1 Révision 1

Révision 1

Contents

1 Basic labelling standards ______4 1.1 Wine ______5 1.2 Beer ______6 1.3 Cider ______7 1.4 Spirits ______8 1.5 Unstandarized alcoholic beverages______9 1.6 Batch (lot) number ______10 1.7 Character height ______10 1.8 Language ______10 1.9 Refundable deposit ______10 1.10 Best before and expiry date ______11 2 Information relating to allergies and intolerances ______11 2.1 May contain allergens ______12 2.2 Allergen-free ______12 3 Sustainable development ______12 3.1 Organic products ______12 3.1.1 Standards recognized in Canada ______12 3.1.2 Labelling of organic products ______13 3.1.3 Prohibited wordings ______14 3.2 Biodynamic products ______14 3.3 Natural wines ______14 3.4 Fair-trade products ______14 3.5 Integrated farming ______15 3.6 Sustainable development ______15 3.7 Environmental claims ______15 4 Health claims and other warnings ______15 4.1 Health claims ______15

4.2 Alcohol consumption warning ______15 4.3 Standard drinks (UK units or standard drinks of alcohol) ______16 5 Dealcoholized or low-alcohol beverages ______16 5.1 Alcohol by volume declaration ______16 5.2 Ingredients permitted in dealcoholized wines ______17 6 Other labelling concepts ______17 6.1 “Product of Canada” and “Made in Canada” claims ______17 6.1.1 Product of Canada ______17 6.1.2 Made in Canada ______17 6.1.3 Other Canadian content claims ______17 6.2 Nutrition facts table ______18 6.3 List of ingredients ______18 6.4 Low-calorie and calorie-reduced drinks ______19 6.5 Proof ______19 6.6 Imported by an organization other than the SAQ ______19 6.7 Artificial flavours and graphic representation ______20 7 Packaging ______20 7.1 Tamper-proofing of containers ______20 7.2 Standardized container size ______20 7.3 Alternate containers ______20 Appendix 1 Batch (Lot) Number Guidelines ______22 Appendix 2 Tamper-Proofing of Containers ______23

Note to the reader This guide is intended to assist the SAQ’s suppliers and their agents in labelling their products in accordance with the labelling standards in effect in Quebec and Canada. In the event of divergence between this guide and an existing law or regulation, the law or regulation shall prevail. Please note that this guide covers the labelling concepts generally used for alcoholic beverages and is not necessarily exhaustive.

Blue highlighting is used to indicate documents and websites that can be referred to for more information.

1 Basic labelling standards

The diagrams on the following pages are a graphical representation of the main labelling requirements for various types of products. All labelling information is mandatory. The subsequent sections of this guide cover other labelling-related issues.

Please note that some of the information must appear on the main label, while other information may be placed on the main label or the back label.

Food and Drugs Act

Food and Drugs Regulations

Food Labelling for Industry

Act Respecting the Sale and Distribution of Beer and Soft Drinks in Non-returnable Containers

Regulation Respecting Cider and Other Apple-Based Alcoholic Beverages

Product Identification Standards for Use in the Distribution of Beverage Alcohol

1.1 Wine

Brand name: Regulatory, geographic Must not cause confusion and traditional as to the type or origin of Product’s brand name designations: Can be in the product. the language of the country 2010 of origin if in compliance with that country’s Controlled appellation regulations. Grape variety Common name: Country of origin: Mandatory in French and Mandatory in French and English. Vin Wine English. Produit de France Product of France Alcohol by volume (actual 12% alc./vol. 750 ml Net contents (volume): alcohol): Mandatory with Mandatory in millilitres (ml the unit “X% alc/vol”, “X% or ML) if the container size alc./vol.”, “alc. X% vol.” or is less than 1 litre and in “alc X% vol”. litres (l or L) for containers 1 litre or larger in size.

Allergen warning: Contient des sulfites Contains sulfites Mandatory in French and English. See section 2 of this guide for more information.

Supplier’s name: Supplier’s name Supplier’s address: Mandatory. It is the name of Mandatory. Must at the very the product’s manufacturer Supplier’s address, city, country least include the name of or of the company the the city and country.1,2 product was made for. Lot 180219 Batch number or production code: Mandatory on the bottle or CUP/EAN code: label. See Appendix 1. Mandatory.

The mandatory common name, country of origin, alcohol by volume and net contents information must be grouped together in a single visual field. They may be located on the main label or the back label.

1. For Canada and the United States, the name of the province or state can replace the country name. 2. An alphanumeric code, such as the European postal code, is not an acceptable way of stating the supplier’s address.

1.2 Beer

Brand name: Common name: Must not cause confusion Mandatory on the main label, in as to the type or origin of Product’s brand name French and English, as per the the product. category (bière extra-légère/extra light beer 1.1% to 2.5% alc./vol., bière légère/light beer from 2.6% Bière forte Strong beer to 4.0% alc./vol., bière/beer from 4.1% to 5.5% alc./vol., bière forte/strong beer from 5.6% to 8.5% alc./vol., bière extra- forte/extra strong beer 8.6% alc./vol. or higher). Alcohol by volume (actual 8.6% alc./vol. 341 ml Net contents (volume): alcohol): Mandatory with Mandatory in millilitres (ml or ML) the unit “X% alc/vol”, “X% if the container size is less than 1 alc./vol.”, “alc. X% vol.” or litre and in litres (l or L) for “alc X% vol”. containers 1 litre or larger in size.

Batch number or Lot 180219 Refundable deposit: production code: Mandatory as shown here, with Mandatory on the bottle or characters at least 4 mm (12 label. See Appendix 1. points) in height. The amount of QUÉBEC 5¢ CONSIGNÉE/REFUND the deposit is 5¢ for cans* 450 ml and smaller, 10¢ for glass bottles 450 ml and smaller and 20¢ for all containers larger than 450 ml.

Supplier’s name: Supplier’s name Supplier’s address: Mandatory. Mandatory. It is the name of Must at the very least include the Supplier’s address, city, country 3,4 the product’s manufacturer name of the city and country. or of the company the product was made for. Lot 180219 Batch number or production code: Mandatory on the bottle or label. See Appendix 1. CUP/EAN code: Mandatory.

*For cans, the refundable deposit must be shown on the top of the container.

3. For Canada and the United States, the name of the province or state can replace the country name. 4. An alphanumeric code, such as the European postal code, is not an acceptable way of stating the supplier’s address.

1.3 Cider

Country of origin: Brand name: Mandatory in French and Must not cause confusion English on the main label. Produit du Québec Product of Québec as to the type or origin of the product. Product’s brand name

Common name: Cidre fort Strong cider Designation of Mandatory in French and effervescence: Mandatory English on the main label on the main label, if and according to the applicable. Crackling, category (cidre/cider, cidre Cidre mousseux Sparkling cider aromatisé/flavoured cider, Crackling carbonated, cidre apéritif/aperitif cider, Sparkling, Sparkling etc.). Carbonated.

Alcohol by volume (actual 12% alc./vol. 750 ml Net contents (volume): alcohol): Mandatory on the Mandatory on the main main label with the unit “X% label in millilitres (ml or mL) alc/vol”, “X% alc./vol.”, “alc. if the container size is less X% vol.” or “alc X% vol”. than 1 litre and in litres (l or L) for containers 1 L or larger in size.

Allergen warning: Contient des sulfites Contains sulfites Mandatory in French and English. See section 2 of this guide for more information.

Supplier’s name: Supplier’s name Supplier’s address: Mandatory. It is the name of Mandatory. Must at the very the product’s manufacturer Supplier’s address, city, country least include the name of 5 6 or of the company the the city and country. product was made for.

(For cider made in Quebec, (For cider made in Quebec, it is the address of the cider it is the name of the permit maker permit holder that holder that must be shown. must be shown.) The number of the permit under which the cider is made must also be included.) L180219 Batch number or production code: Mandatory on the bottle or CUP/EAN code: label. See Appendix 1. Mandatory.

5. For Canada and the United States, the name of the province or state can replace the country name. 6. An alphanumeric code, such as the European postal code, is not an acceptable way of stating the supplier’s address.

1.4 Spirits

Common name: Brandy Country of origin: Mandatory on the main Mandatory on the main label in French and English. label in French and English Produit de France Product of France for wine-based eaux-de-vie entirely distilled in a country other than Canada.

Alcohol by volume (actual Net contents (volume): alcohol): Mandatory on the Mandatory on the main main label with the unit “X% 40% alc./vol. 750 ml label in millilitres (ml or mL) alc/vol”, “X% alc./vol.” or if the container size is less “alc. X% vol.”. than 1 litre and in litres (l or L) for containers 1 L or larger in size.

Allergen warning: Contient (nom des Contains (names of Mandatory in French and English. See section 2 of allergènes) allergens) this guide for more information.

Supplier’s name: Supplier’s name Supplier’s address: Mandatory. It is the name of Mandatory. Must at the very the product’s manufacturer Supplier’s address, city, country least include the name of or of the company the the city and country. The product was made for. address may be shown in the language of the country 7 8 of origin. ,

L180219 Batch number or production code: Mandatory on the bottle or Code CUP/EAN: label. See Appendix 1. Mandatory.

For Armagnac, cognac, tequila, mezcal, Scotch whisky and Irish whiskey bottled in Quebec, the country of origin and permit number must also be included.

7. For Canada and the United States, the name of the province or state can replace the country name. 8 An alphanumeric code, such as the European postal code, is not an acceptable way of stating the supplier’s address.

1.5 Unstandarized alcoholic beverages9

Brand name: Common name: Must not cause confusion Mandatory in French and as to the type or origin of Product’s brand name English on the main label. the product. Boisson alcoolique aromatisée aux fraises Strawberry flavoured liquor

Alcohol by volume (actual 18% alc./vol. 750 ml Net contents (volume): alcohol): Mandatory on the Mandatory on the main main label with the unit “X% label in millilitres (ml or mL) alc/vol”, “X% alc./vol.”, “alc. if the container size is less X% vol.” or “alc X% vol”. than 1 litre and in litres (l or L) for containers 1 L or larger in size.

Allergen warning: Contient (nom des Contains (names of Mandatory in French and English. See section 2 of allergènes) allergens) this guide for more information.

List of ingredients: Ingrédients: Alcool, Sucre (sucre, jus Mandatory in French and English in decreasing order de fraise), Sulfites, Rouge Allura of proportion. Ingredients: Alcohol, Sugar (sugar, strawberry juice), Sulphites, Allura Red

Supplier’s name: Supplier’s name Supplier’s address: Mandatory. It is the name of Mandatory. Must at the very the product’s manufacturer Supplier’s address, city, country least include the name of or of the company the the city and country. The product was made for. address may be shown in the language of the country 10 11 of origin. ,

L180219 Batch number or production code: Mandatory on the bottle or CUP/EAN code: label. See Appendix 1. Mandatory.

Note: The refundable deposit is mandatory for beer-based alcoholic beverages. It must be in characters at least 4 mm (12 points) in height. The amount of the deposit is 5¢ for cans 450 ml and smaller, 10¢ for glass bottles 450 ml and smaller and 20¢ for all containers larger than 450 ml.

9. Unstandardized alcoholic beverages are all beverages for which no legal definition is found in the Canadian Food and Drug Regulations. 10. For Canada and the United States, the name of the province or state can replace the country name. 11 An alphanumeric code, such as the European postal code, is not an acceptable way of stating the supplier’s address.

1.6 Batch (lot) number

A batch number is a series of numbers of letters, which often refers to the production date and is printed on bottles and cases to assure traceability of the batch.

The manufacturer’s batch number is mandatory on all products. Using batch numbers is a good manufacturing practice and we encourage all our suppliers to include one on their bottles. Appendix 1 contains recommendations regarding batch numbers.

Note: The Safe Food for Canadians Regulations, which will enter into force soon, will require having in place a traceability system that makes it possible to track the movement of food products. We strongly recommend that all our suppliers have such a system in place before the regulations enter into force.

1.7 Character height

The characters must be at least 1.6 mm in height, except for the net contents numbers, which must be at least 3.2 mm in height. Character height is based on the height of the lowercase o.

Different requirements may apply depending, for example, on the available surface on small containers and packaging.

Food and Drug Regulations

1.8 Language

All information and wordings included on the main label, back label, neck label and packing carton or affixed to the container and appearing in a language other than French must also be printed in French in characters of equal or greater height than those of the wordings in the other language. In addition, all descriptive marks and informative wordings in a language other than French must be translated into French.

Charter of the French Language

1.9 Refundable deposit

Mandatory only for beer and beer-based (malt) alcoholic beverages. The wording must be “QUÉBEC X¢ CONSIGNÉE / REFUND” in characters at least 4 mm (12 points) in height. The amount of the deposit is 5¢ for cans 450 ml or smaller, 10¢ for glass bottles 450 ml and smaller and 20¢ for all containers larger than 450 ml.

The refundable deposit must be shown on the top of cans.

The refundable deposits applicable in other jurisdictions are not allowed on labels, irrespective of the type of product.

Act Respecting the Sale and Distribution of Beer and Soft Drinks in Non-returnable Containers

1.10 Best before and expiry date

Products with a short life span and products with a best before date must be sold within their estimated life span. The SAQ must therefore ensure they have a reasonable sales period in its sales network.

The SAQ considers products whose estimated life span is less than one year to be products with a short life span.

A best before date is required for bag-in-box (BIB) products. The best before date must allow for a life span of 10 months from the bagging date.

For imported products, the SAQ requires that the time period between the best before date estimated or shown on the container and the order pick-up date be greater than nine months. Any product not meeting this requirement will be sold by the SAQ until its best before date. The product will then be pulled from the outlets and all products in inventory, including in the warehouses, will be destroyed (handling, disposal). The fees for non-compliant products will then be billed to the supplier.

2 Information relating to allergies and intolerances

The declaration of allergens on labels of alcoholic beverages is mandatory in Canada. The substances covered by the regulation are listed in Table 1.

Food and Drug Regulations

Table 1

List of allergens covered by Canadian regulations Almonds Pecans Sesame seeds Soybeans Gluten* Brazil nuts Pine nuts Wheat Shellfish Sulphites** Cashews Pistachios Triticale Fish Hazelnuts Walnuts Eggs Molluscs Macadamia nuts Peanuts Milk Mustard seed *Gluten from the following grains: barley, oats, rye, triticale, wheat, kamut and spelt. **When the total amount of sulphites in the pre-packaged product is 10 ppm or more.

The presence of allergens can be declared either in the ingredients list or in wording that begins with “Contient… / Contains….” The wording must be in both French and English. Please note that fining agents such as egg whites, casein and isinglass must be declared using the wording “Contient de l’œuf / Contains eggs,” “Contient du lait / Contains milk” and “Contient du poisson / Contains fish” to make them more understandable to consumers.

However, for pre-packaged beer, ale, stout, porter and malt liquor, the allergen alert is mandatory only if a list of ingredients also appears on the label.

For vintage-dated products, the allergen alert is required for products from the 2012 vintage and all subsequent vintages.

It should be noted that for products considered as possibly containing undeclared allergens, the SAQ may ask its suppliers to fill out an allergen declaration form.

2.1 May contain allergens

This type of wording may encourage the abusive use of precautionary labelling. Health Canada will soon finalize rules governing this practice. At present, we do not accept such wording on the products that we sell.

2.2 Allergen-free

This notion may be confusing to consumers. Stating that a product does not contain allergens or sulphites may lead consumers to think that other similar products must contain them.

For example, the wording “sulphite-free” on a bottle of Japanese sake may confuse consumers about other Japanese sakes that do not have the wording on their labels (sulphite use is prohibited in sake-making in Japan).

3 Sustainable development

3.1 Organic products

Various laws and regulations in Quebec and Canada govern the use of the term “organic” and its terminological equivalent “ecological.” For a product distributed by the SAQ to be considered organic, it must comply with these laws and regulations. Furthermore, the supplier must be able to provide a certificate attesting to its organic status in conformance with the Canadian Organic Products Regulations and the Act Respecting Reserved Designations and Added-Value Terms.

3.1.1 Standards recognized in Canada

Organic products regulations have been in force in Canada since June 30, 2009. The regulations require that, to be sold on Canadian territory, organic products must be certified in compliance with the Canadian Organic Regime (COR) or any other standard for which there exists an equivalency arrangement with Canada. The certification bodies that issue the certificates must be accredited by the competent authorities in the country where the standards apply.

Organic Products Regulations

The following table lists the countries for which an equivalency arrangement exists. The recognized standards and the names of the government agencies responsible for accrediting the certification bodies are also listed.

Country Standard Government agency responsible for accrediting certification bodies Canada Canadian Organic Regime (COR) Canadian Food Inspection Agency (CFIA) United National Organic Program (NOP) United States Department of Agriculture States (USDA) Europe (EC) No. 834/2007 Direction Générale de l’Agriculture et du (EC) No. 889/2008 Développement Rural (EC) No. 1235/2008 Japan Japanese Agricultural Standards Food Safety and Consumer Affairs Bureau Switzerland Switzerland’s Organic Farming Office fédéral de l’agriculture (OFAG) Ordinance Costa Rica Organic Agriculture Regulation – Servicio Fytosanitario del Estado Decree No. 29782 from Ministry of Agriculture and Livestock

3.1.2 Labelling of organic products

Prior to printing your labels, you must submit the mock-ups to your certification body for validation. The body must ensure that the specific requirements of the organic regulations and standards of the country where your ordered products will be sold are complied with.

A) Organic product (>95% organic products):

The following are mandatory:

• The wording “Biologique / Organic” • Name of the company that holds the product’s certificate • The wording “Certifié par… / Certified by…” or “Certifié biologique par… / Certified organic by…” followed by the full name of the certifying body.12 • Identification of the organic ingredients in the list of ingredients (if applicable).

Logos are optional (e.g. Bio Canada, USDA Organic, etc.)

B) Organic product 70% to 95% of whose contents are organic ingredients:

The following are mandatory:

• The wording “Produit contenant x% d’ingrédients biologiques / x% organic ingredients” • Name of the company that holds the product’s certificate • The wording “Certifié par… / Certified by…” or “Certifié biologique par… / Certified organic by…” followed by the full name of the certifying body.12 • Identification of the organic ingredients in the list of ingredients.

12. Use of the certification number alone (e.g. FR-BIO-01, IT-BIO-009, DE-ÖKO-03) is not acceptable. Also, use of the logo of the certification body does not replace the requirement that the full name of the certifier be listed after the wording “Certified by…”.

The list of ingredients must allow the organic ingredients to be distinguished from the non-organic ingredients. However, the size, colour and style of the characters must be similar to those used for the declaration of non-organic ingredients.

Examples:

Ingredients: Vodka*, Sugars (grapefruit juice*, sugar), Citric acid, Natural flavours (*organic).

Ingredients: Organic Vodka, Sugars (organic grapefruit juice, sugar), Citric acid, Natural flavours.

Please note that any reference to the organic production method in a text is unacceptable if the product is not certified organic in compliance with the laws and regulations in effect.

3.1.3 Prohibited wordings

The following wordings are not allowed on the labels of organic products in Canada:

• “Wine made from organic grapes” or equivalent wordings13 • “100% organic” • “Certified organic” without mention of the certifier • “Made with organic (ingredient name)” or “Made using organic ingredients” • “Converting to organic farming” or equivalent wordings.

3.2 Biodynamic products

You must be able to provide us with a certificate issued by a competent body supporting such a claim. In addition, your product must be certified organic in compliance with Canadian regulations.

3.3 Natural wines

The SAQ requires that the wines identified as “natural” that it sells be certified organic in compliance with Canadian regulations.

3.4 Fair-trade products

The labels of fair-trade products can carry the Fairtrade Canada mark and the wording “”Certifié Équitable / Fair Trade Certified” may be written on the label. Use of the FAIRTRADE logo is not mandatory. You must be able to provide the certificates proving your compliance with the fair-trade rules.

Fairtrade Canada

13. Only the wording “Vin biologique / Organic Wine” is acceptable in Canada. However, for vintage products made before 2010 (made before the year in which the regulations entered into force), we will accept the working “Wine made from organic grapes”.

3.5 Integrated farming

This notion – also known as integrated production – is not regulated in Canada. However, if you want to include this wording on a label, you must be able to provide a certificate issued by a competent body supporting such a claim.

3.6 Sustainable development

This notion is not regulated in Canada. However, if you want to include this wording on a label, you must be able to provide a certificate issued by a competent body supporting such a claim.

3.7 Environmental claims

By “environmental claims” we mean all declarations, other than organic and fair trade, that are regulated by their own body. Examples of this would be the use of lightweight glass in bottle manufacturing, recycling of manufacturing materials or energy conservation.

Environmental claims may not be misleading or confusing. They must be accurate, true and verifiable. We reserve the right, if necessary, to require that you provide authenticating documents (certificates or other) and to question you about your practices. We refer you to Environmental Claims: A Guide for Industry and Advertisers, which is published by the Canadian Standards Association.

Environmental Claims: A Guide for Industry and Advertisers

4 Health claims and other warnings

4.1 Health claims

By “health claim” we mean any wording that could imply that the consumption of alcoholic beverages has a beneficial effect on one’s health. No wording of this type is acceptable on the labels of alcoholic beverages that we distribute.

Code of Ethics of the Alcoholic Beverage Industry in Quebec

4.2 Alcohol consumption warning

Warnings regarding the consumption of alcohol, such as the U.S. government warning or the European warning about consuming alcohol during pregnancy, are acceptable if they are provided in French.

CFIA decision regarding the labelling of alcoholic beverages

The acceptable French translation of the U.S. government warning is as follows:

AVIS GOUVERNEMENTAL : Selon le chef de santé des États-Unis, les femmes ne devraient pas consommer de boissons alcoolisées pendant la grossesse vu le risque de malformation congénitale. La consommation de boissons alcoolisées diminue la capacité de conduire un véhicule ou d’utiliser de la machinerie et peut causer des problèmes de santé.

4.3 Standard drinks (UK units or standard drinks of alcohol)

When the notion of a drink or standard serving is referred to on the label, it must correspond to the definition of a standard drink or serving found in Canada’s Low-Risk Alcohol Drinking Guidelines issued by the Canadian Centre on Substance Abuse (CSSA), in which a drink means a volume of an alcoholic beverage that contains 13.5 g or 17.05 ml of pure alcohol14. In specific cases where the container corresponds to a single drink, the volume of the container must be used to define the drink.

The notional standard drink is defined differently in different countries. As a result, descriptions of this type, whose definition is likely to be unknown to consumers, risk creating confusion or being misunderstood. Accordingly, wordings such as “standard drinks” are not authorized in Canada.

For the same reasons, the logos and warnings of the British body Drinkaware.co.uk are not acceptable.

In addition, the maximum serving sizes recommended by the body are different from those in Canada’s Low-Risk Alcohol Drinking Guidelines issued by the Canadian Centre on Substance Abuse (CCSA).

These logos and warnings risk confusing consumers or being wrongly interpreted by them.

5 Dealcoholized or low-alcohol beverages

In Canada, to be considered a dealcoholized or low-alcohol wine, a wine must contain less than 1.1% alcohol. Accordingly, a wine whose alcohol by volume is 1.1% is not considered “dealcoholized” and would have to be described by a common name such as “partially dealcoholized wine.”

Food and Drug Regulations

CFIA decision regarding the labelling of alcoholic beverages

5.1 Alcohol by volume declaration

The alcohol content must be printed on the label in the form “…% alc./vol.” or, if the product contains less than 0.5% alcohol, in the form “Less than – Moins de 0.5% alc./vol.”

14. Alcohol and Health in Canada: a Summary of Evidence and Guidelines for Low-Risk Drinking, page 15.

If the alcohol content is 0.5% or less, the product is not considered an alcoholic beverage and a nutrition facts table must be included on the label.

5.2 Ingredients permitted in dealcoholized wines

Any ingredients that are permitted in “wine” (B.02.100 of the Food and Drug Regulations) are permitted in “dealcoholized wine.” However, ingredients added directly to the dealcoholized wine after dealcoholization must be declared in the list of ingredients (e.g. dealcoholized wine, sugar, glucose).

If ingredients are added that are not permitted to be added to “wine,” whether they are added before or after dealcoholization, the common name “dealcoholized wine” is not acceptable. Such a beverage could be called a “dealcoholized wine beverage.” In such cases, a list of ingredients is required.

“Dealcoholized wine” may contain added water as an ingredient but only in an amount to replace that which is removed during the dealcoholization process, which generally removes water as well as alcohol. The water is returned to the wine after dealcoholization and need not be declared as an ingredient.

6 Other labelling concepts

6.1 “Product of Canada” and “Made in Canada” claims

Use of the “Product of Canada” and “Made in Canada” claims is subject to guidelines.

6.1.1 Product of Canada

This claim is allowed only if at least 98% of the ingredients contained in the product are sourced from inside Canada and the processing and labour used to make the product are also Canadian. The term “Canadian” is considered to be the same as a “Product of Canada” claim.

6.1.2 Made in Canada

This claim may be used when the last substantial transformation of the product occurred in Canada. It must be accompanied by a qualifying statement indicating the source of the ingredients. For example, “Made in Canada from domestic and imported ingredients”15 or “Made in Canada from imported ingredients.”

6.1.3 Other Canadian content claims

Other types of claims may be used provided they are factual and not misleading.

Examples: Distilled in Canada, Packaged in Canada, Made with Canadian maple syrup.

15. The terms “domestic” and “imported” must be reversed when the percentage of imported ingredients is greater than the percentage of Canadian ingredients.

6.2 Nutrition facts table

Beverage alcohol products are usually exempt from having to include a nutrition facts table on their label. However, in some very specific cases, a nutrition facts table may be required. For example, this is the case for beverage alcohol products labelled with claims regarding the calories they contain, for products that contain artificial colourings and for dealcoholized products.

Food and Drug Regulations

The Canadian Food Inspection Agency has prepared a nutritional labelling toolkit. Please note that use of the provided templates is mandatory.

Nutrition labelling

New rules effective December 14, 2021

6.3 List of ingredients

Standardized alcoholic beverages, as defined by the Canadian Food and Drug Regulations, are exempt from the requirement of including a list of ingredients on their labels. A standardized alcoholic beverage is a beverage for which a legal definition exists in Canada. Such beverages include wine, whisky and beer, among others.

Food and Drug Regulations

Accordingly, all unstandardized alcoholic beverages must include a list of ingredients, in French and English, on their labels. The list of ingredients must meet the following requirements16:

• Black type on a white or neutral background. • Use of lowercase and uppercase letters for ingredients that appear in the list. Only the first letter of each ingredient should be capitalized. • The ingredients are separated by bullet points or commas. • The ingredients are listed in decreasing order by weight. • Sugar-based17 ingredients are grouped together between parentheses after the word “Sugars” in decreasing order by weight. • Food colourings are designated by their unique usual name. • The titles “Ingredients” and “Contains” are in boldface type.

16. On December 14, 2021, the new Canadian labelling rules will enter into force as part of the CFIA initiative to modernize food labels. You can begin complying with the new rules immediately or wait until they enter into force. For the sake of conciseness, we here present only the new rules pertaining to the list of ingredients. 17. Sugars may include white sugar, beet sugar, raw sugar or brown sugar, agave syrup, honey, maple syrup, barley malt extract, fancy molasses, fructose, glucose, glucose-fructose (also know as high-fructose corn syrup), maltose, sucrose, dextrose, concentrated fruit juice and fruit purée concentrates. .

• The minimum height of the characters is 1.6 mm (1/16 inch), based on the height of the lowercase “o.” • The same formatting rules apply to any “contains” declaration indicating the presence or possible presence of priority food allergens, of sources of gluten or of added sulphites.

Example of a list of ingredients:

Ingredients: Alcohol, Cream, Sugars (sugar, maple syrup), Whisky, Citric acid, Natural flavours, Sun Yellow FCF. Contains: Milk

Note that, in cases where all the ingredients used are mentioned in the product name, the list of ingredients is not necessary. For example, this would be the case for a vanilla- flavoured vodka whose only ingredients are vodka and vanilla.

6.4 Low-calorie and calorie-reduced drinks18

Use of the term “calorie-reduced” is allowed only if the product contains at least 25% fewer calories than the original product. Use of the term “low calorie” applies only to products that contain no more than 40 calories per serving.

The notion of serving to be used for labelling purposes is the one defined in in Canada’s Low-Risk Alcohol Drinking Guidelines issued by the Canadian Centre on Substance Abuse (CSSA), in which a drink means a volume of an alcoholic beverage that contains 13.5 g or 17.05 ml of pure alcohol.

In cases where the container corresponds to a single serving, it is the volume of the container that is used to define the serving size.

All references to calories must appear on the back label. A nutrition facts table must also be included.

Food labelling for industry

6.5 Proof

Use of the PROOF scale as a means of declaring alcoholic strength is not authorized in Canada. Besides being poorly understood by consumers, the presence of this wording may create confusion about the product’s actual alcohol content and is therefore not authorized.

6.6 Imported by an organization other than the SAQ

As only the SAQ is entitled to import alcoholic beverages into Quebec, the declaration “Imported by…” is unacceptable.

18. The same rules apply to claims related to the nutrient content of sugar or alcohol, for example.

However, if the declaration is meant for a market other than Quebec and this is clearly indicated, the presence of such a declaration will be tolerated. In such cases, it must take the following form, for example: “For the USA, imported by Maison du vin.”

An alternate acceptable wording would be “Imported for…”

6.7 Artificial flavours and graphic representation

Fruits and herbs are often depicted on the labels of alcoholic beverages. However, rules apply if artificial flavours, whether alone or in combination with natural flavouring agents, have been added to the product.

The use of an image of a fruit or herb on a label normally implies that product contains the fruit or herb. If that is not the case but rather artificial flavours have been used, the declaration “imitation,” “artificial” or “simulated” must appear on or adjacent to the image of the fruit or herb.

Food labelling for industry

7 Packaging

7.1 Tamper-proofing of containers

Containers must be sealed so that any attempt to open the container will leave marks or signs visible to consumers. Appendix 2 presents a summary of the requirements by container type and opening type.

Consumer Packaging and Labelling Regulations

7.2 Standardized container size

Standardized container sizes exist for wine. Wine may be sold online in container sizes of 50 ml, 100 ml, 200 ml, 375 ml, 500 ml, 750 ml, 1 L, 1,5 L, 2 L, 3 L or 4 L.

For spirits, the accepted formats are 50 ml, 200 ml, 375 ml, 750 ml, 1,14 L et 1,75 L.

Consumer Packaging and Labelling Regulations

7.3 Alternate containers

By “alternate container” we mean any container or material that is in direct contact with the beverages and that is not traditionally used in the beverage alcohol industry.

For each type of alternate container, you must fill out a form that specifies the materials used. The materials in direct contact with the liquid must comply with part B of the Food and Drug Regulations. You must also be able to provide to the SAQ proof of health protection agency approvals, any other documents necessary to demonstrate that the

20 packaging material satisfies the regulatory requirements and all documents supporting the conditions of use of the packaging material.

Guidance for Food Establishments Concerning Construction Materials and Packaging Materials and Non-Food Chemicals

Appendix 1 Batch (Lot) Number Guidelines

The purpose of the following guidelines is to ensure that the batch numbers printed on the sales units are easily found, decipherable and interpretable.

Recommended location

We recommend using one of the following three locations.

L070501 In the area located at 2 the base of the neck

L070501

L070501 2 00001 14141 6

At the bottom of the back 1 label In the area located at the 3 base of the bottle

Legibility

The characters in which the batch number is printed must be at least 1.6 mm in height. They must also be printed so as to provide sufficient contrast with the background.

Recommended format

We recommend using one of the following two batch number formats:

• L070121, i.e. the letter L followed by the two-digit year number (07 for 2007), two-digit month number (01 for January) and two-digit day number (21 for the 21st day).

• L7021, i.e. the letter L followed by the one-digit year number (7 for 2007) and three-digit number of the day of the year (021 for January 21).

Appendix 2 Tamper-Proofing of Containers

CLOSURES PACKAGING TAMPER-PROOFING TYPE (SALEABLE PRODUCTS) Non-twist-off crown These are typically found on imported beer caps products and require the use of an opener to remove. Once removed, the cap is deformed and cannot be put back on the bottle. Twist-off crown These are typically found on North American beer caps products and are removed by twisting the cap or using a bottle opener. Beer products using this type of closure must be sold in a sealed consumer unit or otherwise be made tamper-evident by the application of a tamper evident feature, e.g. foil overwrap, shrinkable seals, paper seals. Shrinkable seals These seals: over the caps • are frequently found on twist-off caps; • extend up the neck and over the bottle cap; • must be firmly attached to both the bottle and neck. Foil overwrap The foil overwrap: Bottles • is frequently found on beers and coolers with twist-off caps; • extends up the neck and over the bottle cap; • must be firmly attached to both the bottle and neck. Cork finish Cork finish is used: • mostly in wine but also in some premium spirits, fruit brandies and liqueurs; • together with an over-covering capsule, seal or disc made (normally) of paper, plastic, wax or metal foil.

Note: Paper or wax discs placed directly on corks must adequately adhere to the cork and provide visible evidence of tampering when removed. Screw caps A metal ring or plastic is attached directly underneath the cap and breaks when the cap is removed. Bag-in-box All BIB products must be winery sealed. The valve (BIB) opening in the box must also be sealed. Tamper-evident The plastic ring is attached just under the cap on rings with bridge the Tetra Pak and is designed to break when the seals cap is removed. Plastic caps with hidden bridge seals require paper strip-seals to make them Tetra Pak/Flexi tamper-evident. pack (Cheer Twist-off caps These are removed by twisting the cap. Tetra Pak Pack®) products using this type of closure must be sold in a sealed consumer unit or otherwise be made tamper-evident by the application of a tamper evident feature, e.g. plastic pull tab seal.

Pull tabs The metal pull tab is intact Screw caps A metal or plastic ring is attached just under the Cans cap and is designed to break when the cap is removed. Enclosed package (e.g. beer packages) that Enclosed packages completely encloses the product. The seal must be broken to have access to the contents.