Include a percentage daily value (%DV) for free sugar content in the Nutrition Facts table and in front-of-package labeling
Foods with significant levels of nutrients of concern can not use a disease-reduction claim
Restaurant menu labeling requirements based on a strengthened Ontario program (improved salt and energy and core nutrient information)
Restrict nutrients of concern in government procurement and food service, including para-governmental agencies such as schools and hospitals
Limit advertising of foods with significant levels of nutrients of concern in non-broadcast settings, such as facilities under government control or receiving significant government support
A Nutrition Resource Centre funded in every province, independently or through a public health institution
Remove zero - rated HST/PST status for table salt and refined sugar
Continue negotiating sector specific sodium reduction targets with industry (voluntary compliance)
Amend the Food and Drug Regulations to change the basis of the Daily Value (DV) for sodium in the Nutrition Facts table (NFT)
Include a percentage daily value (%DV) for free sugar content in the Nutrition Facts table and in front-of-package labeling
Total sugars must be placed on the Nutrition Facts table as per federal regulations (over the 5 year implementation period), with a %DV, but food manufacturers are not required to place a percentage daily value for free sugars on the nutrition facts table. Given that absence, there will not be front-of-pack labeling for free sugars, although total sugars have been included in FOP proposals (at a threshold of 15% of the DV, consistent with the nutrition facts table warnings). Voluntary claims are permitted for representations such as "unsweetened", "sugar-free", "no added sugar", "reduced sugar", and "lower in sugar". Each product must meet specified targets to be legitimate. Most of these are relative, eg., 25% less than the standard product.
There remains some debate about how much added sugar in the diet is advisable. The Canadian Heart and Stroke "... recommends you consume no more than 10% total calories per day from added sugars, and ideally less than 5%; that is, for an average 2,000 calorie-a-day diet, 10% is about 48 grams (or 12 teaspoons) of added sugars." The American Heart Association suggests 7.5% (36 g or 9 teaspoons) is a more suitable target for men and 6 teaspoons for women. The WHO covers both these targets with its recommendation of 6-10%. One US modelling study estimated that the implementation of a 2016 policy requiring added sugar information on labels had reduced new cancers by 30,000 and deaths by 17,000, with net savings of $1590 million in health care related expenses (Du et al., 2021). Another US modelling study found major health care cost reductions in heart disease and diabetes associated with the same policy change (Huang et al., 2019).
Health Canada needs to settle on a target they feel is supported by the evidence and use it. Adjustments can be made later as the evidence becomes clearer. The threshold for FOP labeling could be the same as the threshold for total sugars. FOP regulations were announced in 2022 but implementation by companies can be delayed until 2026.
Foods with significant levels of nutrients of concern can not use a disease-reduction claim
Federal rules permit disease-reduction claims on food packaging under specified circumstances, including for sodium and potassium, vitamin D and calcium, saturated and transfats, fruits and vegetables, and fibre. However, the rules for some of these claims permit significant levels of sugar and salt, meaning that one nutrient of negative concern may be reduced but not others, or a nutrient of positive concern may be augmented while nutrients of negative concern are still permitted. The rules should be amended so that all nutrients of negative concern are below a specified level. These levels can be taken from existing rules regarding reduced level claims, (eg. levels associated with "low in _____" claims).
Restaurant menu labeling requirements based on a strengthened Ontario program (improved salt and energy and core nutrient information)
Ontario passed the Healthy Choices Menu Act and regulations, implemented by food firms on January 1, 2017. It applies to all chain restaurants with 20 or more locations in Ontario. The regulation requires calorie information to be displayed on menus, labels and tags adjacent to the price. No other province has as developed an undertaking. While this is an important initiative, it also has a number of weaknesses that need addressing if such an approach is to be implemented across the country. An early evaluation of its impact suggested that in the first year of operation there were no significant changes to calorie levels in the menu items (Scourboutakos et al., 2019).
The Ontario Food and Nutrition Strategy reviewed a number of studies that concluded that menu calorie information is insufficient on its own to change choices, but when combined with consumer education, and more comprehensive label information, it can reduce consumption of nutrients of concern. This happens in part because when forced to label, food service operations are more likely to reformulate.
Food-EPI Canada (Ontario report) recommends that the provincial government, "Update the Healthy Menu Choices Act to provide additional information for sodium on menus, and implement a comprehensive menu labelling education campaign and added fiscal incentive for industries to reformulate. In addition, require chain food service providers to fully disclose amounts of energy and the 13 core nutrients found on the Nutrition Facts table per serving size in an online format". This should be done.
Online menus can be exempted from the regulation if they do not list the price. This exemption should be removed.
Chain restaurants with more than 20 outlets typically have the resources to implement such measures, but providing fiscal incentives to reformulate and label becomes more critical if the program is to be expanded to chains with less than 20 outlets and independent restaurants. The provincial government should create a modest contribution agreement program for small to medium enterprises to facilitate this transition.
A more robust program can then be a template for other provinces to follow. The FPT Task Group on the Provisions of Nutrition Information in Restaurants and Foodservices has not been active recently but needs to be resuscitated as a vehicle for expanding this approach to the other provinces.
Restrict nutrients of concern in government procurement and food service, including para-governmental agencies such as schools and hospitals
Nutrients of concern are very available in public facilities as a result of government food procurement programs that have not taken account of the quality of foods being purchased. This is particularly concerning for public day cares, schools, senior's facilities and health care institutions (Raine et al., 2018). Prior to hydrogenated oils being added to the List of Contaminants and other Adulterating Substances in Foods, the government of BC restricted procurement of foods with transfats. Some municipalities have also taken steps on a fuller suite of nutrients (Raine et al., 2018). But coverage has definitely been uneven across the country. Generally, international studies assessing impacts of procurement programs find that availability, sales and intake of healthy foods increases, especially when combined with other program elements such as price changes and eater education. However, evidence of improved health outcomes is mixed (Raine et al., 2018)
Admittedly, there are challenges. Procurement officers don't necessarily have structural linkages with nutritionists and, if they do,nutrition standards and policies may be unsuitably constructed for procurement or inconsistent. Public food preparation faciities may face logistical barriers (e.g. lack of cooks or proper kitchens in schools), or financial issues (food service has to be revenue neutral or positive in the unit budget model) (Raine et al., 2018).
All procurement officers in government and para-governmental faciltiies should be restricting (but not yet eliminating) purchase of foods that are high in nutrients of concern. Given a lack of information on nutrients of concern in foods (see other proposals, this section), elimination is not feasible. As well, governments must respect existing procurement contracts, so depending on the time periods of them, changing the rules will be a gradual process. The new guidance will need to be issued by the Dept of Public Works (federal) and provincial Management Boards, in consultation with their Ministries of Health. At the municipal and para-government agency levels, there are additional co-ordination challenges. In many municipalities, multiple government units are responsible for contracts with food service providers, so a uniform approach is more difficult. The task becomes more manageable with municipal procurement re-configuration (see Goal 1, Economic Development Strategies). Similarly, procurement in para-governmental agencies is often dispersed across multiple units, so a harmonized guidance is required. Some provinces have legislated food procurement initiatives (e.g., Ontario's Local Food Act), but these are generally weak instruments and it's not clear that they need to exist for action to be undertaken.
The federal government should develop procurement guidances, based on Healthy Eating Guidelines and Front of Pack labeling and disseminate them to all levels of government and key para-governmental agencies receiving government funding. All levels of government and associated agencies should have mandatory programs in place within 5 years.
Limit advertising of foods with significant levels of nutrients of concern in non-broadcast settings, such as facilities under government control or receiving significant government support
Restrictions for broadcast, internet and social media are discussed under Goal 1, Consumer Information Systems. However, as was an issue with tobacco promotion, sports and recreational facilities, public transportation, public facilities and entertainment venues have all been used to promote unhealthy foods with significant levels of nutrients of concern (e.g, signage, billboards, brand integration, product placement, give-aways, kiosks, point-of-sale materials). However, there is a growing sentiment that sponsorships from companies producing foods high in salt, sugar and fat are in comparable categories to tobacco, alcohol and betting companies that sponsor sport (Crompton, 2014). The focus at this stage would be on facilities under government control or private ones receiving substantial government support. The exclusion criteria for these nutrients would be based on rules set out for government food procurement. For private facilities receiving government funding, the rules would be part of the contract allocating funds.
General brand promotion (that is, not connected directly to a food or meal) would be a challenge since most food firms have multiple products and at this stage of transition, some would meet health criteria and others would not. The other consideration would be the effects of loss of private sector support on recreational activities, especially for children, since the loss of recreational opportunities would be counter-productive. All these matters would have to be part of the negotiations for facilities dependent on significant private and public funding. The motivation for private facilities is that being associated with products that are increasingly seen as socially undesirable can compromise their customer base (reputational damage), and that the loss of sponsor does not necessarily mean a less profitable enterprise (Crompton, 2014).
A Nutrition Resource Centre funded in every province, independently or through a public health institution
Nutrition work is generally underfunded relative to the needs, especially as these and related proposals are implemented. Certainly many municipal public health units have nutrition specialists, and provincial governments do as well, but this will not be sufficient to meet the needs, especially for actively advising small to medium companies (SMEs) that need nutrition advice (larger ones often have nutritionists on staff).
In Ontario, Nutrition Connections (formerly the Nutrition Resource Centre) is a project of the Ontario Public Health Association (OPHA). It serves as a nutrition resource for many organizations, although it can expand its reach by supporting more SMEs. BC Public Health Association has the Food Security Gateway, though it is a more passive online information resource. Other public health associations have the foundations of what is needed.
Food-EPI Canada (Ontario report) recommends "Continue funding for the Nutrition Resource Centre as a health promotion resource centre for Ontario that supports capacity for planning, implementing and evaluating evidence-based healthy eating and nutrition, health promotion interventions across Ontario". Each province should provide comparable funding.
Remove zero - rated HST/PST status for table salt and table refined sugar
Basic groceries are zero - rated for HST/PST, so no sales tax is paid on them. Table salt and refined sugar are included in the zero rating category. Table salt (but not curing and pickling salt which are used in home food preservation) and refined table sugar (but not other sweeteners such as honey and maple syrup) should no longer be considered a basic grocery item and should have their status changed to the provincial / harmonized tax rate. This may not significantly reduce purchase but sends a signal that these items are no longer considered a basic necessity. Many snack foods and baked goods (high in sugar, fat and salt) are already paying full sales tax, so this places table salt and refined sugar in the same category.
Continue negotiating sector specific sodium reduction targets with industry (voluntary compliance)
A main recommendation of the Sodium Working Group (2010) was to negotiate voluntary and phased reductions with the food industry, based on targets by food category. In setting the targets, food safety, quality and consumer acceptance were taken into account. A 2017 evaluation of efforts covering 2012-16 produced disappointing results, with only 14% of food categories meeting the Phase III target reduction. Almost 50% of categories had made no progress, and in fact sodium levels in some categories had increased. Other categories had met either Phase I or Phase II targets. Many of the categories with no to minimal progress were in snacks, baked goods, prepared meals, condiments, sauces and dips, prepared meats, and seasonings.
Negotiations with food service and meal replacement firms were announced by Health Canada in October 2016, but it is not clear how well these have been implemented or what their successes have been.
The evaluation concluded, however, that voluntary efforts were worth continuing, in combination with stronger measures, some of which have been implemented since the evaluation was conducted, and others are soon to be, including some of the initiatives proposed on this site.
Amend the Food and Drug Regulations to change the basis of the Daily Value (DV) for sodium in the Nutrition Facts table (NFT)
Sodium is required on the Nutrition Facts Table, including reporting as a percentage of Daily Value (FDR B.01.401). The problem is the reference value, 2300 mg. The Sodium Working Group recommended the Adequate Intake level be changed to 1500 mg, based on their review of the literature. This must be implemented.
