Hi
From my experience of working with labelling in Canada 'spices' are exempt from breakdown declarations however you do need to declare any allergens contained within that compound ingredient. For example I have a spice mix in one of my products that contains mustard seeds so i declare as "spices (contains mustard)".
However the OP was asking specifically about sulphites and the regulations state that with respect to sulphites if the ppm is less than 10ppm in the finished product there is no requirement to declare the sulphites with the compound ingredient, Looking at the information the OP gave regarding sulphite levels it looks most likely that the level is below 10ppm so he does not require to declare the sulphites.
Obviously this is just my view and I may be wrong however this is how I present my labels in Canada and I have not had any issues with the regulatory departments.
S
Dear SpursGirl,
Clearly we interpret the (HC) English Language differently. Maybe it's a Canadian variation. No problem.
Anyway, there's an easy way for the OP to find out.
Rgds / Charles.C
(ADDED LATER) PS -
After re-re-reading and backtracking through the Health Canada website, I have concluded your understanding of (HC) English and HC’s labelling intentions are superior to mine.
Just to reiterate some of previous comments -
(a) I deduce that Health Canada have decided that a level of 10 ppm sulphites in the finished product is a “critical” level for sulphites . (quote, A28, “Documented reactions to sulphites occurred at levels of 10 parts per million or above”,
http://www.hc-sc.gc....0_qa_qr-eng.php )
(b) I deduce that where sulphites are
directly added to a food, a declaration is required at
any sulphite level, eg would be required at a level of 1ppm. (A1, A28, ibid).
© I infer that previously (eg ca 2010) spices were legally exempted from having all (??) their components declared on the label. ( quote “Previously, certain components of ingredients were exempted from declaration. For example, when spices or seasonings were used as ingredients in other food, their components were not required to be included in the list of ingredients.” A24, ibid)
(d) I deduce that, operationally, after August 2012, the situation for spices has changed with respect to occurrences of “mustard” and sulphites (and ??). The change for sulphites (
assuming overall exemption status of spices unchanged from [c]) is defined by A1, A28, ibid. Specifically, for spices, no sulphite declaration is required if level
below 10ppm in finished product
(e) The above implies that the statement I previously quoted in the PS of post #3, ie “For example, if a prepackaged food contains the ingredient "spices", that food will be required to list any allergens, gluten sources, or sulphites present in the spices” is incompletely stated on Health Canada website.
(f) paras (a-d) are not relevant if the (unknown) food is exempted from providing an ingredient declaration, see A16, ibid (and ??).
(g) the originating Feb.2011 document for above discussion (prior to various modifications) appears to be
http://gazette.gc.ca...dors28-eng.html , the sulphite-relevant content looks mainly to be in sections B.01.010.2, B.01.010.3. It is neither brief nor simple.
(g) (the ??s) emphasise that the above comments are opinions only.