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:
- Food intended solely for children one year of age or older but less than four years of age:
- DV for sodium: 1200 mg (Column 2 of Item 6 in Part 1 of the table)
- Food intended solely for infants six months of age or older but less than one year of age:
- DV for potassium: 860 mg (Column 2 of Item 1 in Part 2 of the table)
- 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:
- DV for potassium: 2000 mg (Column 3 of Item 1 in Part 2 of the table)
- For any other case:
- DV for potassium: 3400 mg (Column 4 of Item 1 in Part 2 of the table).
Daily value for sodium
Rationale for revising the DV for sodium
- Sodium is an essential mineral nutrient that our bodies need in small amounts to function properly. However, Canadians consume too much sodium. High sodium intake can cause hypertension (high blood pressure) which is an important risk factor for heart disease, stroke, and kidney disease, as well as other conditions. Heart disease and stroke are leading causes of death in Canada, after cancer. For these reasons, sodium is a nutrient of public health concern.
- The 2019 DRI report included a new category of DRIs called Chronic Disease Risk Reduction Intakes (CDRR). The CDRR is the lowest level of intake expected to reduce chronic disease risk. CDRR values were established for sodium. In the case of sodium, the CDRR for adults, 19-70 years is "reduce intakes if above 2300 mg/day" and CDRR for children 1-4 years is "reduce intakes if above 1200 mg/day".
- There is insufficient evidence to establish a toxicological risk level from high sodium intake, separate from chronic disease risk. As such, no sodium Tolerable Upper Intake level (UL)Footnote 1 was established. The CDRR values for sodium are similar to the ULs established in the 2005 DRI report as the effect of sodium intake on blood pressure used to inform the previous ULs was part of the evidence used by the DRI committee to inform the CDRR. However, the sodium CDRRs for children were extrapolated based on Estimated Energy requirements (EERs) for sedentary individuals, rather than being based on reported energy intake because of concerns over bias in self-reported energy intake.
- For nutrients of public health concern related to excessive intakes that are linked to increased risk of chronic disease, the DVs declared on the NFt are typically based on the upper limit values or the lowest level of intakes expected to minimize the risk to health. In the case of sodium, the updated DVs are based on the CDRR values.
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
- Potassium is an essential mineral nutrient. Increasing dietary potassium intake can reduce blood pressure in individuals with hypertension. Based on current dietary intake recommendations, potassium is a nutrient of public health concern because of the low intakes and high prevalence of hypertension in the Canadian population.
- In the absence of a specific indicator to determine potassium requirements of healthy people, the Adequate Intake (AI) values for potassium were updated in the 2019 DRI report. Apart for infants 6 months to less than 12 months old, the potassium values are lower for every life-stage group in comparison with the 2005 DRI values. This is because the AIs were derived using updated usual potassium intakes of children and adults with normal blood pressure and no history of cardiovascular disease. For infants, the AIs were derived from estimates of potassium intakes in breastfed infants.
- For nutrients Canadians do not consume enough of, such as potassium, the DVs continue to be based on the "population coverage" principle of choosing the highest recommended intake value that covers the nutrient requirements of almost all healthy individuals in each age group.
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
- The updated sodium DV for food intended solely for children one year of age or older but less than four years of age will result in higher %DV declaration in the NFt. However, this will not impact the sodium nutrient content claims (Note: only a "no added sodium or salt" nutrient content claim is permitted on these foods (B.01.503(2)(d)).
With respect to potassium
- The updated potassium DV will result in a higher %DV declaration in the NFt (except for the %DV for infants six to twelve months which will result in a lower %DV).
- The updated potassium DV will allow for a greater number of products to make potassium-related source claims. For example, in order to make a potassium nutrient content claim such as "source of", "good source of" or "excellent source of" a food must contain at least 5%, 10% or 15% respectively of the potassium DV per serving of stated size. Based on the 2016 DVs, this is equivalent to 235 mg, 470 mg or 705 mg respectively per serving of stated size. As the revised DVs are considerably lower than the 2016 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.
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:
- The impacts and economic challenges of the COVID-19 pandemic.
- Successive recent and planned labelling changes and their associated costs.
- The proposed change to the potassium DV would require a complete redesign to most food labels as they would have to be reassessed. They claimed that any update to a label means total redesign including potential impacts on nutrient content 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 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 DirectorateHealth 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.
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