Modification to buffer zone between the front-of-package nutrition symbol and the supplemented food caution identifier, and between nutrition symbols
Notice of modification – Directory of Nutrition Symbol Specifications, Directory of Supplemented Food Caution Identifier Specifications
Reference number: M-CIS-24-01
July 17, 2024
Background
Amendments to the Food and Drug Regulations (FDR), effective July 20, 2022, require the display of a front-of-package (FOP) nutrition symbol on prepackaged products high in saturated fat, sugars, and/or sodium. Similarly, as of July 21, 2022, supplemented foods requiring cautionary statements must display a supplemented food caution identifier (SFCI). Some supplemented foods may be required to carry both symbols on their principal display panel. Additionally, prepackaged products that contain an assortment of foods may be required to carry more than one FOP nutrition symbol and/or the SFCI.
The SFCI is required to help consumers make informed choices when there are health or safety risks associated with a food. The FOP nutrition symbol is intended to complement the Nutrition Facts table and help consumers more easily identify foods high in saturated fat, sugars and sodium to make healthier and more informed decisions. Health Canada's Food and Nutrition Directorate designed both symbols to help ensure legibility for consumers while limiting the space occupied on labels. To ensure the FOP nutrition symbol and the SFCI are distinct from the background, they each require a minimum buffer zone in accordance with the specifications of the Directory of Nutrition Symbol Specifications and the Directory of Supplemented Food Caution Identifier Specifications, respectively. Additionally, the buffer zone cannot contain any text or other graphic material.
Issue
Through consultations and discussions, including those during the Canada Gazette, Part I process for the regulations for supplemented foods, Health Canada received feedback from industry organizations and manufacturers. This feedback noted that displaying both the FOP nutrition symbol and the SFCI used up a significant portion of the principal display panel.
Rationale for action
The Directorate considered industry comments on the impact on available label space when both an FOP nutrition symbol and the SFCI are required on supplemented foods. The Directorate concluded that the Directory of Nutrition Symbol Specifications and the Directory of Supplemented Food Caution Identifier Specifications should be modified to permit displaying the FOP nutrition symbol and the SFCI with no buffer between them where they share a border (that is, where they are contiguous). Additionally, the same flexibility should be available for prepackaged products that contain an assortment of foods, where more than one FOP nutrition symbol is required.
The removal of the buffer zone for contiguous symbols allows flexibility in terms of space required to display them, while still maintaining their integrity and distinctiveness. This is achieved through modifications to the corresponding directories.
When food products require more than one FOP nutrition symbol or require both an FOP nutrition symbol and the SFCI, regulated parties are now permitted to display the symbols with no buffer between them where they share a border. This is achieved by including a footnote to column 4 of the tables in each directory (as indicated in the revised table entries located further down for both directories) indicating that a buffer as small as 0 mm is permitted between the FOP nutrition symbol and the SFCI, and between nutrition symbols, where they share a border.
The minimum buffer continues to apply to the remaining borders of each symbol as indicated in their respective directories, as does the requirement for prepackaged products that contain an assortment of foods to display the FOP nutrition symbols in a manner that clearly indicates the applicable nutrients that are contained in each food (B.01.353(1), FDR).
The minimum buffer zone also continues to apply to all four borders of the FOP nutrition symbol or the SFCI when a single FOP nutrition symbol or SFCI is displayed on the principal display panel. Regulated parties still have the flexibility to place the symbols in any order, provided they continue to meet their respective placement requirements.
Consultation
Modifications were required to the Directory of Nutrition Symbol Specifications and the Directory of Supplemented Food Caution Identifier Specifications to change buffer zone specifications. On September 25, 2023, Health Canada published a Notice of Proposal (NOP) regarding the buffer zones between the FOP nutrition symbol and the SFCI, and between nutrition symbols, which was open for public comment for 75 days. Ten comments were received from individuals, industry representatives and associations, and a political organization during the consultation period which ended December 8, 2023. These comments are summarized below with Health Canada's responses.
The Food and Nutrition Directorate has included the following footnote to column 4 of the tables for both directories: The minimum buffer zone between a nutrition symbol and a supplemented food caution identifier, or between nutrition symbols, that are labelled contiguous can be 0 mm.
This revision to include the same footnote in both directories ensures consistency and reflects the flexibility that could apply to an assortment of supplemented foods that don't require the SFCI but require more than one FOP nutrition symbol. This modification to the footnote does not modify the SFCI or nutrition symbol specifications or alter the directories beyond what was proposed in the NOP.
Comments on reduced buffer zone
Stakeholder comments: The feedback from industry and individuals largely supports the proposed changes to the buffer zone, although some stakeholders also raised specific concerns. One stakeholder inquired how the modifications would change the presentation of the SFCI as well as expressing concern regarding the visibility of the symbols.
Health Canada's response: The modifications specifically apply to the shared border between a SFCI and FOP nutrition symbol and between nutrition symbols. The minimum buffer specifications would continue to apply to the remaining borders of each symbol as indicated in their respective directories. The modification, therefore, allows some flexibility in terms of space required to display the symbols, but still maintains their integrity and distinctiveness so they are clearly visible to consumers.
Outcome: Proposal maintained.
Comments on label designs
Stakeholder comment: One industry stakeholder supported the adjustment to the buffer zone but expressed their preference for an alternative approach. They would favour a streamlined graphic combining both the FOP nutrition symbol and SFCI to convey a cohesive message. Additionally, they requested the removal of one "Health Canada/Santé Canada" attribution when both the FOP nutrition symbol and SFCI are required on a label.
Health Canada's response: The request to remove a "Health Canada/Santé Canada" attribution is outside the scope of the consultation. Additionally, the suggestion to create a new symbol combining both the FOP nutrition symbol and the SFCI was not part of the scope of the original proposal. Any changes to the design of the symbols would need to be supported by research and undergo public consultation.
Outcome: Proposal maintained.
Comments on implementation and enforcement
Stakeholder comment: One industry association noted that the proposal provided industry with flexibilities in complying with the regulations for supplemented foods and the FOP labelling regulations, specifically helping to address some concerns related to label space. However, they expressed concern with the timing of the proposal, indicating that it comes at a time when design work related to making changes associated with the above-mentioned regulations has started.
The stakeholder indicated that the lack of clarity regarding when the proposed changes will be published could compromise their members' ability to make label changes by the compliance date of January 1, 2026. In addition, they noted that if members choose to update labels using the original buffer zone requirements, it means that manufacturers will have to make an additional label change, resulting in extra costs. The stakeholder requested both the timely finalization of the proposal and flexibility to the January 1, 2026, compliance date through enforcement discretion.
Health Canada's response: The modification made to both directories does not introduce a new requirement regarding either the FOP nutrition symbol or the SFCI presentation. It provides additional flexibility to permit a buffer as small as 0 mm between the FOP nutrition symbol and the SFCI, or between nutrition symbols on prepackaged products that contain an assortment of foods, where they share a border.
Additionally, this modification is permissive. As such, regulated parties can choose whether to comply with the new 0 mm buffer zone specifications or the original specifications in the FDR. Businesses therefore have the flexibility of retaining labels where the original buffer requirements were already applied, using up stocks of those labels and implementing a 0 mm buffer zone where permitted as part of future label redesigns, or redesigning labels to implement a 0 mm buffer immediately.
Outcome: Proposal maintained.
General comments
Stakeholder comments: Feedback included suggestions for implementing a glossary of terms for supplements and ingredients and inquiries into both the importation and labelling practices for imported foods, and discussions on the process for the identifying terminology to be used for ingredients and their labelling.
Health Canada's response: While Health Canada acknowledges the importance of these topics, they are outside the scope of the consultation as they do not pertain to either the buffer zone, nutrition symbols and/or the SFCI. Consequently, these are not elaborated on further in this Notice of modification.
Outcome: Proposal maintained.
Modification to the Directory of Supplemented Food Caution Identifier Specifications
| Item | Column 1 Range of principal display surface |
Column 2 Supplemented food caution identifier in Schedule K.2 of the Food and Drug Regulations |
Column 3 Supplemented food caution identifier dimensions (width x height) |
Column 4 Minimum buffer surrounding the supplemented food caution identifierFootnote a |
Column 5 Height of upper case letters or tallest ascender of lower case letters (except for the words Health Canada / Santé Canada) |
Column 6 Height of upper case letters or tallest ascender of lower case letters for the words Health Canada / Santé Canada |
Column 7 "x" height of letters (except for the words Health Canada / Santé Canada) |
Column 8 "x" height of letters for the words Health Canada / Santé Canada |
Column 9 Height of the black bar |
Column 10 Height of the exclamation mark |
| 1 | > 600 cm² | 1(ES) and 1(FS) | 4.42 cm x 1.61 cm | 3.0 mm | 4.2 mm | 3.8 mm | 3.0 mm | 2.6 mm | 7.6 mm | 12.7 mm |
| 2 | > 450 cm² to ≤ 600 cm² | 2(ES) and 2(FS) | 3.79 cm x 1.38 cm | 2.7 mm | 3.7 mm | 3.1 mm | 2.7 mm | 2.3 mm | 6.5 mm | 10.9 mm |
| 3 | > 250 cm² to ≤ 450 cm² | 3(ES) and 3(FS) | 3.10 cm x 1.13 cm | 2.2 mm | 3.0 mm | 2.5 mm | 2.2 mm | 1.8 mm | 5.4 mm | 8.9 mm |
| 4 | > 100 cm² to ≤ 250 cm² | 4(ES) and 4(FS) | 2.50 cm x 0.92 cm | 1.7 mm | 2.4 mm | 2.0 mm | 1.7 mm | 1.4 mm | 4.3 mm | 7.2 mm |
| 5 | > 30 cm² to ≤ 100 cm² | 5(ES) and 5(FS) | 1.87 cm x 0.69 cm | 1.3 mm | 1.8 mm | 1.6 mm | 1.3 mm | 1.1 mm | 3.2 mm | 5.4 mm |
| 6 | ≤ 30 cm² | 6(ES) and 6(FS) | 1.65 cm x 0.65 cm | 1.1 mm | 1.6 mm | 1.6 mm | 1.1 mm | 1.1 mm | 3.0 mm | 5.1 mm |
ES: English standard
| ||||||||||
| Item | Column 1 Range of principal display surface |
Column 2 Supplemented food caution identifier in Schedule K.2 of the Food and Drug Regulations |
Column 3 Supplemented food caution identifier dimensions (width x height) |
Column 4 Minimum buffer surrounding the supplemented food caution identifierFootnote a |
Column 5 Height of upper case letters or tallest ascender of lower case letters (except for the words Health Canada / Santé Canada) |
Column 6 Height of upper case letters or tallest ascender of lower case letters for the words Health Canada / Santé Canada |
Column 7 "x" height of letters (except for the words Health Canada / Santé Canada) |
Column 8 "x" height of letters for the words Health Canada / Santé Canada |
Column 9 Height of the black bar |
Column 10 Height of the exclamation mark |
| 1 | > 600 cm² | 1(BS) | 6.29 cm x 1.28 cm | 2.5 mm | 3.4 mm | 3.2 mm | 2.5 mm | 2.3 mm | 6.1 mm | 10.1 mm |
| 2 | > 450 cm² to ≤ 600 cm² | 2(BS) | 5.40 cm x 1.10 cm | 2.1 mm | 2.9 mm | 2.7 mm | 2.1 mm | 1.9 mm | 5.2 mm | 8.7 mm |
| 3 | > 250 cm² to ≤ 450 cm² | 3(BS) | 4.50 cm x 0.93 cm | 1.7 mm | 2.4 mm | 2.2 mm | 1.7 mm | 1.5 mm | 4.4 mm | 7.2 mm |
| 4 | > 100 cm² to ≤ 250 cm² | 4(BS) | 3.60 cm x 0.76 cm | 1.4 mm | 1.9 mm | 1.9 mm | 1.4 mm | 1.3 mm | 3.5 mm | 5.9 mm |
| 5 | ≤ 100 cm² | 5(BS) | 2.97 cm x 0.63 cm | 1.1 mm | 1.6 mm | 1.6 mm | 1.1 mm | 1.1 mm | 2.9 mm | 4.9 mm |
BS: Bilingual standard
| ||||||||||
| Item | Column 1 Range of principal display surface |
Column 2 Supplemented food caution identifier in Schedule K.2 of the Food and Drug Regulations |
Column 3 Supplemented food caution identifier dimensions (width x height) |
Column 4 Minimum buffer surrounding the supplemented food caution identifierFootnote a |
Column 5 Height of upper case letters or tallest ascender of lower case letters (except for the words Health Canada / Santé Canada) |
Column 6 Height of upper case letters or tallest ascender of lower case letters for the words Health Canada / Santé Canada |
Column 7 "x" height of letters (except for the words Health Canada / Santé Canada) |
Column 8 "x" height of letters for the words Health Canada / Santé Canada |
Column 9 Height of the black bar |
Column 10 Height of the exclamation mark |
| 3 | > 250 cm² to ≤ 450 cm² | 1(BC) | 2.17 cm x 1.40 cm | 1.5 mm | 2.0 mm | 1.9 mm | 1.5 mm | 1.4 mm | 6.9 mm | 6.9 mm |
| 4 | > 100 cm² to ≤ 250 cm² | 2(BC) | 1.75 cm x 1.14 cm | 1.2 mm | 1.6 mm | 1.6 mm | 1.2 mm | 1.1 mm | 5.6 mm | 5.6 mm |
| 5 | ≤ 100 cm² | 3(BC) | 1.66 cm x 1.09 cm | 1.1 mm | 1.6 mm | 1.6 mm | 1.1 mm | 1.1 mm | 5.3 mm | 5.3 mm |
BC: Bilingual compact
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Modification to the Directory of Nutrition Symbol Specifications
| Item | Column 1 Range of principal display surface |
Column 2 Nutrition symbol in Schedule K.1 of the Food and Drug Regulations |
Column 3 Nutrition symbol dimensions (width x height) |
Column 4 Minimum buffer surrounding the nutrition symbolFootnote a |
Column 5 Height of upper case letters or tallest ascender of lower case letters (except for the words Health Canada / Santé Canada) |
Column 6 Height of upper case letters or tallest ascender of lower case letters for the words Health Canada / Santé Canada |
Column 7 "x" height of letters (except for the words Health Canada / Santé Canada) |
Column 8 "x" height of letters for the words Health Canada / Santé Canada |
Column 9 Height of the black / white bars |
Column 10 Diameter of the lens of the magnifying glass |
| 1 | > 600 cm2 | 1(EH) and 1(FH) |
4.42 cm x 3.30 cm | 2.7 mm | 3.5 mm | 3.0 mm | 2.7 mm | 2.3 mm | 6.2 mm | 17.3 mm |
| 2 | > 450 cm2 to ≤ 600 cm2 | 1(EH) and 1(FH) |
3.79 cm x 2.83 cm | 2.3 mm | 3.0 mm | 2.5 mm | 2.3 mm | 1.9 mm | 5.3 mm | 14.8 mm |
| 3 | > 250 cm2 to ≤ 450 cm2 | 1(EH) and 1(FH) |
3.10 cm x 2.36 cm | 1.9 mm | 2.5 mm | 2.0 mm | 1.9 mm | 1.5 mm | 4.3 mm | 12.1 mm |
| 4 | > 100 cm2 to ≤ 250 cm2 | 1(EH) and 1(FH) |
2.50 cm x 1.89 cm | 1.5 mm | 2.0 mm | 1.8 mm | 1.5 mm | 1.3 mm | 3.5 mm | 9.8 mm |
| 5 | > 30 cm2 to ≤ 100 cm2 | 1(EH) and 1(FH) |
1.87 cm x 1.42 cm | 1.1 mm | 1.5 mm | 1.5 mm | 1.1 mm | 1.1 mm | 2.6 mm | 7.3 mm |
6 |
≤ 30 cm2 |
1(EH) and 1(FH) | 1.87 cm x 1.42 cm | 1.1 mm | 1.5 mm | 1.5 mm | 1.1 mm | 1.1 mm | 2.6 mm | 7.3 mm |
8(EH) and 8(FH) |
1.37 cm x 1.20 cm | 1.1 mm | 1.5 mm | 1.5 mm | 1.1 mm | 1.1 mm | 2.6 mm | 2.9 mm | ||
11(EH) and 11(FH) |
1.37 cm x 0.85 cm | 1.1 mm | 1.5 mm | 1.5 mm | 1.1 mm | 1.1 mm | 2.6 mm | 2.9 mm | ||
EH: English horizontal
|
||||||||||
| Item | Column 1 Range of principal display surface |
Column 2 Nutrition symbol in Schedule K.1 of the Food and Drug Regulations |
Column 3 Nutrition symbol dimensions (width x height) |
Column 4 Minimum buffer surrounding the nutrition symbolFootnote a |
Column 5 Height of upper case letters or tallest ascender of lower case letters (except for the words Health Canada / Santé Canada) |
Column 6 Height of upper case letters or tallest ascender of lower case letters for the words Health Canada / Santé Canada |
Column 7 "x" height of letters (except for the words Health Canada / Santé Canada) |
Column 8 "x" height of letters for the words Health Canada / Santé Canada |
Column 9 Height of the black / white bars |
Column 10 Diameter of the lens of the magnifying glass |
| 3 | > 250 cm2 to ≤ 450 cm2 | 1(EV) and 1(FV) |
2.17 cm x 2.75 cm | 1.9 mm | 2.5 mm | 2.0 mm | 1.9 mm | 1.5 mm | 4.4 mm | 6.2 mm |
| 4 | > 100 cm2 to ≤ 250 cm2 | 1(EV) and 1(FV) |
1.75 cm x 2.19 cm | 1.5 mm | 2.0 mm | 1.8 mm | 1.5 mm | 1.3 mm | 3.5 mm | 5.0 mm |
| 5 | > 30 cm2 to ≤ 100 cm2 | 1(EV) and 1(FV) |
1.37 cm x 1.80 cm | 1.1 mm | 1.5 mm | 1.5 mm | 1.1 mm | 1.1 mm | 2.9 mm | 3.9 mm |
6 |
≤ 30 cm2 |
1(EV) and 1(FV) | 1.37 cm x 1.80 cm | 1.1 mm | 1.5 mm | 1.5 mm | 1.1 mm | 1.1 mm | 2.9 mm | 3.9 mm |
8(EV) and 8(FV) |
1.37 cm x 1.40 cm | 1.1 mm | 1.5 mm | 1.5 mm | 1.1 mm | 1.1 mm | 2.9 mm | 3.3 mm | ||
11(EV) and 11(FV) |
1.37 cm x 0.85 cm | 1.1 mm | 1.5 mm | 1.5 mm | 1.1 mm | 1.1 mm | 2.9 mm | 2.9 mm | ||
EV: English vertical
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| Item | Column 1 Range of principal display surface |
Column 2 Nutrition symbol in Schedule K.1 of the Food and Drug Regulations |
Column 3 Nutrition symbol dimensions (width x height) |
Column 4 Minimum buffer surrounding the nutrition symbolFootnote a |
Column 5 Height of upper case letters or tallest ascender of lower case letters (except for the words Health Canada / Santé Canada) |
Column 6 Height of upper case letters or tallest ascender of lower case letters for the words Health Canada / Santé Canada |
Column 7 "x" height of letters (except for the words Health Canada / Santé Canada) |
Column 8 "x" height of letters for the words Health Canada / Santé Canada |
Column 9 Height of the black / white bars |
Column 10 Diameter of the lens of the magnifying glass |
| 1 | > 600 cm2 | 1(BH) |
6.29 cm x 3.30 cm | 2.7 mm | 3.5 mm | 3.0 mm | 2.7 mm | 2.3 mm | 6.2 mm | 17.3 mm |
| 2 | > 450 cm2 to ≤ 600 cm2 | 1(BH) |
5.40 cm x 2.83 cm | 2.3 mm | 3.0 mm | 2.5 mm | 2.3 mm | 1.9 mm | 5.3 mm | 14.8 mm |
| 3 | > 250 cm2 to ≤ 450 cm2 | 1(BH) |
4.50 cm x 2.36 cm | 1.9 mm | 2.5 mm | 2.0 mm | 1.9 mm | 1.5 mm | 4.3 mm | 12.4 mm |
| 4 | > 100 cm2 to ≤ 250 cm2 | 1(BH) |
3.60 cm x 1.89 cm | 1.5 mm | 2.0 mm | 1.8 mm | 1.5 mm | 1.3 mm | 3.5 mm | 9.9 mm |
| 5 | > 30 cm2 to ≤ 100 cm2 | 1(BH) |
2.80 cm x 1.42 cm | 1.1 mm | 1.5 mm | 1.5 mm | 1.1 mm | 1.1 mm | 2.6 mm | 7.4 mm |
6 |
≤ 30 cm2 |
1(BH) | 2.80 cm x 1.42 cm | 1.1 mm | 1.5 mm | 1.5 mm | 1.1 mm | 1.1 mm | 2.6 mm | 7.4 mm |
8(BH) |
2.50 cm x 1.20 cm | 1.1 mm | 1.5 mm | 1.5 mm | 1.1 mm | 1.1 mm | 2.6 mm | 4.2 mm | ||
11(BH) |
2.50 cm x 0.85 cm | 1.1 mm | 1.5 mm | 1.5 mm | 1.1 mm | 1.1 mm | 2.6 mm | 3.9 mm | ||
BH: Bilingual horizontal
|
||||||||||
| Item | Column 1 Range of principal display surface |
Column 2 Nutrition symbol in Schedule K.1 of the Food and Drug Regulations |
Column 3 Nutrition symbol dimensions (width x height) |
Column 4 Minimum buffer surrounding the nutrition symbolFootnote a |
Column 5 Height of upper case letters or tallest ascender of lower case letters (except for the words Health Canada / Santé Canada) |
Column 6 Height of upper case letters or tallest ascender of lower case letters for the words Health Canada / Santé Canada |
Column 7 "x" height of letters (except for the words Health Canada / Santé Canada) |
Column 8 "x" height of letters for the words Health Canada / Santé Canada |
Column 9 Height of the black / white bars |
Column 10 Diameter of the lens of the magnifying glass |
| 3 | > 250 cm2 to ≤ 450 cm2 | 1(BV) |
2.17 cm x 4.10 cm | 1.9 mm | 2.5 mm | 2.0 mm | 1.9 mm | 1.5 mm | 7.8 mm | 6.2 mm |
| 4 | > 100 cm2 to ≤ 250 cm2 | 1(BV) |
1.75 cm x 3.31 cm | 1.5 mm | 2.0 mm | 1.8 mm | 1.5 mm | 1.3 mm | 6.3 mm | 5.0 mm |
| 5 | > 30 cm2 to ≤ 100 cm2 | 1(BV) |
1.37 cm x 2.60 cm | 1.1 mm | 1.5 mm | 1.5 mm | 1.1 mm | 1.1 mm | 4.9 mm | 3.9 mm |
6 |
≤ 30 cm2 |
1(BV) | 1.37 cm x 2.60 cm | 1.1 mm | 1.5 mm | 1.5 mm | 1.1 mm | 1.1 mm | 4.9 mm | 3.9 mm |
8(BV) |
1.37 cm x 2.05 cm | 1.1 mm | 1.5 mm | 1.5 mm | 1.1 mm | 1.1 mm | 4.9 mm | 3.3 mm | ||
11(BV) |
1.37 cm x 1.50 cm | 1.1 mm | 1.5 mm | 1.5 mm | 1.1 mm | 1.1 mm | 4.9 mm | 3.3 mm | ||
BV: Bilingual vertical
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Other relevant information
The sale of all foods is subject to Sections 3 to 7 of the Food and Drugs Act (FDA) and must comply with the requirements set out in any applicable divisions under Part B and D of the FDR and marketing authorizations such as those respecting the use of food additives. Manufacturers and distributors of food products are responsible for the safety of their products, and for ensuring that their products are compliant with applicable legislation and regulation, including the Safe Food for Canadians Act and Safe Food for Canadians Regulations.
Implementation and enforcement
The above modification came into force July 15, 2024, the day it was published in the Directory of Nutrition Symbol Specifications and the Directory of Supplemented Food Caution Identifier Specifications.
The Canadian Food Inspection Agency is responsible for the enforcement of the FDA and its associated regulations with respect to foods.
Contact information
Health Canada's Food and Nutrition Directorate is committed to reviewing any new information relating to this Notice. Anyone wishing to submit an inquiry or new information may do so by regular mail or email. If you wish to contact the Directorate by email, please use the words "FOP-SFCI Buffer zone (M-CIS-24-01)" in the subject line of your email.
Supplemented Foods
Bureau of Nutritional Sciences
Food and Nutrition Directorate
251 Sir Frederick Banting Driveway
Tunney's Pasture
Address locator 2203E
Ottawa ON K1A 0K9
Email: supplementedfoods-alimentssupplementes@hc-sc.gc.ca
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