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News Article: How Canadian is our food?

Tuesday, November 18th 2008 8:48:13am

To the Editor:

This is an article from a series of monthly columns by Environmental Law Specialist Dianne Saxe and Jackie Campbell. Dr. Saxe is one of the top 25 environmental lawyers in the world.  These articles are available for publishing at no charge, provided Dr. Saxe and Ms. Campbell are cited as the authors.  Dr. Saxe can be contacted at (416) 962 5882 or For more information, visit

How Canadian is our food?

There are lots of reasons to buy Canadian food - to support local farmers and landscapes, to keep money in our economy and to be more sure of food safety. For those who want to reduce our ecological and carbon footprints, one of our most powerful options is to eat local, unprocessed food. The current North American food industry is astonishingly dependent on cheap petroleum, and much less efficient in its use of oil than our grandparents were. In 1940, 10 calories of fossil-fuel produced 23 calories of food. Now, due to food processing, packaging and transportation, the same amount of fossil-fuel produces only 1 calorie of supermarket food.

But unless you buy direct from a farmer, how do you know which food is Canadian? Is it enough to see Canada or a maple leaf on the label?

It turns out that careful reading is required. We were surprised and disappointed to learn how little a "Made in Canada" label means.  First, food vendors and manufacturers aren't required to reveal the origin of their products at all. If they do want to claim Canadian content, they must follow the Canadian Food Inspection Agency's Guide to Food Labelling and Advertising.

However, until this year, this Guide allowed Made in Canada labels to be put on any product manufactured or processed in Canada, regardless of the origin of the ingredients,  as long as at least 51% of total direct manufacturing costs occurred in Canada.   That is, a Made in Canada product may be made of 100% foreign ingredients, as long as it receives a "last substantial transformation" in Canada. It is enough if the food is changed by processing into some new product that has a name consumers will understand (e.g., "tuna with curry" is "substantially transformed" when you add the curry).  

Fortunately, new rules are expected to come into effect for products produced after December 31, 2008. Under the new rules, Made in Canada labels should now show whether the ingredients are imported. Look for labels that say, for example, "Made in Canada from imported ingredients" or "Made in Canada from domestic and imported ingredients".

Other food products that use the word "Canada" on their label may have even less connection with this country. As long as some value is added here, they may be labelled "Processed in Canada", "Refined in Canada", "Brewed in Canada" etc..  Maple leaf marks should not appear on imported products, but there is no quantitative limit as to how much of the product  must be Canadian for a maple leaf to appear.

The only label that that guarantees  primarily Canadian content is "Product of Canada". Under the old rules, a "Product of Canada" label meant little more than "Made in Canada". Under the new rules, a "Product of Canada" label may be only used when "all or virtually all" major ingredients, processing and labour used to make the product are Canadian. Non-Canadian "material" must be "negligible".  Foreign ingredients can be used, if they are present at "very low levels", are not typically produced in Canada (e.g., spices, food additives, vitamins, minerals), and each of the foreign ingredients generally must be less than 2% of the product.  

For people who want to know what they're eating, the new labelling rules are a major improvement, but they still leave room for concern:

• Most consumers don't understand the difference between "Made in Canada" and "Product of Canada" - pass the word!
• The new rules only apply to products manufactured after 2008. This means that old labels may continue to appear in supermarkets for months or years, until all existing stocks are exhausted.
• Consumers still won't know where foreign ingredients come from (e.g., Countries whose human rights practices are abhorrent? Countries whose standards of food safety are inadequate?)
• "Very little" or "minor" concentrations of ingredients "generally" means less than 2% of a product; in some cases this could be significant.
• There is no clear quantitative limit on the total amount of foreign ingredients,  even in a Product of Canada.
• A "Product of Canada" claim applies to the food product, not the packaging -- all packaging, and much of the product cost, may therefore come from outside Canada.

The bottom line? The best way to buy Canadian food is still to buy it directly from a farmer or through a community supported agriculture group.  When that's not possible, look for a "Product of Canada" label, and ask your store manager to confirm that the  label meets the new Guide to Food Labelling and Advertising rules.

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