Urgent: New Canadian Front-of-Package Food Labeling Regulations

Table of Contents

A. Which Foods Will Require the New Front-of-Package Label—and Which Ones Will Be Exempt?

B. Timelines

• What Does the Transition Period Mean for Food Manufacturers?
• What Happens After the Transition Period?

C. Key Components of the Front-of-Package (FOP) Nutrition Labeling Regulation

• A Standardized FOP Nutrition Symbol
• Nutrient Thresholds That Trigger the FOP Label
• Prepackaged Foods vs. Prepackaged Meals: How to Determine the Right Category
  • Prepackaged Foods (General)
  • Prepackaged Meals (≥200g)
  • Key Factors to Consider
• Special Thresholds for Small Packages
• Exemptions
  • Foods Exempt from the FOP Symbol
  • Rationale Behind These Exemptions
• FOP Symbol Format and Placement Requirements

D. What is the Context Behind Canada’s New FOP Labeling Regulation?

• Health Canada’s Research and Consultations
• International Practices and Their Impact

Time is running out for food manufacturers to comply with Canada’s new Front-of-Package (FOP) Nutrition Labeling Regulations.

Canada’s new Front-of-Package (FOP) Nutrition Labeling Regulation introduces a standardized symbol that must be displayed on prepackaged foods exceeding specific thresholds for saturated fat, sugars, or sodium.

With less than one year to prepare, food businesses must act now to review product formulations, update packaging, and ensure compliance.

This article breaks down the essential steps to keep your business ahead of the curve.

A. Which Foods Will Require the New Front-of-Package Label—and Which Ones Will Be Exempt?

By January 1, 2026, all prepackaged foods exceeding Health Canada’s thresholds for saturated fat, sugars, or sodium must display a standardized front-of-package nutrition symbol on their food labels. This regulation aims to help consumers make informed choices and reduce diet-related health risks.

• Which foods does the new regulation apply to? Prepackaged foods exceeding specific nutrient thresholds must feature the FOP symbol.
• What is the symbol? A black-and-white, magnifying glass symbol with “High in [nutrient]” text and Health Canada logo.
• Which foods are exempt from this regulation? Some foods, including whole fresh foods, certain dairy products, and small packaging formats, are exempt.
• Which foods are prohibited from displaying the FOP symbol? Some foods designed for specialized nutritional needs, such as infants, medical diets, and meal replacements, are prohibited from displaying the FOP symbol on their labels.

B. Timelines

What Does the Transition Period Mean for Food Manufacturers?

Manufacturers should use this transition period strategically to avoid last-minute compliance issues and ensure a smooth shift to the new labeling requirements.

• Transition Period Dates: June 20, 2022, to December 31, 2025.
• Purpose:
  • Allows manufacturers to review recipes, reformulate products, and update packaging to comply with the new labeling rules.
  • Allows manufacturers to manage inventory, redesign labels, and phase out non-compliant packaging without immediate penalties.
• Flexibility: During this period, businesses can gradually implement the FOP symbol but are not yet legally required to do so.

What Happens After the Transition Period?

Starting January 1, 2026, the regulation becomes fully mandatory, and any non-compliant products may face enforcement actions, including fines, product recalls, or restricted sales.

C. Key Components of the Front-of-Package (FOP) Nutrition Labeling Regulation

Below are the essential details of the regulation to ensure compliance.

A Standardized FOP Nutrition Symbol

The required symbol is a black-and-white magnifying glass icon, designed to be highly visible to consumers. It includes:

• A bold “High in” warning, followed by the specific nutrient exceeding the threshold (saturated fat, sugars, or sodium).
• The Health Canada / Santé Canada designation at the bottom to reinforce credibility.
• A simple, bilingual format (English and French) to meet Canada’s language requirements.

This symbol must be prominently displayed on the front of the package, ensuring consumers can easily identify products high in key nutrients linked to chronic diseases.

Nutrient Thresholds That Trigger the FOP Label

Food manufacturers must display the FOP symbol if their product exceeds the following limits per serving (serving size or reference amount):

Nutrient	Prepackaged Foods (General)	Prepackaged Meals (≥200g)	Small Packagess (≤ 30g or 30ml)
Saturated Fat	≥15% of Daily Value (DV)	≥30% of DV	≥10% of DV
Sugars	≥15% of DV	≥30% of DV	≥10% of DV
Sodium	≥15% of DV	≥30% of DV	≥10% of DV

Prepackaged foods and prepackaged meals: How to Determine the Right Category

• Prepackaged Foods (General)

  • This includes most individual food products, such as snacks, cereals, condiments, beverages, and processed foods sold in a package.
  • The FOP labeling threshold is 15% of the Daily Value (DV) for saturated fat, sugars, or sodium. (Note that daily values are different in Canada and the USA for some foods. Refer to the discussion on Canada’s Daily Values in our article Food Labels: Differences between U.S. and Canada – Nutrition Facts Table, Ingredients, etc. – 2025 Updates)
  • Example: A bag of chips, a bottle of soda, or a jar of pasta sauce would fall under this category.

• Prepackaged Meals (≥200g)

  • This refers to multi-component meals that constitute a complete meal or a substantial part of a meal.
  • The FOP labeling threshold is higher—30% of the Daily Value (DV) for saturated fat, sugars, or sodium to account for the fact that meals are larger portions.
  • Example: Frozen lasagna, ready-to-eat meal kits, or prepackaged sushi trays would be considered prepackaged meals.

• Key Factors to Consider for Prepackaged Foods vs. Meals

  • Weight Matters: If a product is ≥200g and is intended as a meal, it is classified as a prepackaged meal and follows the higher threshold.
  • Single Component vs. Multiple Components: Single ingredient or snack foods fall under prepackaged foods, whereas a combination of protein, grains, and vegetables would likely be a prepackaged meal.

Manufacturers should carefully review Health Canada’s classification guidance to ensure accurate labeling and compliance before the January 1, 2026 deadline.

Special Thresholds for Small Packages

For prepackaged foods in small packages (≤30 g or ≤30 mL), the nutrient thresholds are set at 10% of the Daily Value (DV) for saturated fat, sugars, and sodium, instead of the standard 15%. This lower threshold ensures that even small portion sizes contribute proportionally to consumer awareness of high-nutrient content.

Exemptions

While the new Front-of-Package (FOP) Nutrition Labeling Regulation applies to most prepackaged foods, certain products are exempt from displaying it. These exemptions are based on the nutritional nature of the food, regulatory consistency, and practicality.

Here are some examples of foods exempt from displaying the FOP Symbol:

• Whole, Unprocessed Foods
  • Fresh, frozen, canned or dried fruits and vegetables, such as apples, carrots, and leafy greens.
  • Raw, single-ingredient meats, poultry, and seafood without added sodium or fats.
  • Whole eggs, as they are a whole food source of protein.
• Certain Dairy Products
  • Whole milk, cheese, and yogurt with naturally occurring saturated fats and sodium.
  • These are exempt due to their role in a balanced diet and their nutrient-dense composition, including calcium and protein.
• Other Special Cases
  • Small packages (< 15 cm² available display surface) that cannot reasonably fit the FOP symbol.
  • Foods with protected status, such as butter and honey, which are minimally processed and have traditional dietary roles.
  • Shipping containers if not sold as a single unit to a consumer at retail.
  • Foods served by a restaurant, a commercial entreprise or institution.

Rationale Behind These Exemptions

• Encouraging Whole Foods: Health Canada aims to promote the consumption of unprocessed, nutrient-dense foods rather than discouraging their intake with warning labels.
• Recognizing Nutrient Contributions: Dairy products, for example, naturally contain saturated fat but are also key sources of calcium and protein.
• Practical Considerations: Small packages and single-ingredient products may not have the physical space for an FOP label or may already be subject to other regulations.

While these exemptions exist, most processed and packaged foods are still subject to the regulation.

Food manufacturers should review their product categories and product labels carefully now to determine if an exemption applies or if reformulation or label updates are necessary to ensure they meet these specifications before the January 1, 2026 compliance deadline.

FOP Symbol Format and Placement Requirements

To maintain consistency and ensure visibility, the regulation specifies:

• Size: The size and format of the FOP nutrition symbol vary based on the principal display surface with specific requirements for dimensions, buffer space, letter height, bar height, and magnifying glass size, including options for vertical, horizontal, bilingual, and unilingual formats.
• Placement: It must appear in the upper half of the principal display panel unless impractical (e.g., small packages).
• Contrast & Clarity: Black-and-white design to stand out against colored packaging.
• Bilingual Compliance: English and French versions must be included unless the package is only sold in one linguistic region by a local manufacturer.

D. What is the Context Behind Canada’s New FOP Labeling Regulation?

Before concluding, let’s share a bit of the background and context for this new FOP regulation.

The introduction of Front-of-Package (FOP) nutrition labeling in Canada is part of a broader effort to combat rising rates of diet-related diseases, including obesity, heart disease, and type 2 diabetes. Research shows that excessive intake of saturated fat, sugars, and sodium contributes to these health issues, increasing the burden on the healthcare system.

Health Canada’s Research and Consultations

Health Canada developed the FOP labeling system based on extensive scientific research and industry consultations. Studies indicate that clear, visible warnings on packaged foods help consumers make more informed choices and reduce intake of harmful nutrients.

This approach aligns with Canada’s broader Healthy Eating Strategy, which includes updates to Canada’s Food Guide, restrictions on food advertising to children and more.

International Practices and Their Impact

Canada is not the first country to adopt front-of-package labeling. Similar initiatives have been implemented globally with measurable effects:

• Chile (2016): The “black stop sign” warning labels led to significant reductions in the purchase of high-fat, high-sodium and particularly high-sugar foods. Read article: Chile Provides a Convincing Case for Mandatory Warning Labels on Processed Food
• United Kingdom (2013): The traffic light labeling system improved consumer awareness and encouraged reformulation of products by manufacturers.
• Australia & New Zealand (2014): The Health Star Rating system, a voluntary front-of-pack label, motivated brands to reduce sodium and added sugars in packaged foods.

By introducing mandatory FOP labels, Canada is aligning with international best practices while encouraging manufacturers to reformulate products to meet healthier standards. Businesses that proactively adjust their formulations now may gain a competitive advantage as consumer demand for healthier options grows.