Re-evaluate high use substances on the Health Canada additives lists that are not included on the organic Permitted Substances Lists (PSL)
Assess processing techniques and aids that are not permitted in organic processing for sustainable diet implications
Ban substances with primarily cosmetic purposes
Re-evaluate packaging materials banned in Europe (that haven't been recently re-evaluated)
Use Threshold of Toxicological Concern (TTC) approach for by-products of additives and processing aids
Limit plastics
Improve labelling of additives
Re-evaluate high use substances on the Health Canada additives lists that are not included on the organic Permitted Substances Lists (PSL)
As part of organic certification, producers and processors must comply with a PSL that focuses on materials deemed less environmentally damaging than many conventional inputs and more health-promoting than many additives and processing aids. As such, the PSL represents something of an attempt to comply with sustainable diet requirements, certainly not perfect, but probably the closest regulated list with such intentions that we have in Canada.
Comparing the two lists is a bit difficult. The 15 Food Additives Lists from the Canadian Food Inspection Agency (CFIA) contain 441 items, while the comparable organic Permitted Substances Lists (PSL) have 111 (after removing duplicates and condensing synonymous terms). The organic permitted substances and their usages tend to be more generally defined than the CFIA standards, which explicitly state what food items the substances are permitted in or upon, and to what level/concentration. In contrast, the organic permitted substances are stricter on where a substance is sourced or originates from (these are typically limited to organic, biological sources, or if not available, exceptions apply). For example, in the Organic PSL, “colouring agents” are a permitted additive, with the main stipulation being that they must derive from “biological sources such as spices, annatto”, plant juices, etc. The CFIA is more specific, with a whole “List of Permitted Colouring Agents” containing 43 substances like carbon black, iron oxide, and indigotine. The organic PSL lists “microorganisms” from “agricultural or biological substances”, whereas the CFIA defines species and specific strains including “Saccharomyces cerevisiae CD15407, Saccharomyces cerevisiae Y63348,” and “Yarrowia lipolytica VRMS”. Sixty-nine substances are found on both lists, but there is likely more overlap because of broad, undefined categories or obvious substances on the organic PSL.
Table: Comparing the CFIA permitted additives against the organic PSL (source: Kennedy Halvorson)
| CFIA Lists | # of CFIA Substances | # of Organic Substances | Crossover |
| Class 1 Preservatives | 13 | 2 | 15% |
| Permitted Anticaking Agents | 16 | 4 | 25% |
| Permitted Bleaching, Maturing or Dough Conditioning Agents | 21 | 1 | 5% |
| Permitted Carrier or Extraction Solvents | 24 | 4 | 17% |
| Permitted Colouring Agents | 43 | 2 | 5% |
| Permitted Emulsifying, Gelling, Stabilizing or Thickening Agents | 107 | 25 | 23% |
| Permitted Firming Agents | 11 | 3 | 27% |
| Permitted Food Additives with Other Accepted Uses | 123 | 27 | 22% |
| Permitted Food Enzymes | 46 | 9 | 20% |
| Permitted Glazing or Polishing Agents | 12 | 3 | 25% |
| Permitted pH Adjusting Agents, Acid-Reacting Materials and Water Correcting Agents | 83 | 30 | 36% |
| Permitted Sequestering Agents | 27 | 7 | 26% |
| Permitted Starch-Modifying Agents | 26 | 3 | 12% |
| Permitted Sweeteners | 24 | 0 | 0% |
| Permitted Yeast Foods | 20 | 8 | 40% |
| Grand Total*** | 596 | 128 | |
| *** Many substances are found on multiple lists. For instance, Calcium Phosphate, allowable under both the CFIA and Organic standards, co-occurs on six lists, under multiple names. The crossover column is the minimum estimation of overlap of organic permitted substances on each CFIA list. It is the minimum because the CFIA lists multiple chemical forms of the same substance, while the organic just uses the general name. | |||
Many substances are not permitted on the PSL. Not included are most anti-caking and bleaching agents, such as acetone peroxide, benzoyl peroxide, Calcium Stearoyl-2-Lactylate, chlorine. potassium iodate, and sodium sulphite. Isopropyl alcohol is not permitted as an extractant unless exceptional circumstances prevail. For meat curing only extracts, juice or cultured powder of celery or chard are permitted, sourced from organic production if available, and the other curing agents including synthetic nitrites, are not permitted. Re-evaluations, within a sustainable diet framework, should begin with these above listed not permitted substances and then move to additional substances in categories where most CFIA materials are not permitted (see Table).
For more detailed information, the full dataset can be accessed here.
Assess processing techniques and aids that are not permitted in organic processing for sustainable diet implications (adapted from COG, 2020)
Organic processors are restricted in the processing techniques, aids, cleansers and sanitizers they can use relative to conventional processing. Highly processed ingredients are generally not permitted. Under the Canadian Organic Standards (8.1.3), mechanical, physical or biological processes (such as fermentation and smoking) are permitted, but chemical manipulation (hydrogenation, bleaching, hydrolysis, oxidation, denaturation and interesterification) is prohibited. Ionizing radiation is also prohibited but non-ionizing radiation (microwaves, ultra-violet rays and x-rays) is allowed, except to boil (7.2.14) or sterilize (7.2.12.2) maple syrup sold as syrup or used in maple products. Nanotechnology (1.4 b) is prohibited because it is a field of limited regulation and unknown risks. Fortification is prohibited unless required by federal regulation (milk, white flour, meal replacements and a few other products) or for non-dairy substitutes. No other organic foods can be enriched, including organic breakfast cereals, infant formulas and juice products.
Many cleansers and sanitizers are also not permitted (see Cleanser and sanitizer PSL).
Review of some of the techniques and aids are captured directly or indirectly in the first action above, but others do not require federal letters of no objection, so as a first step towards assessing these processing techniques and aids, Health Canada should commission independent third party assessments of their merits in a sustainable diet context.
Ban substances with primarily cosmetic purposes
Related to the first action, additives with primarily cosmetic purposes should start being removed from the list of permitted additives. This is part of a larger strategy to improve food literacy and reduce consumption of highly processed foods. The food industry will balk and Health Canada would have to treat their participation as they did with much of the renewal of the Healthy Eating Guidelines, that industry will not be viewed as a health stakeholder. The most likely products to start with are glazes and colourants, particularly those dyes in Europe that require a warning message about children. Obviously, a product re-evaluation would be required, but a main focus would be that the product should be removed unless it had a value beyond cosmetic perfection.
Re-evaluate packaging materials banned in Europe (that haven't been recently re-evaluated)
The CFIA used to maintain a Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products Database. Responsibility was transferred to Health Canada who no longer maintain the list. Manufacturers can continue to use materials on the reference list, but the list has not been updated since 2016. Now only packaging materials used in infant formula have to be pre-approved.
There is also no expiry on a letter of no objection (LONO) as long as the material remains as described in the original submission. HC does, however, have the right to rescind a LONO if new information comes to light. Any substance banned in the EU or the US but used in Canada should be subject to a regular re-evaluation. This does not mean that the substance will be banned but it should be automatically reviewed regularly given there would have to be some evidence of problems for it to be banned in another major jurisdiction.
There does not appear to be re-evaluation program for packaging of equivalent strength to that used by the PMRA for pesticides. Controversial packaging materials should be on a regular cycle of review (at least every 5 years). Any new uses for existing materials or new materials should require pre-approval as with infant formula.
Use Threshold of Toxicological Concern (TTC) approach for by-products of additives and processing aids
The TTC approach has been used in Europe for food flavourings (Serafimova et al., 2021). It can be applied to any chemicals with known structure, for which oral exposures can be evaluated, and toxicity data are scarce. Although several federal departments use the TTC approach for chemical contaminants, it's not clear Health Canada uses it as they do in Europe for food additive by-products, that is the unintended substances that appear as degradation products or the consequences of substance interactions. Since Health Canada already uses the approach in other contaminant areas, it should be relatively straightforward to apply it to such food additive by-products.
Limit plastics
A full ban on microplastics is not feasible at this stage, but numerous initiatives can be undertaken to reduce plastic in the food supply. See the proposals under Goal 5 Food Packaging Reduction.
Improve labelling of additives
In general additives must be labelled by their chemical name or approved synonym, although they can also labelled in groupings of related substances which to some extent hides the degree to which the product contains them in the absence of mandatory quantity identification (QUID, see Goal 1, Consumer Information Systems) in all but a few cases. However, the bigger issue is that there is no mandatory requirement to name the purpose of the additive, with the exception of function identifying language required for some sweeteners under specific circumstances. Under the CFIA current rules,
Manufacturers may voluntarily choose to include a function descriptor within parentheses following the specific common name of a food colour (e.g., "iron oxide (a food colour)", "iron oxide (a colouring agent)", "iron oxide (for colour)" or simply "iron oxide (colour)"). This statement of a colour's function would be additional information only and is not mandatory.
This must become a mandatory requirement for all additives and their functions, as outlined in the List of Permitted Food Additives with its 15 categories. In some cases, additives serve multiple purposes, so the most important one should be listed, rather than all of them.
Regarding processing aids, there is no requirement on the label to state that they have been used and for what purpose. This should become a mandatory requirement and the CFIA and Health Canada should devise standard statements under the FDR to be placed on the label, for example, "Clarifying or filtering agents [name specific agents] have been used in the processing of this fruit juice [or oil, vinegar, beer, wine and cider]". Since clarifying agents often reduce the nutritional value of the product, but extend shelf life and uniformity which suits the manufacturer, it is important for consumer under a food literacy agenda, to understand the implications.
