You may regularly use a wide variety of natural health products, like vitamins, minerals, probiotics, herbal remedies, homeopathic and traditional medicines. Did you know that unlike pre-packaged foods, the labels for natural health products do not have the same requirements for providing ingredient information in plain, simple language or calling out priority food allergens? This is why over the past five years we have participated in ongoing consultations with Health Canada, to ensure food allergens would be included when labelling updates were being considered.
Health Canada is now proposing changes to the labelling on natural health products, specifically new requirements for allergen labelling. While we support their proposed changes, there are additional recommendations that are not currently addressed.
We need your help to ensure all recommendations get considered.
Before September 24th, 2021, let Health Canada know you support their proposed labelling changes to natural health products plus raise the need for additional changes.
Here’s what you need to know:
What’s included:
One of Health Canada’s proposed new regulations include the labelling of food allergens, gluten, and aspartame. Specifically:
“1. If a product contains a priority food allergen, gluten, or aspartame, a statement indicating the source of the food allergen, gluten or aspartame would be required on the product’s label.
2. If a priority allergen is used as a medicinal or non-medicinal ingredient, it is required to be listed in the Warnings section of the label, in bold. (e.g., “Allergy alert:” followed by the source of the food allergen or gluten).”
What’s missing:
There are additional recommendations that are not currently addressed. Help us ensure they get considered:
- Provide common names of all medicinal and non-medicinal ingredients – Make it easy to identify the food ingredients in a product, including priority allergens and other ingredients, given that you can be allergic to any foods. Having access to complete ingredient information is essential.
- No small package exemptions for ingredient information – Medicinal, non-medicinal, and allergy alert ingredient information should be required for all sizes of product packaging.
- Place all ingredient information together – Medicinal, non-medicinal, and allergy alert ingredient information should be placed together in the same location on the label. This makes it easier to find the information needed to make informed choices.
- Ensure access to ingredient information is available at point of purchase – It’s essential that all medicinal, non-medicinal, and allergy alert ingredient information is provided on the physical package and prior to or at point-of-sale for online purchases so those with food allergy have the information they need to avoid their allergens and make safe choices.
- Include sulphites as a priority allergen – Currently sulphites are not included as a priority allergen for the labelling of natural health products. Given that the allergen labelling requirements for food products apply to sulphites, they should be included for natural health products.
Next steps: How to provide your feedback
Let Health Canada know how important proper allergen labelling is on natural health products for those living with food allergy.
1. Read Health Canada’s consultation request: https://www.canada.ca/en/health-canada/programs/consultation-improved-labelling-natural-health-products-proposed-changes-regulations.html
2. Contact Health Canada before the deadline of September 24, 2021: Email hc.nnhpd.consultation-dpsnso.sc@canada.ca to provide your feedback. To make it easier, you can copy this paragraph:
“I am one of over 3 million Canadians impacted by food allergy and I support Health Canada’s proposed recommendations for allergen labelling on natural health products. However, there are many additional recommendations that should be considered to help me make informed choices and avoid having potential allergic reactions.
I would like Health Canada to consider including the following recommendations to ensure proper allergen labelling on natural health products: <cut and paste the points in the “What’s missing” section>.”
We will also be providing a written submission to Health Canada regarding our input on the new proposed regulations and additional considerations we would like them to include moving forward.