Health Canada’s notice of modification to update the incorporated by reference document entitled nutrition labelling – Table of daily values

Reference Number: NOM/ADM-DVQ-2022-1

October 20, 2022

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Summary

The purpose of this notice is to inform consumers and interested stakeholders that Health Canada has amended the Nutrition Labelling – Table of daily values on October 20, 2022. Manufacturers will have until January 1, 2026 to comply with the updated Daily Values. The notice provides the appropriate contact information for any inquiries or for those wishing to submit any new information.

The Table of daily values is a two-part table that sets out the reference values or recommended amounts of nutrients (the daily value) for specific age groups. These are the reference points upon which the % daily values (DVs) in the Nutrition Facts table (NFt) are based.

Part 1 of the table sets out the daily values for macronutrients and sodium for two age groups. Part 2 of the table sets out the daily values for vitamin and mineral nutrients for three different age groups.

The table 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, this information was prescribed in tables following section B.01.001.1 and in Part D, Divisions 1 and 2 of the FDR.

Rationale for revising daily values for sodium and potassium

The National Academies of Sciences, Engineering and Medicine (NASEM) has published updated Dietary Reference Intakes (DRIs) for sodium and potassium intake (2019). The DRIs are a comprehensive set of nutrient reference values for healthy populations that are used to inform nutrition policies and programs.

The release of the 2019 DRIs prompted Health Canada to examine policy implications for existing nutrition labelling regulations. Health Canada has completed an assessment of the new DRI values and has updated the DVs for potassium and sodium set out in the Table of daily values as follows:

Daily value for sodium

Rationale for revising the DV for sodium

Updated daily value for sodium
Column 1 Daily Value
Column 2 Column 3
Nutrient Food intended solely for children one year of age or older but less than four years of age Food intended for children one year of age or older but less than four years of age or for children four years of age or older and adults
Sodium 1200 mg 2300 mg (no changes)

Daily value for potassium

Rationale for revising the DVs for potassium

Updated daily values for potassium
Column 1 Daily Value
Column 2 Column 3 Column 4
Nutrient Food intended solely for infants six months of age or older but less than one year of age Food intended for infants six months of age or older but less than one year of age or children one year of age or older but less than four years of age Any other case
Potassium 860 mg 2000 mg 3400 mg

Nutrition labelling considerations

With respect to sodium

With respect to potassium

Stakeholder consultation

On June 24, 2021, Health Canada published a Notice of Proposal to update the incorporated by reference document: Table of daily values [NOP/ADP-DVQ-2021-1] that was open to the public for comment for 75 days.

Eighteen submissions were received from industry, academia, health organizations/professionals and a consumer advocacy organization. While most supported the intent of the proposed amendments, some expressed concerns about certain aspects such as the proposed date of December 14, 2023 for implementing the changes to the DVs. The feedback received throughout the consultation was considered in refining the proposal.

Summary of comments received:

Daily Values for sodium

Stakeholders' views: Most stakeholders supported the updated sodium DV of 1200 mg for young children to be in line with the 2019 DRIs.

One suggested that the sodium DV for children one year of age or older but less than four years of age or for children four years of age or older and adults should be based on the 1500 mg Adequate Intake (AI) because the current DV of 2300 mg understates the amounts of sodium in foods and thus contributing to high sodium consumption. The NFt does not display that 2300 mg is a limit rather than a target consumption and this puts people at risk because sodium elevates blood pressure in continuum if consumed above 1500 mg.

Health Canada's response: Health Canada decided to move forward with the updated sodium DV for young children as proposed.

Health Canada's approach is to set the DVs for nutrients of public health concern related to excessive intakes based on upper limit values. Therefore, the DV for sodium is set at the Chronic Disease Risk Reduction Intake (CCDR) for sodium of 2300 mg for most individuals. For sodium, the CDRR is the intake above which intake reduction is expected to reduce chronic disease risk (blood pressure, hypertension, and cardiovascular disease risk) within an apparently healthy population. Although further reductions in sodium intake below the sodium CDRR may lower blood pressure, more evidence is needed to determine the effect on chronic disease risk.

Even though the DV doesn't represent individual needs, consumers can use the %DV as a simple guide to quickly and easily assess the nutrient content of a serving of a food. Using the %DV rule of thumb, where "5% or less is a little" and "15% or more is a lot" of a nutrient, consumers can more easily select foods with nutrients they are trying to decrease or increase. Alternatively, individuals can use the amount of sodium declared in the NFt to choose foods low/lower in sodium.

Daily Values for potassium

Stakeholders' views: Most stakeholders agreed or supported Health Canada's rationale for revising the potassium DVs to be in line with the updated 2019 DRIs. Some health stakeholders added that the lower potassium DV would better align the guidance of "5% or less is a little" with what is considered to be a low potassium food for people with kidney disease. Some noted that individuals seeking to limit or improve intakes are less guided by DVs than by the amounts of nutrients displayed on label.

Health Canada's response: Health Canada decided to move forward with the changes to the potassium DVs as proposed. As already noted, the DV doesn't represent individual needs, instead, the %DV is a guide to help consumers make informed food choices and make comparisons among similar products. Health Canada recognizes that consumers seeking to limit/improve their potassium intake can use the absolute amounts of potassium which is now required to be declared in the NFt.

Education

Stakeholders' views: Some stakeholders suggested education to help consumers understand the labels of similar products that would use different basis for the potassium DVs during the compliance/transition window because consumers may interpret the higher percentage of DVs for potassium as happening because of changes in the composition of the food for a similar type of product.

Some encouraged Health Canada to communicate the changes to the sodium/potassium DVs and use the updated DVs as an opportunity to promote lower sodium intakes among high consumers of sodium, including children, and to promote adequate potassium intakes for the general population.

Health Canada's response: Given the basis of the DVs are not declared on labels (i.e. 3400 mg vs 4700 mg for the potassium DV), consumers cannot determine whether the former or updated DV for potassium is used as basis for the %DV shown on a label. However, consumers can use the amount of potassium declared in the NFt to make accurate comparisons between similar products.

In December 2016, Health Canada amended regulations that include the mandatory declaration of potassium in the NFt, in milligrams and as a %DV. The food industry was given a 5-year transition period to comply with these changes, ending in December 2021. However, due to challenges caused by the COVID-19 pandemic, the Canadian Food Inspection Agency will focus its efforts on education and compliance promotion for the first year, until December 14, 2022. Therefore, consumers will soon be consistently able to use the amount of potassium declared in the NFt to make accurate comparisons between similar products, while both the former and updated DV apply.

To improve understanding of food labels, Health Canada launched the Nutrition Labelling Online Course in June 2021. This free course provides information to health professionals and educators about nutrition labelling and helps increase understanding of the latest nutrition labelling information. Topics include food labelling in Canada, the NFt, the serving size, the %DV, the list of ingredients and nutrition claims. This tool contains interactive content, quizzes and ready-to-use resources activities.

Furthermore, Health Canada promotes sodium reduction through various initiatives such as the voluntary sodium reduction targets for processed foods and via Canada's Food Guide that promotes healthy eating.

Nutrient content claims

Stakeholders' views: A few respondents that commented on nutrition labelling considerations, agreed that the changes to the potassium DV will result in more products meeting the new conditions to make potassium-related source claims and noted that the conditions should be updated and also be communicated to stakeholders.

Health Canada's response: As the updated potassium DVs are lower compared to the 2016 potassium DVs, more food products will now meet the new conditions to make a "source of" (170 mg), "good source of (340 mg) or "excellent source of" (510 mg) claim.

Compliance date/end of transition period

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

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 NOM is published and alignment with the Food Labelling Coordination Policy published in August 2021.

Health Canada's response: Health Canada's opinion is that updating the DVs will not require redesign of package labels, as it does not affect the NFt's size or format. With respect to sodium, manufacturers will be required to update the %DV for foods intended solely for children one year of age or older but less than four years of age. With respect to potassium, manufacturers will be required to update the %DV for all foods and in some cases, the voluntary potassium content claims on their labels.

Health Canada has determined that the proposed amendments to the DVs for potassium and sodium for specific age groups that were published prior to the release of the Food Labelling Coordination Policy fall within the scope of this policy. The objective of the policy is to coordinate/establish predictable compliance dates for food labelling changes to provide industry with greater predictability so that overlapping transition periods and sequential labelling changes be minimized.

Therefore, the compliance date for these amendments will now be aligned with the first compliance date set out by the policy, i.e., January 1st, 2026.

Compliance and enforcement

Health Canada has enabled the modifications described above by amending the Nutrition Labelling – Table of daily values on October 20, 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 apply. 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 daily values (NOM/ADM-DVQ-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 0L2
Email: bns-bsn@hc-sc.gc.ca

Footnotes

Footnote 1

The UL is the highest average daily nutrient intake level likely to pose no risk of adverse health effects not related to chronic disease.

Return to footnote 1 referrer

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