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U.S.A.-Canada Bilateral Labeling Guide

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U.S.A.-Canada Bilateral Labeling Guide U.S.A. – Canada Bilateral Labeling Guide For Retail, Master and Shipping Container Packaging of Fresh Fruits and Vegetables Prepared for Commerce in the U.S.A. and Canada Legal Notice U.S.A. CANADA • This guidance tool is designed to • CPMA makes every effort to ensure assist in development of produce that accurate information is provided labels for consumer packaging but cannot accept any responsibility and trade containers (shipping for any errors or omissions no matter and master containers) that are in how caused, including but not limited compliance with U.S.A. and/or to whether as a result of an error by Canadian food labeling CPMA or in change in policy by the regulations, including Quebec. Canadian Food Inspection Agency. • This document contains non- • It is important that members consult binding recommandations. It is the pertinent acts and regulations the obligation of the Responsible prior to developing its package and Party to ensure regulatory nutrition labels for the Canadian compliance of the products marketplace. introduced into commerce. 2 U.S.A. - Canada Bilateral Labeling Guide Version 1.0 December 2016 Legal Notice U.S.A. CANADA • This guide is for information • All information is provided “as is”, purposes only and is not without warranty or guarantee of intended to and does not any kind as to its accuracy, constitute legal advice. completeness, operability, fitness for • Readers with questions beyond particular purpose, or any other the scope of this guide may wish warranty, express or implied. to consult with qualified legal • CPMA shall not be liable for any counsel to ensure compliance damages, loss, expense or claim of with U.S.A. and/or Canadian law. loss arising from the use, or reliance on the information. 3 U.S.A. - Canada Bilateral Labeling Guide Version 1.0 December 2016 Table of Contents TOPIC Slide • Using The Guide 7 • Important Information 8-10 • Labeling Content Requirements Retail Packaging 11-42 Statement of Product Identity 12-13 Declaration of Net Quantity of Contents 14-17 Responsible Party/Signature line 18-19 Country of Origin Labeling (COOL) 20-22 Grade Designation 23-24 Ingredient Declaration 25-26 Allergens 27 Sulphites 28 44 U.S.A. - Canada Bilateral Labeling Guide Version 1.0 December 2016 Table of Contents TOPIC Slide • Retail Packaging (continued) Gluten Claims 29 Nutrition Labeling 30-32 Serving Size 33-35 Date Codes 36-37 Price Lookup (PLU)/GS1 DataBar 38-39 Universal Product Codes (UPC) 40-41 Exemptions 42 Storage Instructions – USA 43 Storage Instructions - Canada 44 • Additional Packaging Labeling Method of Production 45-50 GMO 46 Halal 47 Irradiation 48 Kosher 49 Organic 50 5 U.S.A. - Canada Bilateral Labeling Guide Version 1.0 December 2016 Table of Contents TOPIC Slide • Case Labeling Requirements 51-58 Master Containers 52 Shipping Containers 53-54 Recommended PTI Standard Label Information 55 RPCs - Reusable Plastic Container 56-58 • Label Content Requirements 59-60 Optional Information 60 • Glossary of Terms – Appendix A 61-62 • U.S.A. Resources – Appendix B 63-64 • Canada Resources – Appendix B 65-66 • Acknowledgements 67 66 U.S.A. - Canada Bilateral Labeling Guide Version 1.0 December 2016 Using The Guide • The Guide is designed to be a user-friendly tool for use by those involved in the design of fresh produce labeling and packaging to be shipped and distributed in the U.S.A. and/or Canada, including Quebec, for both consumer packaging and master containers (RPC and shipping containers). • The Guide will discuss and show with detailed graphics the requirements for labeling fresh-cut produce to be entered into commerce in both Canada and the U.S.A. 7 U.S.A. - Canada Bilateral Labeling Guide Version 1.0 December 2016 Important Information • This guidance tool is designed to assist in development of produce labels for consumer packaging and trade containers (shipping and master containers) that are in compliance with U.S.A. and/or Canadian food labeling regulations, including Quebec. • This document contains non-binding recommandations. It is the obligation of the Responsible Party to ensure regulatory compliance of the products introduced into commerce. • This guide is for information purposes only and is not intended to and does not constitute legal advice. • Readers with questions beyond the scope of this guide may wish to consult with qualified legal counsel to ensure compliance with U.S.A. and/or Canadian law. 8 U.S.A. - Canada Bilateral Labeling Guide Version 1.0 December 2016 Important Information • Every attempt has been made to ensure this Guidance Document is accurate, correct and is up-to-date as of September 2016. • Users should bear in mind that regulatory requirements and policies change over time and appropriate state and national regulations should be confirmed with the appropriate regulatory entities. • Multiple Canadian and U.S.A. Reference Source links are included throughout the guidance document with a comprehensive list in Appendix A. • A Glossary of terms is included in Appendix B. • In the U.S.A., with very few exceptions, full compliance with federal requirements will fulfill all state requirements. In any event, no state requirement can supersede a federal requirement. • States cannot discriminate against out-of-state products in a manner that burdens interstate commerce. 9 U.S.A. - Canada Bilateral Labeling Guide Version 1.0 December 2016 Important Information Continued- • As stated, this Guidance Document is not intended to provide legal advice. Specific labeling decisions should be based on a review of actual regulatory documents. • Food may be deemed to be misbranded if its labeling is false, misleading or deceptive in any particular way. • To meet language laws in Canada including Quebec*, all information, on or with consumer products must appear in both official languages (English and French) unless exempted**; the French translation must be of at least equal prominence*** to the English (or other languages, if present). *Reference sources are included throughout and at the end of this document. **Example: Proper names (such as Robert Smith) and addresses, and in general trademarked items, etc. ***Please reference GLOSSARY located at the end of the presentation. 10 U.S.A. - Canada Bilateral Labeling Guide Version 1.0 December 2016 Labeling Content Requirements Retail Package of Fresh Fruits and Vegetables Statement of Product Identity U.S.A. CANADA • Common name of food: • Common name of food: – Brand names are not statements – Apples must include variety name. of identity . • On the Principal Display Panel • On the Principal Display Panel (PDP). (PDP) and any alternate PDP. • In bold face type in a size • In both French and English. reasonably related to the most • Minimum height requirement of prominent printed matter on the 1/16 inch (1.6mm) based on a front panel at least ½ the size of the lowercase letter “o”. largest print on the package. • Exemption for common name on • Do not crowd required labeling package: those fresh fruits or with artwork or non-required labeling. vegetables that are easily visible or identifiable in the package (open • Exception for common name on or transparent package). package: bulk (commodity) produce sold at retail. FDA Reference: CFIA Reference: http://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsR http://www.inspection.gc.ca/food/labelling/food-labelling-for- egulatoryInformation/LabelingNutrition/ucm064872.htm industry/common-name/eng/1354906212164/1354906290936 12 U.S.A. - Canada Bilateral Labeling Guide Version 1.0 December 2016 Statement of Product Identity Examples of Common Name U.S.A. Example CANADA Example This is an example of a double sided pouch with English and French on opposite sides using same size font. 13 U.S.A. - Canada Bilateral Labeling Guide Version 1.0 December 2016 Declaration of Net Quantity U.S.A. CANADA • Must appear on Principal Display Panel • Must appear on Principal Display Panel (PDP). (PDP) in the bottom 30% of label. • Must be expressed in terms of weight, volume, • Must include Net Content on each PDP if or numerical count. (numerical count more than one. required for heads of cauliflower or lettuce, • Must be shown in both metric (grams, stalks of celery, ears of sweet corn, kilograms, milliliters, liters) and U.S.A. or greenhouse cucumbers of Canada No. 1 Customary System terms(ounces, pounds, grade) fluid ounces). • Only metric is required, however if U.S.A. • Metric statement either before or after or measure or Canadian measure is also used it above or below the U.S.A. customary must be grouped with the metric with no statement. intervening material and the metric units expressed first. U.S.A. measure where it is not • Presented in terms of largest appropriate equivalent to Canadian measure (e.g. unit of measure. volume) must be clearly stated as U.S.A. • Minimum type size is the smallest type size • Minimum letter height requirement is that is permitted based on the space according to the area of the principal display available for labeling. surface of the package. • Net Weight or Net Count of Package • Net quantity must be rounded to 3 figures, Contents, does not include packaging unless below 100 then it must be rounded to material. two figures. 14 U.S.A. - Canada Bilateral Labeling Guide Version 1.0 December 2016 Declaration of Net Quantity Continued- U.S.A. CANADA • Bold faced type, bilingual if wording used. Metric • Determine the height of the type by abbreviation symbols are considered bilingual and are measuring the height of the lower case case sensitive (lower case) with two exceptions: L for letter "o" or its equivalent when mixed litre and mL for mililitres may be used. No brackets, punctuation etc. A single space must be used to upper and lower case letters are used, separate the number from symbol.
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