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Labeling of Foods, Marion Zarkadas
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Marion Zarkadas is a Policy and Legislation Officer for the Canadian
Food Inspection Agency.

Ms. Zarkadas discussed Canadian food labeling regulations and the
current efforts for change.  With the formation of the Canadian Food
Inspection Agency in April 1997 from the amalgamation of several
government activities and organizations, the Canadian food industry is
now viewed by the agency as being composed of four distinct segments:
the CFIA, the food industry itself, Health Canada, and consumers.

The agency is responsible for providing science-based information to
the food industry, inspecting and monitoring food labeling and
manufacturing practices, and recalling foods as required.

The industry is responsible for developing an allergy awareness plan
and ensuring that foods are safe and accurately labeled.

Health Canada is responsible for setting health and safety standards,
providing risk assessments, and developing regulations.

Consumers are responsible for reading food labels carefully and
avoiding questionable foods.

The only major change to the Canadian Food Labeling regulations since
their initiation in 1976 was the added regulation in 1996 regarding
gluten-free (GF) foods.  The added regulation reads as follows:  "No
person shall label, package, sell, or advertise a food in a manner
likely to create an impression that it is a gluten-free food unless
the food does not contain wheat, including spelt and kamut, or oats,
barley, rye or triticale or any part thereof."  However, gluten
sources are not declared:

  1.  ...where there is a component exemption such as an ingredient of
         an ingredient.  An example would be icing sugar or baking
         powder which may contain wheat starch to prevent clumping.

  2.  ...where they fit in a class name such as seasonings,
         flavorings, spices, etc.  Sometimes wheat flour is added.

  3.  ...where there is cross contamination or mistakes such as
         mislabeling.

Food labeling in Canada is done at all levels of trade:  wholesale,
retail, packaged for hospital use, etc.  So an ingredient list can be
found somewhere in the system for almost everything.  The following
are specifically exempt:

  *  Foods packaged from bulk at retail.  (Note:  The foods as
     delivered in bulk, however, should be labeled.)

  *  Individual food portions served with meals or snacks.  (Butters,
     jellies, mustards, catsups, etc.)

  *  Individual foods prepared by a commissary and sold in automatic
     vending machines or mobile canteens.

  *  Meat and poultry barbecued at retail.

  *  Standardized alcoholic beverages and vinegar.  (Note:  Ms.
     Zarkadas stated that vinegar is not a problem for celiacs except
     for possibly malt vinegar.  Later, when discussing paprika, she
     again declared that white vinegar is no problem.)

Two other categories of foods that may be a problem for celiacs are:

  *  Prepared meat, fish, poultry, or their by-products if they are
     present at less than 10% in the final food, because they may
     contain wheat flour or gluten.

  *  Starches, modified starches, and hydrolyzed plant protein because
     they may not identify the plant source.  For example:  wheat
     starch, corn starch, or hydrolyzed wheat protein.

Several activities are occurring which could significantly assist
celiacs.  On the international level, the Codex Alimentarius is in the
final stages of adoption of the inclusion of a declaration of all
gluten sources on ingredient labels.

Canada has recently sent a letter (not a regulation) to members of the
food industry urging them to always declare in the ingredient list
when the following foods are present as ingredients OR COMPONENTS:

   peanuts
   tree nuts (almonds, Brazil nuts, cashews, hazelnuts (filberts),
      macadamia nuts, pecans, pinenuts, pistachios, walnuts)
   sesame seeds
   milk
   eggs
   fish, crustaceans (e.g. crab, crayfish, lobster, shrimp) and
      shellfish (e.g. clams, mussels, oysters, scallops)
   soy
   WHEAT
   sulphites

In addition, Canada has also urged the food industry to include the
plant source in the common name of all forms of hydrolyzed plant
protein, starches, modified starches, and lecithin (e.g.  hydrolyzed
WHEAT protein, modified WHEAT starch, soy lecithin).