Modification to the Table of reference amounts for food (very high fibre cereals, nutritional yeast, fondue cooking broths)
Notice of modification – Nutrition Labelling – Table of Reference Amounts for Food
Reference number: M-QRA-24-01
October 18, 2024
Background
The document, Nutrition Labelling - Table of Reference Amounts for Food (TRA), sets out reference amounts for different categories of foods.
Reference amounts:
- 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 shown 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. It is incorporated by reference into the Food and Drug Regulations (FDR).
Issue
The following items were identified as areas in the TRA requiring revision and/or clarity:
- The requirement to base the serving size for all ready-to-eat breakfast cereals on 1 cup is not appropriate for very high fibre cereal, since it results in an amount of fibre that is not reflective of the amount typically consumed in one sitting.
- Nutritional yeast was not captured in the previous version of the TRA (November 2022) and stakeholders need guidance for nutrition labelling purposes.
- A reference amount of 250 mL for fondue cooking broths is not representative of the amount typically consumed, because they are typically used as a cooking medium (for example, for meats or vegetables).
- Editorial revision to the French version of the TRA to better align the product category terminology in both official languages.
Rationale for action
Health Canada's Food and Nutrition Directorate considered stakeholder feedback, food consumption data, and/or market analysis in determining that the following revisions to the TRA were required.
Add new serving size instructions for very high fibre cereals (C.3)
For ready-to-eat breakfast cereals in items C.2, C.3 and C.4 of the TRA, the serving size and nutrition information declared in the NFt is based on "1 cup" and the weight of 1 cup in grams. This approach was introduced as part of the 2016 nutrition labelling changes to help consumers compare different cereals. It was determined that a consistent serving size of 1 cup is easier for consumers to relate to than a consistent amount in grams, given the varying density across breakfast cereal categories. However, due to the density of some very high fibre cereals, a serving size of 1 cup may correspond to a weight that is well above the reference amount, and in some cases, a large fibre declaration in the NFt that is not reflective of the amount of fibre typically consumed in a sitting.
The Directorate has added new serving size instructions in column 3A and B for very high fibre cereals in item C.3 of the TRA. The resulting serving size for these products in the NFt willcontain an amount of fibre that is more likely to be consumed in one sitting.
Add a new reference amount and corresponding serving size instructions for nutritional yeast (M.17)
The Food and Nutrition Directorate has also added a new reference amount category (item M.17), and corresponding serving size instructions for nutritional yeast to the TRA. This update provides guidance on this food category.
Change the reference amount for fondue cooking broths (T.2)
Fondue cooking broths were previously captured in item T.1 as part of the “All varieties of soup, including bouillon, broth and fondue broth category” of the TRA with a reference amount of 250 mL. The Food and Nutrition Directorate has revised the reference amount for fondue cooking broths to more accurately reflect the amount typically consumed. To accommodate the revision to the reference amount, fondue cooking broths are now listed separately in item T.2. The Directorate also accepted an industry association request to include "amount to make" serving size instructions because there are unprepared forms of fondue cooking broths. Additional details can be found in the Consultation section below.
Consultation
On December 21, 2023, Health Canada published a Notice of proposal to update the Nutrition labelling: Table of reference amounts for food (NOP), that was open to the public for comment for 70 days. Three stakeholders provided comments during the consultation period which ended February 28, 2024. These comments are summarized below with Health Canada's responses.
Comments on the proposed changes for very high fibre cereals (C.3), nutritional yeast (M.17) and fondue cooking broths (T.2)
Stakeholder comment: One industry association indicated that their members generally support the changes for very high fibre cereals, fondue cooking broths and nutritional yeast. They also requested that "amount to make" serving size instructions be included for item T.2 because there are unprepared forms of fondue cooking broths.
Health Canada's response: Unprepared forms of fondue cooking broths (for example, dry mix) were overlooked in the NOP, and instructions for "amount to make" have also been included in item T.2.
Outcome: Proposal revised.
Comments on implementation and enforcement
Stakeholder comment: One industry association expressed concern about the implementation timelines for the amended TRA. It was noted that the proposed compliance date of January 1, 2026 would provide less than two years to update labels, which is not in accordance with the Food Labelling Coordination Policy (FLCP). It was proposed that the compliance date be extended to January 2028.
Health Canada's response: Updating the TRA will have nutrition labelling implications for very high fibre cereals, nutritional yeast and fondue cooking broths. Some food labels will need to be updated to comply with these changes. In addition, reference amounts factor into claim eligibility and the requirements for the new front-of-package nutrition symbols.
Health Canada agrees that the modifications fall within the scope of the FLCP. Therefore, the compliance date for these TRA modifications has now been aligned with the next available compliance date under the policy, January 1, 2028. The compliance date does not restrict industry stakeholders from making changes before the end of the transition period, as this remains a business decision.
Outcome: Proposal revised.
Other comments
Stakeholder comments: Some of the comments suggested changes unrelated to those proposed for very high fibre cereal, nutritional yeast or fondue cooking broth.
Health Canada's response: Further changes to reference amounts, food examples and/or serving size instructions are outside of the scope of the NOP and would require further consultation. Health Canada will review these requests separately from this Notice. Where appropriate, changes may be proposed for a future consultation and update to the TRA. Stakeholders are encouraged to continue submitting new requests with supporting data to nut.labelling-etiquetage@hc-sc.gc.ca at any time, to ensure they are considered for future work.
Outcome: Proposal maintained.
Modification to the Table of reference amounts for food
Health Canada has modified the TRA as shown below.
C. Cereals, other grain products and substitutes
| Item | Column 1 | Column 2 | Column 3 | |
|---|---|---|---|---|
| Product Category | Reference Amount (RA)Footnote 1 | A. Criteria to Determine the Serving of Stated Size for Multiple-Serving Prepackaged Products |
B. Units for Expressing the Serving of Stated Size for Multiple-Serving Prepackaged Products Footnote 3 |
|
| C.3 | Ready-to-eat breakfast cereals, puffed and coated, flaked, extruded, without fruit or nuts (weighing 20 g to 42 g per 250 mL), very high fibre cereals (with 28 g or more fibre per 100 g) | 30 g | Ready-to-eat breakfast cereals, puffed and coated, flaked, extruded, without fruit or nuts (weighing 20 g to 42 g per 250 mL):
|
1 cup (# g) |
Very high fibre cereals (with 28 g or more fibre per 100 g):
|
fraction cup (30 g) | |||
Package of multiple, individually prepackaged units, where one unit weighs either 50% to 200% of the RA, or more than 200% of the RA but can reasonably be consumed by one person at a single eating occasion:
|
1 unit (# g) | |||
M. Miscellaneous category
| Item | Column 1 | Column 2 | Column 3 | |
|---|---|---|---|---|
| Product Category | Reference Amount (RA)Footnote 1 | A. Criteria to Determine the Serving of Stated Size for Multiple-Serving Prepackaged Products |
B. Units for Expressing the Serving of Stated Size for Multiple-Serving Prepackaged Products Footnote 3 |
|
| M.17 | Nutritional yeast | 5 g |
|
# tsp (5 g) |
T. Soups
| Item | Column 1 | Column 2 | Column 3 | |
|---|---|---|---|---|
| Product Category | Reference Amount (RA)Footnote 1 | A. Criteria to Determine the Serving of Stated Size for Multiple-Serving Prepackaged Products |
B. Units for Expressing the Serving of Stated Size for Multiple-Serving Prepackaged Products Footnote 3 |
|
| T.1 | All varieties of soup, including bouillon and broth | 250 mL | Ready to serve:
|
1 cup (250 mL) |
| Amount to make 250 mL final product |
|
# cubes (# g) |
||
Package of multiple, individually prepackaged units, where one unit prepares 50% to 200% of the RA, or more than 200% of the RA but can reasonably be consumed by one person at a single eating occasion:
|
1 unit (# g) | |||
| T.2 | Fondue cooking broths | 15 mL |
|
1 tbsp (15 mL) |
| Amount to make 15 mL final product |
|
# tsp (# g) |
||
Package of multiple, individually prepackaged units, where one unit prepares 50% to 200% of the RA, or more than 200% of the RA but can reasonably be consumed by one person at a single eating occasion:
|
1 unit (# g) | |||
- Footnote 1
-
Unless otherwise noted, the reference amounts are for the ready-to-serve or almost ready-to-serve form of the food. If not listed separately, the reference amount for the unprepared form, such as dry mixes, concentrates, dough, batter, and fresh or frozen pasta, is the amount required to make one reference amount of the prepared form.
- Footnote 3
-
The terms piece(s) or unit(s), container, package, pan, fruit and other similar terms are used as generic descriptors.
Note: Footnote 2 has been omitted here as it pertains to information not included in this Notice.
Editorial modification
In item H.4 of the French version of the TRA, "Sauces pour salades" has been added to the Product Category (Column 1) for greater clarity.
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
Implementation of the above modification came into force October 18, 2024, the day it was published in the Nutrition Labelling - Table of Reference Amounts for Food.
Given the nature of the modification, Health Canada is providing industry until December 31, 2027 to implement the changes. During this time, prepackaged products can be labelled according to the most current version of the TRA (October 2024), or can continue to be labelled in accordance with the November 2022 version. Additionally, prepackaged products can remain labelled under the December 2016 version of the TRA until December 31, 2025. The transition period for the current modification enables manufacturers and distributors to maintain market access while making the necessary changes to their products to comply with the new regulatory requirements.
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 "Table of Reference Amounts for Food (M-QRA-24-01)" in the subject line of your email.
Bureau of Nutritional Sciences
Food and Nutrition Directorate
251 Sir Frederick Banting Driveway
Address locator 2203E
Tunney's Pasture
Ottawa ON K1A 0K9
Email: nut.labelling-etiquetage@hc-sc.gc.ca
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