Flexibility in the Declaration of Ingredients.

Hello all,

CFIA has posted the attached notice pertaining to flexibility in ingredient declarations brought about by substitutions due to supply chain issues.

In a nutshell, if the disruption is unanticipated, you can proceed with a substitution for a short period of time without modifying your labelling provided the substitution does not itself introduce an undeclared allergen or any other health concern. It is understood that the substitution would be for a short period of time, following which you would return to the former ingredient or would be required to amend your labelling to reflect the new ingredient.

If it is anticipated, then you will be required to modify the label to accurately reflect the change in the ingredient declaration. 

Below is the link to the release:


I trust this is to your satisfaction. Please feel free to call if you have any questions.

Have a great day and stay safe,



Dear values clients,

The office will be closed on Monday, October 11th for Thanksgiving. The office will re-open on Tuesday the 12th.

Wishing all my Canadian clients a happy Thanksgiving,

Niccolas  Cosmatos  BSc  [he / him]

2021 Summer Vacation Notice

Dear valued clients, 

I will be taking my usual vacation during the 2nd week of August [Aug. 6th to 13th], returning to office on the 16th. As I have done in previous years [except last year due to Covid], I will be working overtime the week before and after in order to minimize the disruption. 

Wishing you all a wonderful Summer.

Niccolas Cosmatos

SFCR licence deadline reminder

Dear valued clients,

This is just a reminder that March 15, 2021 is the deadline after which CFIA will automatically reject any food import transaction without a valid Safe Food for Canadians (SFC) licence entered in the Integrated Import Declaration (IID).  A rejected transaction may result in delays and have their food shipment(s) held at the border until the error is addressed and the import transaction resubmitted.

For more information on transaction rejections, please refer to: Importing food into Canada with a Safe Food for Canadians licence.

Have a great day and stay safe,


2016 Nutrition Facts Deadline Update

Dear valued clients,

Yesterday, CFIA released a notice to industry concerning a change in the 2016 nutrition labelling amendments as a result of the challenges brought about by Covid-19.

The compliance date for the new formatting remains December 14th of this year but CFIA is delaying enforcement by one year. 

Products found out of compliance after December 14th will be subject to the equivalent of a “friendly reminder” to make your packaging compliant. You will be required to show a detailed compliance plan. This will be in effect until December 14, 2022, after which time non-compliant packaging will be subject to enforcement.

While this may seem like a one year reprieve, it isn’t. My recommendation remains that you ensure all packaging compliance to the new regulations by this December so as to avoid putting your company and its products on CFIA’s radar.

Excerpt from the notice:

While the end of the transition period for the amendments will remain December 14, 2021, the CFIA will focus its efforts on education and compliance promotion for the first year (until December 14, 2022). After December 14, 2022, the CFIA will verify compliance and apply enforcement discretion in cases of non-compliance where regulated parties have a detailed plan that shows how they intend to meet the new requirements at the earliest possible time, and no later than December 14, 2023.

The entire text can be found at:


Please feel free to call if you have any questions.

Have a great day and stay safe,


Holiday Wishes and Hours

Dear Valued Clients,

As in prior years, the office will be closed for the holidays. Friday, December 18th will be my last day. The office will reopen on Monday, January 4th.

I would like to take this opportunity to thank you all for your patronage and trust in me to ensure the accuracy of your product labelling. Looking forward to assisting all of you in 2021. We’ll be celebrating our 35th year of service!

From my family to yours, we wish you and your families a safe, healthy and joyous Holiday season.

Season greeting

Niccolas, Dominique and Justin Cosmatos

Summary – CFIA Proposed Regulatory Amendments to Labelling

On June 22nd the following Regulatory amendment proposals to the FDR were printed in Gazette 1. This is the preliminary publication for final consultation prior to the amendments moving to final implementation in Gazette II. Below is the link to the publication document that provides the specifics for each of the sections.


The proposed changes are summarized below:

Date marking and storage instructions

Apart from certain exceptions, all products will require date marking (currently products with greater than 90 days are exempt)
Definitions for expiration date and best before date will be clarified/revised to align with international standards giving industry more formatting choices. (e.g. the month may be declared by words, bilingual abbreviations, or numbers).

Food company information

Companies will be required to include contact information (e.g. telephone, email, postal, or website) for consumers to be able to seek more information about a product or to make a complaint. Industry would be given the flexibility to choose a method of communication suited to their particular business.

Foreign state of origin of imported food

country of origin to be declared on all “wholly imported foods” (i.e. referring to foods that are not transformed in Canada).

Legibility and location of information

setting of minimum type heights for mandatory labelling information: uniform colour, adequate contrast, and not be obscured or crowded by other information on the label or packaging.
location requirements for certain labelling information: country of origin would have to be grouped with dealer name and address, and storage instructions would have to be on the front of the package or grouped with the list of ingredients.
These would apply to all prepackaged food labels and take into consideration the labelling space associated with various packaging sizes (an industry concern).

Emphasized ingredients

Promoted, highlighted or specified ingredients would require a declaration of the ingredient percentage on the label. Industry would have flexibility in the declaration (e.g. list of ingredients, part of the emphasized claim, or common name). Certain exceptions will apply if a compositional standard exists (e.g. raisin bread)
labels to clearly indicate that the food is “flavoured” when the emphasized ingredient is not present or present in flavouring amounts.

Standard container sizes

Repeal certain requirements for standard container sizes from the SFCR, and incorporate by reference the remaining list of sizes. [listed below]
o the requirements in the Honey Regulations that apply to bulk honey containers
o the requirements in the Fresh Fruit and Vegetable Regulations that apply to prepackaged beets, prepackaged onions, prepackaged parsnips, and prepackaged rutabagas, bulk packages of graded produce marketed in import or interprovincialtrade exceeding 50 kg net weight (with the exception of apples, potatoes and carrots, which would remain status quo).
o The requirements in the Processed Products Regulations that apply to canned asparagus, canned sweet potatoes (cut and whole), frozen fruits (including fruits with added sugar, syrup, fruit juice or fruit juice from concentrate), frozen spinach, frozen squash (cooked or diced uncooked),
o frozen corn-on-cob, frozen concentrated apple juice, pineapple (sliced, crushed, tidbits and chunks), grapefruit, orange,grapefruit and orange sections, bean sprouts vegetables forchop suey, mandarin oranges, grape juice (including concentrated grape juice and grape juice from concentrate, but not including carbonated juices and juices packed with nitrogen).

Incorporation by reference of class names

Repeal separate lists of mandatory and optional class names for ingredients from the FDR and incorporate them by reference. – this basically means they will take the lists found in B.01.010 and move them to the “IBR” lists. This means if they wish to add or remove common names, they can do so without the “beaurocratic delay”

Definition of test market food

Introduce a definition for “test market food” into the SFCR to clarify the intent of an exception for the purpose of test marketing. This definition would limit the application of test marketing exemptions to foods that differ substantially (e.g. in composition, function, packaging) from others sold in Canada and that were not sold previously in Canada in that form.
o Based on past projects, this one doesn’t affect many of you.

Streamlining commodity-specific labelling

Maintain food commodity–specific labelling requirements necessary for health and safety reasons (to protect consumers from false and misleading information, or for trade reasons), while streamlining the rest. This would be achieved by either repealing requirements or introducing a single horizontal requirement to replace multiple commodity-specific ones. For example, a new horizontal provision requiring certain foods to include words that distinguish them from other similar foods, when necessary to avoid purchaser confusion, would replace several existing labelling requirements. In addition, some food descriptors (e.g. “soft,” “semi-soft,” “firm,” and “ripened” terms for cheese) would be incorporated by reference to allow these requirements to change over time in response to marketplace changes or innovation. This outcome-based approach would align Canadian standards with Codex standards and those of Canada’s trading partners.

Transitional provisions and phasing-in of requirements

The chart below identifies the three phases of implementation for the above regulatory changes. As with the NFT/Ingredient implementation from 2016, during each transition period, industry would be entitled to comply with either the current or the new regulations.

FLM Element

Transitional Period (Assume Final Publication in 2020)

Incorporation by reference of class names

Standard container sizes

Definition of test market food

Streamlining commodity-specific labelling (no change to label)


Foreign state of origin of imported food

Food company information

Date marking and storage instruction

Streamlining commodity-specific labelling (changes to label)

Two years
(anticipated 2022)

Emphasized ingredient

Legibility and location

Six years
(anticipated 2026)