Update on the Canadian Nutrient File Initiative

Joint Statement from Health Canada and
the Canadian Food Inspection Agency
On the Potential Use of Nutrient Databases
to Meet Nutrition Labelling Requirements

October 6, 2003

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The Food Directorate of Health Canada embarked on an initiative in the fall of 2002 to enhance the Canadian Nutrient File (CNF), the Health Canada reference food composition database listing the nutrient composition of foods commonly consumed in Canada. The goal of the initiative is to expand the CNF to better meet the needs of government, dietitians and institutions, industry and academia. Earlier this year, consultations were held across the country with stakeholders of the CNF to seek their interest and support for this initiative.

At almost all of these meetings, stakeholders stated that the CNF or another database is needed to assist the industry to comply with the requirements of the nutrition labelling regulations announced in the Canada Gazette Part II on January 1, 2003. The first objective of these regulations is to enable consumers to make appropriate food choices in relation to reducing the risk of developing chronic diseases and permitting dietary management of chronic diseases of public health significance. To support this objective, there is a need for accurate product specific data to assist industry in their development of the Nutrition Facts tables to be carried on the labels of prepackaged food products.

The CNF has traditionally been used as a tool to assist Health Canada in the areas of policy formulation, standard setting, risk assessment and surveillance activities. As well, the CNF is used in product development, recipe formulation, institutional menu planning and diet counselling. However, as it contains generic data on foods, as opposed to brand-specific data, it is most often not suitable for use in determining values for nutrition labelling.

The purpose of this joint statement is to highlight the Health Canada and the Canadian Food Inspection Agency (CFIA) position regarding the use of databases in supporting nutrition labelling requirements.

Both Health Canada and the CFIA recognize the importance to industry of maintaining reasonable costs and efficiencies while generating accurate nutrition data. As part of the Health Canada CNF initiative, the merits and feasibility of a separate ingredient database that would help generate nutrient information meeting the objectives of the nutrition labelling regulations are being investigated. This database, if developed, could be associated with, but separate from, the original CNF, in a Canadian Nutrient Data System (CNDS). A variety of partnership and resourcing options for the development of a database are being examined.

It is the mandate of the CFIA to enforce the regulations developed by Health Canada. In its upcoming publication, Nutrition Labelling Compliance Test, the CFIA sets out its system for assessing the accuracy of nutrient values in Nutrition Facts tables. It is based on laboratory analysis of the nutrient content of a sample drawn at random from a lot and the results subject to acceptance criteria including tolerances. Manufacturers have the responsibility of ensuring that values in the Nutrition Facts table are accurate, however, they are not required to use the CFIA procedure but may choose the risk management strategy for developing accurate nutrient data best suited to the foods to be labelled. Tools include laboratory analysis, nutrition labelling databases and supplier ingredient data. Some of the considerations in developing accurate values include knowledge of the sources of variability (e.g. processing effects), good sampling criteria, and use of proven methods of laboratory analyses.

Health Canada's aim in facilitating the development of an ingredient data base is to assist in the creation of a database that would use the same rigorous principles identified above, such that the nutrient information generated by it would likely be representative of the specific product described. Manufacturers would need to assess this and similar databases for applicability to their specific situations, usually by involving some laboratory testing. In order to ensure a high probability of correct label values, manufacturers should also have good process controls so that their products are consistent and the nutrient values are predictable. They may need to generate additional data for unique ingredients.

The CFIA will assess label values by evaluating industry system controls, including record keeping, raw material control and specifications, company lab analysis, documentation of data sources, audit verification, management of ingredient data, such as updates, substitution and processing effects where warranted, via laboratory analysis. Compliance action would take into consideration not only laboratory results, but the health risk to the public, economic loss to consumers, past compliance history, and the company's quality control over the manufacturing and labelling processes. If a product were found to be non-compliant, the CFIA would work with the manufacturer to understand and oversee the correction of the problem.

The CFIA and Health Canada are currently preparing several documents to aid industry in nutrition labelling. These include revisions to The Guide to Food Labelling and Advertising and a new Guide for Developing Nutrition Labelling Values.

Health Canada and CFIA look forward to the continued support of all stakeholders in the CNF Initiative as we begin to build the Canadian Nutrient Data System.

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For further information, please contact:

cnfuser@hc-sc.gc.ca