minister of Agriculture and Agri-food
       Ms. Val Merideth, M.P., Canadian Alliance Party Sr. Health Critic
       Mr. James Lunney, M.P., Health Critic
       Mr. Reed Elley, M.P.
       Ms. Judy Wasylycia-Leis, M.P., New Democratic Party Health Critic
       Mr. André Bachand, M.P., Progressive Conservative Party Health Critic
       M. Réal Ménard, député, porte-parole de Bloc Québécois en matière de Santé
       Mr. Tom Wappel, M.P.
       Mr. Svend Robinson, M.P.
       Mr. Mel Cappe, Clerk of the Privy Counsel and Secretary to the Cabinet
       Mr. Ian C. Green, Deputy Minister of Health
       Mr. Mr. Samy Watson, Deputy Minister of Agriculture and Agri-food Canada
       Mr. Ronald L. Doering, President, Canadian Food Inspection Agency
       Ms. Eunice Chao, Project Coordinator, Health Canada
       Ms. Melodie Wynne, Health Canada
       Ms. Christina Zehaluk, Health Canada
       Dr. Margaret Cheney, Health Canada
       Ms. Mary Bush, Health Canada
       Dr. Kevin Keough, Chief Scientist, Health Canada
                                             s
I endorse the Alliance for Food Label Reform’ September 14, 2001 submission to Mr. Ronald
Burke at Health Canada regarding Nutrition Labelling, Nutrition Claims, and Health Claims (Ref.
Canada Gazette, Part I, published June 16, 2001).



_______________________________
Bill Jeffery, L.LB.
Centre for Science in the Public Interest
                                             -8-

                                             s
I endorse the Alliance for Food Label Reform’ September 14, 2001 submission to Mr. Ronald
Burke at Health Canada regarding Nutrition Labelling, Nutrition Claims, and Health Claims (Ref.
Canada Gazette, Part I, published June 16, 2001).



_______________________________
Nathalie St. Pierre
Action Réseau Consommateur
                                             -9-


                                             s
I endorse the Alliance for Food Label Reform’ September 14, 2001 submission to Mr. Ronald
Burke at Health Canada regarding Nutrition Labelling, Nutrition Claims, and Health Claims (Ref.
Canada Gazette, Part I, published June 16, 2001).



_______________________________
Claude Renaud, BSc, MD, CCFP, FCFP
College of Family Physicians of Canada
                                             - 10 -

                                             s
I endorse the Alliance for Food Label Reform’ September 14, 2001 submission to Mr. Ronald
Burke at Health Canada regarding Nutrition Labelling, Nutrition Claims, and Health Claims (Ref.
Canada Gazette, Part I, published June 16, 2001).



_______________________________
Curtis DeCoste
National Pensioners & Senior Citizens Federation
                                             - 11 -

                                             s
I endorse the Alliance for Food Label Reform’ September 14, 2001 submission to Mr. Ronald
Burke at Health Canada regarding Nutrition Labelling, Nutrition Claims, and Health Claims (Ref.
Canada Gazette, Part I, published June 16, 2001).




_______________________________
Trinkie Coffin
Canadian Home Economics Association
                                              - 12 -

                                             s
I endorse the Alliance for Food Label Reform’ September 14, 2001 submission to Mr. Ronald
Burke at Health Canada regarding Nutrition Labelling, Nutrition Claims, and Health Claims (Ref.
Canada Gazette, Part I, published June 16, 2001).




_______________________________
Elizabeth MacNamara, MD, FRCP(C)
Canadian Association of Medical Biochemists
                                             - 13 -

                                             s
I endorse the Alliance for Food Label Reform’ September 14, 2001 submission to Mr. Ronald
Burke at Health Canada regarding Nutrition Labelling, Nutrition Claims, and Health Claims (Ref.
Canada Gazette, Part I, published June 16, 2001).




_______________________________
Gerry Philippe
Canadian Federation of Chefs and Cooks
                                              - 14 -

                                             s
I endorse the Alliance for Food Label Reform’ September 14, 2001 submission to Mr. Ronald
Burke at Health Canada regarding Nutrition Labelling, Nutrition Claims, and Health Claims (Ref.
Canada Gazette, Part I, published June 16, 2001).




_______________________________
Carolyn Froats Emond, RD
Ont. Society of Nutrition Professionals in Public Health
                                             - 15 -

                                             s
I endorse the Alliance for Food Label Reform’ September 14, 2001 submission to Mr. Ronald
Burke at Health Canada regarding Nutrition Labelling, Nutrition Claims, and Health Claims (Ref.
Canada Gazette, Part I, published June 16, 2001).



_______________________________
Debbie Field
FoodShare Toronto
                                             - 16 -

                                             s
I endorse the Alliance for Food Label Reform’ September 14, 2001 submission to Mr. Ronald
Burke at Health Canada regarding Nutrition Labelling, Nutrition Claims, and Health Claims (Ref.
Canada Gazette, Part I, published June 16, 2001).



_______________________________
Maude Barlow
Council of Canadians
                                             - 17 -

                                             s
I endorse the Alliance for Food Label Reform’ September 14, 2001 submission to Mr. Ronald
Burke at Health Canada regarding Nutrition Labelling, Nutrition Claims, and Health Claims (Ref.
Canada Gazette, Part I, published June 16, 2001).



_______________________________
Wayne Roberts, Ph.D.
Toronto Food Policy Council
                                             - 18 -

                                             s
I endorse the Alliance for Food Label Reform’ September 14, 2001 submission to Mr. Ronald
Burke at Health Canada regarding Nutrition Labelling, Nutrition Claims, and Health Claims (Ref.
Canada Gazette, Part I, published June 16, 2001).



______________________________
Laurie Beachell
Council of Canadians with Disabilities
                                             - 19 -

                                             s
I endorse the Alliance for Food Label Reform’ September 14, 2001 submission to Mr. Ronald
Burke at Health Canada regarding Nutrition Labelling, Nutrition Claims, and Health Claims (Ref.
Canada Gazette, Part I, published June 16, 2001).



________________________________
Libby A. Gardon
Consumer Health Organization of Canada
                                             - 20 -

                                             s
I endorse the Alliance for Food Label Reform’ September 14, 2001 submission to Mr. Ronald
Burke at Health Canada regarding Nutrition Labelling, Nutrition Claims, and Health Claims (Ref.
Canada Gazette, Part I, published June 16, 2001).



______________________________
Robin Moore-Orr, D.Sc., R.D.
Canadian Institute of Child Health
                                             - 21 -

                                             s
I endorse the Alliance for Food Label Reform’ September 14, 2001 submission to Mr. Ronald
Burke at Health Canada regarding Nutrition Labelling, Nutrition Claims, and Health Claims (Ref.
Canada Gazette, Part I, published June 16, 2001).



________________________________
Michael Brennan
Canadian Dental Assistants' Association
                                             - 22 -

                                             s
I endorse the Alliance for Food Label Reform’ September 14, 2001 submission to Mr. Ronald
Burke at Health Canada regarding Nutrition Labelling, Nutrition Claims, and Health Claims (Ref.
Canada Gazette, Part I, published June 16, 2001).



________________________________
Leonard Harrison, President
National Retired Workers Advisory Council
                                             - 23 -

                                             s
I endorse the Alliance for Food Label Reform’ September 14, 2001 submission to Mr. Ronald
Burke at Health Canada regarding Nutrition Labelling, Nutrition Claims, and Health Claims (Ref.
Canada Gazette, Part I, published June 16, 2001).




________________________________
Nadine Henningsen
Canadian Home Care Association

								
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