Health Canada’s notice of modification to update the incorporated by reference document entitled nutrition labelling – Table of reference amounts for food

Reference Number: NOM/ADM-QRA-2022-1
November 24, 2022

On this page

• Summary
  • Rationale for revising the Table of Reference Amounts for Food
  • Changes to the Table of Reference Amounts for Food
  • Nutrition labelling considerations
  • Stakeholder consultation
• Summary of comments received
  • Process
  • Reference amounts
  • Food examples
  • Serving size instructions
  • Editorial
  • Units of measure
  • Compliance date/end of transition
• Compliance and enforcement
• Contact Information

Summary

The purpose of this notice is to inform consumers and interested stakeholders that Health Canada has amended the Nutrition Labelling - Table of Reference Amounts for Food on November 24, 2022. Manufacturers will have until January 1, 2026 to comply with the updated Table. The notice provides the appropriate contact information for any inquiries or for those wishing to submit any new information.

The Table of Reference Amounts for Food (TRA) sets out reference amounts (RAs) for different food categories, which:

• represent the amount of food typically consumed in one eating occasion;
• are used to determine what is considered to be a single-serving prepackaged product;
• serve as the basis for determining the serving size to be declared in the Nutrition Facts table (NFt) of multiple-serving prepackaged products;
• serve as part of the criteria for making nutrient content claims and health claims; and
• factor into the requirements for the new front-of-package nutrition symbol.

The TRA also provides detailed instructions on how to determine and declare the serving size for each food.

The TRA was incorporated by reference in the Food and Drug Regulations (FDR) on December 14, 2016 (SOR/2016-305) in order to allow for timely and efficient updates in response to new scientific data. Previously, RAs for some foods were prescribed in Schedule M of the FDR.

Rationale for revising the Table of Reference Amounts for Food

Health Canada is taking the opportunity to update the TRA using food consumption data from the most recent (2015) Canadian Community Health Survey (CCHS).

Based on stakeholder feedback, which identified gaps in the TRA and areas requiring further clarity, Health Canada has:

• Added new RA categories and product examples to existing food categories. For example, a RA is added for freeze-dried fruit; phyllo and puff pastry sheets have been added to the pie crust product category and glazes have been added to the dessert toppings product category.
• Provided additional instructions for the serving of stated size declaration for food formats that were overlooked in the 2016 revision. For example, for lasagna noodles, an additional option for serving of stated size declaration has been added based on the number of unit(s) and for grains, such as rice or barley, an additional option for serving of stated size declaration has been added based on fraction of the package.
• Added a serving of stated size declaration based on instructions for the amount to make the RA of the food, for foods sold in a format requiring further preparation, such as cake mix.

Changes to the Table of Reference Amounts for Food

The changes consist of:

• Changing 3 RAs (Column 2)
  • Dairy Products and Substitutes - D.12.1, D.15
  • Legumes - K.3
• Adding 16 new items with product category descriptions (Column 1), RAs (Column 2) and corresponding serving size instructions (Column 3A and B)
  • Bakery Products and Substitutes - A.26
  • Beverages - B.2 d) and e)
  • Dairy Products and Substitutes - D.1.1
  • Desserts - E.6
  • Eggs and Egg Substitutes - G.4
  • Fruit and Fruit Juices - J.13, J.14
  • Legumes - K.1.1, K.4
  • Miscellaneous Category - M.13, M.14, M.15, M.16
  • Sauces, Dips, Gravies and Condiments - R.7
  • Snacks - S.3
• Providing additional examples to the product category descriptions (Column 1) for 49 items
  • Bakery Products and Substitutes - A.1, A.2, A.8, A.10, A.13, A.17, A.18, A.19, A.23
  • Beverages - B.1, B.2, B.3, B.4, B.5
  • Cereals, Other Grain Products and Substitutes - C.5, C.7, C.8
  • Dairy Products and Substitutes - D.6
  • Desserts - E.5
  • Dessert Toppings and Fillings - F.1, F.2
  • Eggs and Egg Substitutes - G.1, G.2
  • Fats and Oils - H.4, H.6
  • Marine and Fresh Water Animals and Substitutes - I.4
  • Fruit and Fruit Juices - J.6, J.10
  • Legumes - K.1
  • Meat, Poultry, their Products and Substitutes - L.7
  • Miscellaneous Category - M.1, M.8
  • Combination Dishes Including Main Dishes - N.2, N.3
  • Nuts and Seeds - O.3
  • Potatoes, Sweet Potatoes and Yams - P.1, P.2, P.3
  • Salads - Q.1, Q.3
  • Sauces, Dips, Gravies and Condiments - R.5, R.6
  • Snacks - S.1
  • Soups - T.1
  • Sugars and Sweets - U.1, U.4
  • Vegetables - V.1, V.9
  • Foods Intended Solely for Children Under Four Years of Age - W.6
• Adding serving size instructions (Columns 3A and B) for 40 foods that require preparation
  • Bakery Products and Substitutes - A.1, A.2, A.4, A.5, A.6, A.7, A.8, A.9, A.10, A.17, A.22, A.23, A.24
  • Beverages - B.1, B.3, B.4, B.5
  • Cereals, Other Grain Products and Substitutes - C.11
  • Dairy Products and Substitutes - D.11, D.13
  • Desserts - E.5
  • Dessert Toppings and Fillings - F.1, F.2, F.3
  • Fats and Oils - H.4
  • Fruit and Fruit Juices - J.11
  • Eggs and Egg Substitutes - G.2
  • Meat, Poultry, their Products and Substitutes - L.7
  • Miscellaneous Category - M.11
  • Combination Dishes Including Main Dishes - N.1, N.2
  • Nuts and Seeds - O.3
  • Potatoes, Sweet Potatoes and Yams - P.1, P.2
  • Salads - Q.3
  • Sauces, Dips, Gravies and Condiments - R.1, R.2, R.3, R.4, R.5
  • Soups - T.1
  • Foods Intended Solely for Children Under Four Years of Age - W.6
• Providing serving size instructions (Columns 3A and B) for 61 food formats that had been overlooked in 2016
  • Bakery Products and Substitutes - A.5, A.6, A.7, A.8, A.10, A.18, A.19, A.20
  • Beverages - B.1, B.3, B.4
  • Cereals, Other Grain Products and Substitutes - C.1, C.7, C.8
  • Dairy Products and Substitutes - D.11, D.12, D.13
  • Desserts - E.1
  • Dessert Toppings and Fillings - F.1
  • Eggs and Egg Substitutes - G.1, G.2
  • Marine and Fresh Water Animals and Substitutes - I.3, I.4
  • Fruit and Fruit Juices - J.1, J.4, J.6, J.7, J.10, J.11
  • Legumes - K.1, K.2
  • Meat, Poultry, their Products and Substitutes - L.1, L.3, L.7, L.8
  • Miscellaneous Category - M.1, M.3, M.6, M.8, M.10
  • Combination Dishes Including Main Dishes - N.1, N.2
  • Nuts and Seeds - O.1
  • Potatoes, Sweet Potatoes and Yams - P.1, P.2, P.3
  • Salads - Q.1
  • Sauces, Dips, Gravies and Condiments - R.2, R.4
  • Snacks - S.1, S.2
  • Soups - T.1
  • Sugars and Sweets - U.1, U.3, U.4, U.10, U.13, U.14
  • Vegetables - V.1
  • Food Intended Solely for Children Under Four Years of Age - W.4
• Other
  • Added "and substitutes" to category titles A and C, and removed "substitutes" from Column 1 of items D.6, D.7, D.8, D.11 and D.13
  • Removed "used as ingredients" from Column 1 of item J.5
  • Added "without sauce" to Column 1 of item K.1
  • Re-itemized the following from the Notice of Proposal:
    • A.16.1 to A.26
    • J.7.1 to J.13
    • J.7.2 to J.14
  • Re-itemized former item S.3, Meat or poultry snack food sticks, as L.11
    • New product category, "Roasted seaweed, for use as snack", has thus been added as item S.3 rather than item S.4
  • Merged proposed item M.17 from the Notice of Proposal with item K.4
  • Made minor grammatical edits throughout the Table

Nutrition labelling considerations

The updates to the TRA provide clearer guidance on several food categories and address questions received from stakeholders after the 2016 nutrition labelling amendments to the FDR were published in the Canada Gazette, Part II. The changes also reflect stakeholder feedback received through the Notice of Proposal consultation.

Updating the TRA will have nutrition labelling implications for certain foods. These changes may affect the serving size declaration and the information declared in the Nutrition Facts table (NFt) for some foods. The RAs also factor into the requirements for the new front-of-package nutrition symbols. Since claim eligibility is assessed against both the serving of stated size and the RA, the modifications may have an impact on the ability to make certain claims. For example, products whose RAs have decreased (e.g., drinkable yogurts, yogurt and refried beans) may no longer be able to make the claims they are currently making (e.g., "excellent source of calcium" or "source of fibre").

As such, a transition period will be provided to allow sufficient time for regulated parties to make the necessary changes to their labels.

Stakeholder consultation

On June 24, 2021, Health Canada published a Notice of proposal to update the nutrition labelling: Table of reference amounts for food (Ref. No. NOP/ADP-QRA-2021-1) that was open to the public for comment for 75 days.

Twenty-seven submissions were received from stakeholders. The feedback received throughout the consultation was considered in refining the amendments to the TRA.

Summary of comments received

The majority of proposed amendments did not generate stakeholder feedback. In these cases, the proposed changes are included in the final Table. The following sections cover general comments on the TRA for which Health Canada is able to provide a response or clarification; comments on proposed changes, and; comments that relate to elements of the Table where no change was proposed but for which Health Canada believes there is value in being included in this round of amendments. The latter is limited to adding examples or clarity to the document.

Process

Stakeholders' views: Some health and industry stakeholders sought more clarification and commentary on the proposed updates, or more transparency on the overall process of updating the TRA. Health Canada was also encouraged to initiate discussions with industry earlier.

Health Canada's response: The amendments to the TRA are based on new food consumption data and market trends, and to address identified gaps in certain food categories.

To facilitate future updates to the TRA, stakeholders are encouraged to submit proposals for potential amendments to nut.labelling-etiquetage@hc-sc.gc.ca. The type of information that is required to accommodate such proposals depends on the request. For more information, please consult the Table of reference amounts for food.

Reference amounts

Stakeholders' views: Some industry stakeholders were not supportive of the proposed RAs for spirits (B.2d), mousse (E.6), salad kits consumed as part of a meal (Q.1.1) and hollandaise (R.4).

Some stakeholders did not support the updated RA of 115 g for yogurts, or raised concerns that decreasing from 175 g to 115 g would impact the ability to make certain positive claims, including probiotic, protein, calcium and reduced sugar claims.

Many stakeholders proposed adding new RAs for certain foods and/or proposed changes to existing RAs.

Health Canada's response: Health Canada has made revisions to the following RAs based on feedback received from stakeholders and the availability of supporting food consumption data and/or market trends.

• New item Q.1.1 included in the Notice of Proposal (Salad kits consumed as part of a meal) has been rescinded and these products have been added as an example to the product category description of item Q.1, Salads, with a RA of 100 g.
• Food consumption data indicated that the proposed RA of 60 mL for hollandaise was too high; therefore, hollandaise will remain in item R.1 with a RA of 30 mL.

The proposed RA for mousse (E.6) has been maintained, as it is supported by food consumption data. The proposed RA for spirits (B.2d) has also been maintained, as the RAs are based on food consumption data (i.e., amount typically consumed) rather than recommended amounts.

The proposed RA for yogurt has been maintained as it is supported by food consumption data. Health Canada does not intend to change the minimum number of microorganism per serving as a condition to make a probiotic claim. The minimum level of probiotics for probiotic claims remains the same (i.e., 1.0 x 10⁹ or 1 billion cfu), regardless of the change to the RA. Similarly, the criteria for nutrient content claims, including those for protein, calcium and reduced sugar, will not be adjusted to account for the reduced RA for yogurt, as these claims apply to all foods with a broad range of RAs.

As for stakeholder comments requesting new RAs or updates to existing RAs that went beyond the changes contained in the Notice of Proposal, Health Canada considers this feedback to be out of scope of this recent consultation. Stakeholders are encouraged to submit proposals for potential amendments, with supporting data, to be considered for future consultations.

Food examples

Stakeholders' views: Some industry stakeholders pointed out that the addition of meatloaf and nuggets to item L.7 would require label changes, as manufacturers currently use item L.4 for meatloaf and item L.6 for nuggets.

Several industry stakeholders raised concerns or inconsistencies regarding the application of the RAs for alternative or substitute foods, such as dairy and meat alternatives, and grain-free substitutes for pizza crust, pasta and noodles.

In addition, many stakeholders sought clarification on where particular foods are categorized, or proposed additional examples be captured in the TRA. Some health stakeholders were concerned that the current categories do not cover the diversity of foods currently available in the marketplace.

Health Canada's response: Health Canada's proposal to include meatloaf and nuggets in item L.7 is maintained, as stakeholders did not provide supporting data.

Alternative or substitute foods, such as dairy-free cheese, grain-free noodles or meat alternatives, should be categorized with the food they are mimicking, unless otherwise captured in the TRA (e.g., sugar substitutes have their own product category and RA). For example, dairy-free alternatives for milk are included in item D.11, while dairy-free alternatives for yogurt are included in item D.15. This is indicated in the category titles where examples of alternative or substitute foods have been identified (e.g., "D. Dairy Products and Substitutes"). Health Canada has added "and substitutes" to category titles A and C for consistency. To minimize redundancy and potential confusion, "substitutes" has been removed from the product category descriptions of items D.6, D.7, D.8, D.11 and D.13.

Certain examples from the Notice of Proposal have been rescinded. For example, "toppers for cheese" has not been added to item R.2, as stakeholders were unclear what it referred to. "Fruit and/or nut-based bars" has not been added to A.20, since energy and protein bars containing fruit and nuts are inherently captured in A.20. Rather, "fruit and/or nut-based bars" was added to A.18 and A.19, for added clarity.

In some cases, additional food examples have been provided in the product category description for clarification. In addition to the food examples from the Notice of Proposal, yorkshire puddings have been added as an example to item A.2; dessert perogies to item A.8; macarons and macaroons to item A.10; crepes to item A.17; clusters to items A.18 and A.19; matcha to item B.4; couscous to item C.7; noodles to item C.8; glaze to item F.1; pastry creams to item F.2; kimchi and sauerkraut to item V.9, and; other beverages (excluding milk) to item W.6. The product category description of item B.2e has been adjusted to clarify that all liqueurs are included. The product category description of item M.8 has been adjusted to clarify that regular and substitute bacon bits are included. Small creamer and milker cups were added to the product category description of item D.6. Overall, the number of product categories where additional examples have been provided has increased from 40 in the Notice of Proposal to 49.

For some requests, additional food examples were not provided in the TRA because it was considered unnecessary (e.g., foods that do not require nutrition labelling) or because the food does not fit within an existing category.

Health Canada acknowledges that the food examples in the TRA may not clearly accommodate the growing diversity in the food supply. While the TRA is not meant to be an exhaustive list, stakeholders are encouraged to continue to submit questions related to product categorization, or requests for amendments with supporting data, to nut.labelling-etiquetage@hc-sc.gc.ca.

Serving size instructions

Stakeholders' views: Several stakeholders proposed additional serving size instructions for various food formats that had been overlooked in the Notice of Proposal. Some proposed adding criteria for "single units for sale" to various categories such as beverages (B.1), as one person can reasonably consume certain products at a single occasion.

For various categories, industry stakeholders asked that Health Canada provide flexibility for serving size instructions. For example, by allowing the metric measure to be based on the amount of the household measure (i.e., # g or mL) rather than the RA itself or permitting the use of "about" or "approximately" within the serving size instructions.

Some stakeholders suggested revisions to the criteria for coffee (B.3), tea (B.4) and cocoa (B.5), such as: revising the criteria to be based on the amount of ground coffee or loose tea required to prepare the RA; adding or adjusting the criteria for pods; removing the word "prepared" as part of the requirements for the serving size declaration; and distinguishing requirements for instant cocoa.

One stakeholder suggested that the serving of stated size for eggs (G.2) remain as "2 eggs (# g)", rather than the proposed "# eggs (# g)".

Another stakeholder proposed revisions to the added criteria for "candy and chocolates, measureable with cup (where 15 or more pieces make up the RA)" and "package of multiple units (where 14 or less pieces make up the RA)" in item U.1.

Health Canada's response: In some cases, various food formats had been overlooked, and additional serving size instructions have been added based on stakeholder feedback. For example:

• Additional serving size instructions (Columns 3A and B) have been added to item S.3.
• Instructions for "fraction package" have been added to items C.7, D.1.1, J.7 and M.13.
• Instructions for "amount to make" have been added to items B.5, F.1, F.2, G.2, R.7 and W.6.
• Instructions for number of "scoops" and "packets" have been added to item D.13.
• Instructions for "package of multiple, individually prepackaged units, where one unit weighs either 50% to 200% of the reference amount, or more than 200% of the reference amount but can reasonably be consumed by one person at a single eating occasion" have been added to item N.2.

Criteria for "single units for sale" was not added, because the TRA is used to establish the serving size for multiple-serving prepackaged product. The serving of stated size for single-serving prepackaged products are determined using section B.01.002A (1)(b) of the Food and Drug Regulations.

The metric measure is often based on the RA to facilitate product comparison between similar foods, and this approach has been maintained for the majority of product categories. Health Canada acknowledges that for categories with larger RAs, there could be large discrepancies between the weight of the piece(s) or unit(s) used for the household measure and the weight used for the nutrition declaration (i.e., the RA). Health Canada intends to continue monitoring the application of the TRA for such categories.

The nutrition declaration for coffees and teas is based on the prepared amount so that carbohydrate and fibre values do not need to be declared in the NFt, because the grounds and leaves are not generally consumed. Health Canada considers that pods are able to use the existing criteria in these categories and that the inclusion of the word "prepared" as part of the serving size declaration on a label is important for consumer understanding, since most foods must provide the nutrition information for the product as sold. Therefore, no changes have been made to items B.3 and B.4, beyond what was proposed. The criteria in column 2 for cocoa (B.5) has been adjusted to "amount to make 250 mL of beverage" to clarify that it applies to instant products.

The proposed serving of stated size of "# eggs (# g)" for eggs (G.2) has been maintained. Most types of eggs will still have a serving size of "2 eggs" in practice, but flexibility is required for smaller eggs.

Health Canada has also maintained the proposed criteria for "candy and chocolates, measureable with cup (where 15 or more pieces make up the RA)" and "package of multiple units (where 14 or less pieces make up the RA)". This criteria was established for consumer ease and is consistent with other product categories in the TRA (e.g., items A.10 and A.11).

Editorial

Stakeholders' views: Some stakeholders proposed minor changes to the structure, grammar and spelling of the Table.

Health Canada's Response: Previously proposed items A.16.1, J.7.1 and J.7.2 have been changed to items A.26, J.13 and J.14 respectively. These did not need to be grouped with items A.16 or J.7, and therefore, the additional decimal number has been removed for simplicity. We note that some categories will retain this system. For example, item D.1.1, Cheese fondues, has remained as such, as it is logical to group this product category with other cheese product categories in the TRA.

Health Canada has moved previous item S.3, Meat or poultry snack food sticks, to new item L.11, as it is logical to group this product category with other meat and poultry product categories. This will also help manufacturers of alternative or substitute meat sticks recognize that they may use this product category.

Previously proposed item M.17, Soy protein isolate, has been merged with item K.4, Dried texturized soy protein. In the Notice of Proposal, these foods had the same RA and serving size instructions. This change removes the need for an additional category under miscellaneous.

Minor grammatical, spelling and formatting updates have been incorporated into the TRA.

Units of measure

Stakeholders' views: Some stakeholders raised concern that there is a discrepancy between the unit required for net quantity declaration and the unit of measure required for the serving size declaration of certain multiple-serving prepackaged foods. For example, the net quantity declaration for olives is required in millilitres, while the unit of measure for the serving size declaration is required in grams.

Health Canada's response: Health Canada acknowledges this inconsistency for a variety of foods, including vegetables packed in oil or pickled vegetables (V.9), and canned beans or pasta with sauce (N.1). However, B.01.002A(1)(b) of the Food and Drug Regulations does not require the serving size declaration for multiple-serving prepackaged foods to be in the same units as the net quantity declaration.

End of transition period / compliance date

Stakeholders' views: Industry associations raised concerns about the proposed transition period ending in December 2023 for the amended TRA, noting several reasons:

• The impacts and economic challenges of the COVID-19 pandemic
• Successive recent and planned labelling changes and their associated costs
• Resource constraints and the burden for assessing the implications and implementing changes to products' NFts and claims.

Based on the reasons above, industry associations requested a longer transition period to implement the changes, ranging from 3 to 5 years from the date the NOMs are published, and alignment with the Food Labelling Coordination Policy (FLCP) that was published in August 2021.

Health Canada's response: Updating the TRA will have nutrition labelling implications for certain foods. Some food labels will need to be updated to comply with these changes. In addition, RAs factor into claim eligibility and the requirements for the new front-of-package nutrition symbols. Therefore, the modifications may have broader impacts on nutrition labelling.

While the proposed amendments to the TRA were published prior to the publication of the FLCP, Health Canada has determined that the amendments fall within its scope. The objective of the FLCP is to establish predictable compliance dates for food labelling changes to provide industry with greater predictability so that overlapping transition periods and sequential labelling changes are minimized. Therefore, on January 14, 2022, stakeholders were informed through the Consultation and Stakeholder Information Management System (CSIMS) that the compliance date had now been aligned with the first compliance date set out by the policy, i.e., January 1^st, 2026. This also aligns with other updates to nutrition labelling, including the new front-of-package nutrition labelling regulations and recent amendments to the Table of Daily Values. The compliance date does not restrict industry stakeholders from making changes before the end of the transition period, as this remains a business decision.

Compliance and enforcement

Health Canada has enabled the modifications described above by amending the Nutrition Labelling – Table of Reference Amounts For Food on November 24, 2022. Given the nature of the changes, Health Canada gives industry until January 1, 2026 to implement these changes. During this time, the updated 2022 Table and the previous 2016 Table may be used. This will provide industry sufficient time to implement these changes. Therefore, following January 1, 2026, only the updated 2022 Table will be in effect.

The Canadian Food Inspection Agency is responsible for the enforcement of the Food and Drugs Act and its associated regulations with respect to foods.

Contact Information

Health Canada's Food Directorate is committed to reviewing any new information relating to this notice. Anyone wishing to submit an inquiry or new information may do so in writing, by regular mail or electronically. If you wish to contact the Food Directorate electronically, please use the words "Table of reference amounts for food (NOM/ADM-QRA-2022-1)" in the subject line of your e-mail and be addressed to:

Bureau of Nutritional Sciences, Food Directorate
Health Products and Food Branch, Health Canada
251 Sir Frederick Banting Driveway
Tunney's Pasture, PL: 2203E
Ottawa, ON K1A 0K9
Email: nut.labelling-etiquetage@hc-sc.gc.ca