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Health Canada Front-of-package Labelling: Dietitian Thoughts

Updated: Jul 19, 2022

For those of you who haven’t heard yet, Health Canada announced recently that that the Front-of-package nutrition labelling regulations are finalized. The Canadian food industry has until January of 2026 to modify their products (or not) to meet these new requirements. Moving forward, foods high in one of more of these nutrients: sugars, sodium, or saturated fats, will require a black and white symbol with a magnifying glass icon that highlights what the food is high in and/ or if there is a combination of the three.

*photos retrieved from Health Canada


This regulation is supported by the Minister of Health, Minister of Agriculture and Agri-Food, Diabetes Canada, Heart & Stroke Foundation and more. Other countries that have adopted this include: Chile, Peru, Israel, Mexico, Brazil. There are many advantages and disadvantages to an approach like this.




Introduction

As a Dietitian I know firsthand the power food can have it in our health. I completed clinical rotations in hospital settings where I provided high-quality disease management education to patients on foods high in sodium as it pertains to chronic kidney disease, fibre in the context of managing blood sugars in diabetes, sugar in the context of Eating Disorders and more! I have also interned at large CPG companies where I have worked with regulatory teams to help communicate the recent Serving Size regulatory changes to consumers to help them better understand, compare, and decide which products work best for them. So, it is safe to say I am a big advocate of evidence-based nutrition policies that may result in Canadians living more fruitful lives. However, with any policy there are many sides to consider. For the purpose of this blog post I will focus on the subtopics pertaining to this regulation 1) food insecurity 2) eating disorders 3) food industry.


Firstly, you should know that the Front-of-package labelling requirements are part of Health Canadas’ broader Health Eating Strategy, a Federal strategy that aims to improve the food environment in Canada to make it easier for consumer to make the healthier choice. Love it!


Health Canada aims to achieve this by doing the following three things 1) improving health eating information 2) improving nutrition quality of foods and 3) protecting vulnerable populations. The latter two initiatives include sodium reduction strategy, marketing to children initiatives.


I will link the Health Canada page here: which goes through everything you need to know about the FOP nutrition labelling requirements from why to nuances related to the nutrition symbol on the packages. For now just understand that the overarching purpose of the strategy is to reduce the risk of non-communicable chronic diseases such as: stroke, obesity, T2D, high blood pressure, some types of cancers and more. Currently across Canada two in five adults have chronic diseases such as heart disease or type 2 diabetes. According to news provided by Health Canada, it is estimated that over a ten year period a reduction of 400 mg per day of sodium would achieve 40,000 fewer cases of heart disease and 23,000 few cases of stroke annually. Pretty impressive!


Food (In)security

During my training to become a Registered Dietitian I was fortunate enough to have completed the MPH program at the Dalla Lana School of Public Health, University of Toronto. It was during that time where I completed courses in Public Health Nutrition and got to really delved into issues pertaining to individual versus population-based intervention strategies to support nutrition health. Within this course we examined the challenges in dietary assessment and planning, current controversies in nutrition policy, and importantly, an examination of an intervention related to food insecurity. This course provided compelling data around the Social Determinants of Health and how they play a role in accessing safe, affordable, and nutritious foods. One area we explored in-depth was around Household Food Insecurity.


Food Insecurity is defined as the inadequate or insecure access to food due to financial constraints. Food insecurity is a significant public health issue and is far more complex than most people think it is, the solution involves policy change.


Back in 2017, research showed that 1 in 8 households in Canada were food insecure which equals 4.4 million people, including more than 1.2 million children living in food-insecure households. As you could imagine, the makeup of household food security vastly impacts Indigenous status and racial/ cultural groups far more than white Caucasian populations. Other notable facts: food insecurity is higher among renters, living in the North, and working low-wage jobs/ precarious working conditions. Importantly, 60.4% of households are reliant on social assistance in Canada, and social assistance rates like WSIB are to low to help recipients cover basic needs.


“Compared to 9% of adults in food secure households, 34% of adults in severely food insecure households report a diagnosis of 3 or more chronic illnesses”


A recent article by Dai et al. that measured the Regional and socioeconomic disparities in CVD in Canada during 2005-2016. Authors reviewed nationwide cross-sectional surveys that analyzed the time-based trends and patterns of regional and socioeconomic disparities in CVD in Canada during 2005-2016. As expected, researchers found sustained absolute and relative SES inequalities in HD and stroke in Canada from 2005 to 2016 with heart disease more significant among men. This may suggest sex and gender and broader SDOH impact health status differently, however, no one specific cause linking SES and CVD has yet to be established.


Absolute= the probability or chance of an event measured by the number of events/ number of people in the group (most important)


Relative= is the ratio of the risks for an event for the exposure group to the risks for the non-exposure group.


Interestingly, research from Huisken, Orr & Trasuk, 2016 found that food insecurity is not a problem of food skills or shopping behaviours in adults. While research does show that adults experiencing food insecurity are more likely to use a budget when shopping for food, their behaviours related to shopping and preparation are like that of food secure individuals. Interesting, right?


So my thought here it is two-fold 1) is placing a symbol on the front of a package for foods that tend to be more processed, less nutritious, and cheaper really going to be an effective health promotion strategy given that Social Determinants of Health play a bigger impact than individual choices to health? If we know that those who experience chronic diseases tend to be lower income but might only be able to afford said products ie. chips, soda, processed and prepared snack foods how effective is this regulation really going to be. Not to mention, the impacts of inflation and rising food costs right now:

During the past year (April 2021 to April 2022), the price of food rose by 9.7%. Canadians had to pay much more for basic food staples, such as fresh fruit (+10.0%), meat (+10.1%) and fresh vegetables (+8.2%)

I hope research measuring the prevalence of Heart Disease and Stroke now versus in 2024, 2026, and 2028 shows a reduction in chronic disease in Canada, and until then Dietitians can continue to advocate for system changes that include: paid sick days, livable wages, regulated food costs.


Eating Disorders

Next, I would be remiss if I didn’t voice my concern and support for those struggling with disordered eating. I have been fortunate enough to study public health, while also working clinically as an RD over the past two years with the ED population and I can already feel the impact this will have on these folx.


First let's look at the quick facts:

  • 2.7 million Canadians meet the diagnostic criteria for an ED

  • Eating disorders have soared during the pandemic and NEDIC has seen a 250% increase in demand for its instant chat and toll-free helplines.

  • According to Psychiatry Advisor, Anorexia Nervosa, the most lethal mental health disorder, has more than doubled during the first COVID-19 wave in Canada.

Eating Disorders are a complex bio-psychosocial group of mental health disorders and while there is no one exact cause we have found that the pandemic has significantly increases in hospitalizations for adolescents. With a disruption in daily activity and routine, youth are spending more time on social media often falling prey to diet culture messages on platforms like Tik Tok and Instagram, which have been linked to disorders eating patterns.



Part of my work in Eating Disorders is working with clients to become more comfortable around ‘fear foods/’. Often when someone is struggling with this disorder restriction can be a hallmark of the disorder. Phobic foods are often the ones that tend to be percieved as processed high in sugar, foods high in fat and sodium etc. Of course this varies depending on the person, but ultimately in the pursuit of “clean eating” the ED will stop at nothing to convince someone these foods are ”bad”. Notably, a recent cross-sectional Harvard study of 1,294 students in 2018 found some similar results in student experiences with the traffic light system of labelling system:

“In survey, some respondents thought TLL’s put people at risk for developing eating disorders (16%) or exacerbating eating disorders (47%); 35% believed TLLs make recovery from an eating disorder more difficult”

The study also found that women were also more likely to report avoiding higher TLL label foods if they are perceived to influence shape or weight (49% vs. 37%, p=0.024)


While of course traffic light labelling is not identical to FOP labels proposed by Health Canada it is important to consider the impacts of labelling. Even though the intent is to empower health promotion, if someone struggling with an ED were to see a FOP label magnifying certain nutrients some may perceive this as a warning and be less inclined to adhere to their treatment plan. I have worked first hand with several students who feel triggered by calorie labelling in the dining hall of their university, often times restricting their overall food intake to avoid meeting their daily requirements due to fear of weight gain. As a non-diet dietitian, I strive to promote and embrace an “all foods fit” approach when it comes to my daily practice.


Finally, how does this impact the food industry?

First you should know that some food do not need to display a nutrition symbol, see that list here. Also, the food industry has until 2026 to finalize changes to their package, though consumers can see the labels on products prior to then. Previously, there was talk that Health Canada was considering putting a FOP label on ground beef labeling it high in saturated fat and sodium. This, of course, caused major backlash amongst the Canadian Cattle Association, farmers, and ranchers.


As a whole, the Canadian cattle and beef sector contributes $22 billion to GDP at market prices (2019-21), generating approximately 347,000 jobs in Canada either directly or indirectly, with every job in the sector yielding another 3.9 jobs elsewhere in the economy.


Having said that, this requirement was not implemented in order to preserve ground beef and poultry looking secondary to single whole cuts.

Credit: https://unsplash.com/photos/XgFFJKSPkNk?utm_source=unsplash&utm_medium=referral&utm_content=creditShareLink


I would imagine this regulation will have a bigger impact on small-medium side companies who will have to spend a lot of money with either reformulation or repackaging. I could also imagine Health Canada providing additional consulting work and/ or money to assist smaller companies in making these changes. The good news is producers have about 4 years to make these changes.


Take Away

The FOP regulation is part of Health Canada’s Health Eating Strategy, however, it is important to note that Health Canada is doing more than just this to help improve the food environment and help make the healthier choice the easier choice. You might also be aware of the Canada’s food guide makeover that happened Jan 2019 which also falls under the first goal, the hope is that FOP requirements will also align with the CFG recommendation to limit the consumption of highly processed foods. Banning industrial trans fats a few years back was another big win.


As a Public Health Dietitian I am a strong advocate for nutrition policy and change, specifically when it comes to ‘Protecting Vulnerable Populations’ and upcoming implementation around restrictions on the advertising of certain foods to children as part of the Forward Regulatory Plan 2022-2024 amendments to the Food and Drug Regulations


I do think these upcoming changes will have a positive impact of the health of Canadians, in conjunction with education, health literacy programming, and continued efforts focused on Canada’s First Poverty Reduction Strategy.


Regarding Eating Disorders, I always speak to my clients about the difference between public health recommendation versus clinical recommendations. In clinical settings, certain populations have very specific and unique nutritional and psychological requirements, therefore, it is imperative for clinicians to be able to empower, explain, and discuss how to clients can continue to safely navigate the food environment while in recovery. I’d also mention here that if parents are involved in caregiver support, they should absolutely be part in these conversations as well.


If you made it this far in the post, thank you so much for taking the time to read! I’d love to hear your thoughts on these upcoming Federal changes to food products. How do you feel about the changes? Leave me a comment below!


Yours in health,





References in no particular order:

  1. https://www.heartandstroke.ca/what-we-do/media-centre/news-releases/new-front-of-package-nutrition-labels-announced-for-canada

  2. https://www.newswire.ca/news-releases/government-of-canada-unveils-new-front-of-package-nutrition-symbol-800108024.html

  3. https://dash.harvard.edu/bitstream/handle/1/37067659/5893474.pdf?sequence=1&isAllowed=y

  4. https://oneill.law.georgetown.edu/the-food-minority-food-labels-eating-disorders-and-people-who-need-more-food/

  5. https://www.healthypeople.gov/2020/about/foundation-health-measures/Determinants-of-Health

  6. https://collections.ola.org/mon/31005/339601.pdf

  7. https://www.canada.ca/en/health-canada/corporate/about-health-canada/legislation-guidelines/acts-regulations/forward-regulatory-plan/plan/restricting-advertising-children-foods-contribute-excess-consumption.html

  8. https://proof.utoronto.ca/food-insecurity/

  9. https://www150.statcan.gc.ca/n1/pub/82-003-x/2022002/article/00002-eng.htm

  10. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8634236/

  11. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8634236/

  12. https://www.ctvnews.ca/health/new-study-paints-grim-picture-of-adolescent-anorexia-during-covid-19-pandemic-1.5697201

  13. https://dailyhive.com/vancouver/ground-beef-warning-label-health-canada

  14. https://iris.paho.org/bitstream/handle/10665.2/52740/PAHONMHRF200033_eng.pdf?sequence=6&isAllowed=y

  15. https://www.cbc.ca/news/politics/nutrition-warnings-food-1.6506855

  16. https://www.canada.ca/content/dam/canada/employment-social-development/programs/poverty-reduction/reports/poverty-reduction-strategy-report-EN.pdf

  17. https://www.canada.ca/en/health-canada/services/food-labelling-changes/front-package.html


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