Managing Health Claims for Foods in Canada:
Towards a Modernized Framework

Discussion Paper

Please note that the deadline for submission of comments is extended to March 31, 2008.

November 2007

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For additional information and/or copies of this document, please contact:

Nutrition Evaluation Division
Food Directorate
Health Canada
Sir Frederick G. Banting Research Centre
251 promenade Sir Frederick Banting Driveway
A.L. 2203A
Ottawa, ON Canada, K1A 0K9

Telephone: 613-957-0352
Fax: 613-941-6636
Email: healthclaims-allegationssante@hc-sc.gc.ca

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Table of Contents

EXECUTIVE SUMMARY

Introduction
Background
Issues

INTRODUCTION

PART A: BACKGROUND

A1. HEALTH CLAIMS FOR FOODS IN CANADA

1.1 What are health claims for foods?
1.2 History of health claims for foods in Canada
1.3 Current regulatory framework

1.3.1 Foods with health claims that require regulatory amendments
1.3.2 Foods with health claims that do not require regulatory amendments

(i) Function claims expressly permitted by current food regulations
(ii) Function claims not expressly permitted by current food regulations
(iii) General claims about "healthy choice"

1.3.3 Natural health products in food form

A2. INTERNATIONAL CONTEXT

2.1 Management of health claims for foods is a focus of much international activity
2.2 International comparisons are tempting but challenging

(i) Definition of "health claim"
(ii) Each legislative context is unique
(iii) Global challenge of managing claims across product categories

2.3 The Canadian situation from a general global perspective

2.3.1 Mechanisms of approval and oversight
2.3.2 Standards of evidence
2.3.3 Nutritional criteria for foods carrying health claims

A3. A MODERNIZED FRAMEWORK FOR MANAGING HEALTH CLAIMS FOR FOODS: THE CHANGING CONTEXT

PART B: ISSUES AND DISCUSSION

B1. DISCUSSION THEME 1: EFFICIENT AND TRANSPARENT PROCESSES

Theme 1.1 Business improvements for increased efficiency
Theme 1.2 Increased openness and transparency

B2. DISCUSSION THEME 2: SOUND EVIDENCE FOR CONSISTENT, CREDIBLE CLAIMS

Theme 2.1 Scientific substantiation of claims
Theme 2.2 Supporting good-quality submissions

B3. DISCUSSION THEME 3: CLEAR POLICIES FOR TODAY AND TOMORROW

Theme 3.1 Functional foods and the food/natural health product interface
Theme 3.2 Managing a broader range of function claims
Theme 3.3 Managing diverse front-of-package claims

Theme 3.3.1 Implied health claims
Theme 3.3.2 Simplified nutritional or general health messages

Theme 3.4 Eligibility criteria for foods to carry claims

B4. DISCUSSION THEME 4: SUPPORTING INFORMED CONSUMER CHOICE

Theme 4.1 Improving consumer understanding of health claims
Theme 4.2 Monitoring the impact of health claims on the food supply and on consumer choice

B5. GENERAL QUESTIONS

B6. INVITING YOUR FEEDBACK

6.1 General instructions
6.2 Feedback form and questions

REFERENCES

APPENDICES

A - Glossary

B - Chronology of the Development of Policy and Standards for Disease Risk Reduction Claims for Foods in Canada

C - Summary Table of Biological Role Claims for Nutrients

D - International Comparisons

E - Health-Related Claims in the United States

F - US Disease Risk Reduction Claims* and Their Status in Canada

G - References: Health Claims for Foods in Selected Jurisdictions