On June 13, 2015, Health Canada’s (HC’s) Proposed Regulations governing changes to Nutrition and Food Labelling were published in Canada Gazette I. The Ontario Home Economics Association (OHEA) chose to respond by forming a committee of eight Professional Home Economists with diverse backgrounds, areas and levels of expertise. All members brought exceptional professional insight to the table through individual review, research into published studies, pooling of pertinent information and group discussion. This culminated in a carefully constructed response to HC.
The following recommendations were made on behalf of OHEA:
Proposed Revisions to Reference Amounts in the Food and Drug Regulations, and Mandatory Application of said Reference Amounts as Standardized Serving Sizes in the Nutrition Facts Table
OHEA accepted the standardization of amount of food declared in the Nutrition Facts table (NFt) but rejected the use of consumption data to determine the Reference Amounts (RA) of food, which, as proposed in this regulatory amendment, would mandate serving size. The primary reason for the opposition was the documented association between portion distortion and either overweightness or obesity. Accordingly, the following recommendations were made:
- Use Canada’s Food Guide (CFG) to determine RA’s, citing that CFG is based on the scientifically determined needs of the general population and is the cornerstone of nutrition education;
- Include a footnote stating, "the Reference Amount in the NFt does not reflect a healthy recommended serving size" if the "super-sized" RA’s are adopted;
- Failing the above, use a standardized measure of 100 g or 100 mL as appropriate in the NFt instead of a serving size.
Proposed Revisions to Core Nutrients in the Nutrition Facts Table, to % Daily Values declared in the Nutrition Facts Table, and, to formatting the Nutrition Facts Table
OHEA accepted declaration of the serving size in both household and metric measure; mandatory inclusion of potassium; removal of mandatory inclusion of vitamin A and C; withdrawal of mandatory % DV for vitamin D as proposed in the 2014 consultation; addition of % Daily Value (DV) for total sugars; removal of "Amount/Tenure"; inclusion of a 5% DV/15% DV footer explanation; larger font for calories; a truncated bold line under calories; and further formatting using bold lines. Rejections of the quantification of micronutrients other than sodium and the removal of % DV for carbohydrate and dietary fibre were voiced, with the following recommendations:
- Remove the requirement of quantification of micronutrients due to the cost of precise measurement, the principle of natural variation, the practicality of testing every batch and therefore, the cost that will be passed onto consumers;
- Retain the % DV for carbohydrate as the insight into various nutritional roles of differing carbohydrates is growing;
- Retain the % DV for fibre at a Reference Standard of 25 g or increase to 28 g, as this is a shortfall nutrient; removal of the % DV diminishes perceived importance of the nutrient;
- If the Reference Standard for dietary fibre remains at 25 g, slightly decrease the threshold for the claim of "high source of fibre" to 3.75 g per stated serving size to align with the footer statement that 15% equates to "a lot";
- Retain the current position of cholesterol with fats or eliminate it as a core nutrient, as the usefulness of this declaration is questionable;
- Bold the serving size to match the bolding and font size of calories.
Proposed Revisions to the Recommended Daily Intakes of Core Nutrition Facts Table Nutrients and Proposed Revisions to the Nutrition Facts Table Formatting
OHEA accepted alignment of the % DV’s with the U.S. Institute of Medicine recommendations, and a separate NFt for each of children under 12 months, and children aged one to four years. Also accepted was the proposed % DV of total sugars in the NFt. The committee recommended retention of the current Recommended Daily Intake and % DV for fat at 65 g, noting Statistics Canada’s finding that the rising rates of obesity are in part contributed to fat intake raising average caloric intake.
Proposed Regulations to Standardize the Formatting of the List of Ingredients
OHEA accepted the proposals of standardized formatting; contrast of font and background in the List of Ingredients (LOI); mandatory listing of food colours by name; mandatory listing of food allergens in the Contains statement; and grouping of sugar-based ingredients together in the LOI. Recommendations to improve the LOI included:
- Eliminate the "Ingredients" header so as to gain back some packaging space lost by the new formatting;
- Group the fat-based ingredients together as proposed for sugars due to the fact that gram for gram, fat is the largest contributor of calories, and, to aid consumers in identifying which ingredients are fat.
Proposed Health Claim
OHEA supported the health claim, "A healthy diet rich in a variety of vegetables and fruit may help reduce the risk of heart disease.", accepting the scientific evidence cited by HC.
OHEA, as professionals who assist families and individuals to achieve and maintain a desirable quality of life believe that "Knowing the nutritional status of a country provides direction on the priorities and programs that will update the overall health of a nation." (Starkey, Johnson-Down, Gray-Donald, 2001), thus OHEA encourages Health Canada to seize this opportunity to improve the health of all Canadians.