What to do with label stocks with incorrect Net Carb Claim?
Hello if anyone could please answer this ,
What to do in case we have one year worth of label supply left with a net carb claim on it which is not accepted by CFIA. Can we finish the supply in hand and get new labels printed after a year supply is done??
Or Do we have to discard the whole supply in hand and use the new labels?
Thank you
May I ask what's wrong with your net carb claim? Why wasn't it accepted by CFIA?
Hello ,
One of our product says Net Carbs and according to cfia-
- "Net Carbohydrate" and "Effective Carbohydrate" Statements
The following terms, "net carbohydrate", "net impact carbohydrate", "net effective carbohydrate", "effective carbohydrate", and "digestible carbs" are not acceptable due to lack of scientific consensus on their definition and their potential to mislead consumers. Additionally, the Regulations prohibit claims concerning the action or effects of nutrients, including carbohydrate, unless specifically provided for (B.01.311, FDR).
If your label does not meet CFIA requirements, I don't think you have other choice but cancel that label. You may try and use those non-compliant labels at your own risk, however if CFIA ever wants to inspect your label you might be in trouble.
Yeah. I was thinking the same, Thank you so much for your help.
You've had 5 years to comply----see below
https://inspection.c...4/1481234946761
These regulatory amendments provide a 5 year transition period for regulated parties to meet the new labelling requirements, ending on December 14, 2021. Amendments dealing with food colour specifications and removal of the synthetic colour certification requirement came into effect immediately at the time of publication of the amendments.
For the first year following the transition period, the Canadian Food Inspection Agency (CFIA) will focus its efforts on education and compliance promotion (until December 14, 2022). After that date, the CFIA will verify compliance and apply enforcement discretion in cases of non-compliance when regulated parties have a detailed plan that shows how they intend to comply at the earliest possible time, and no later than December 14, 2023.
In the US, you can apply for an exemption, not sure if the same exists in Canada. You could explain the monetary loss for disposal of the current label and give a timeframe to use them up (typically 6 months in the US). If the label was previously accepted, then that might help support your position. Might be worth looking into.
Keith
I don't think you have an option but to cancel the label if it doesn't comply with CFIA regulations.
I would treat this as a learning moment and review your other labels to see if they contain any other claims that may cause future problems.
Since this isn't a new chance, you're probably best off if you just get rid of the stock (before new stock of the same label is reordered).