US and Canada Labeling on Added Sugars
Hello everyone,
For quick background, I am creating a dual label for a product with Class 1 caramel color meant for US and Canadian distribution.
Canada requires all sources of added sugars to be grouped together on the ingredients list of their labels. According to this list https://inspection.c...nd-allergens#c7 burnt sugar would count as an added sugar. From Googling, burnt sugar seems to be what they call caramel color but calling it burnt sugar means that it has flavoring and coloring uses but is not necessarily interchangeable with caramel colour, which is just for coloring, though I do not have any "official" regulatory reference for this.
My question is: Do I count my American Class 1 caramel color towards the Canadian added sugars labeling requirement?
My instinct is to leave it out of the grouping and the nutrition calculation for added sugars for the NFP.
Any thoughts or references related to this would be greatly appreciated :)
I can't assist much with your specific case, but I am including the guidance docs we used for requirements on declaring added sugars in honey. (Yes that was a smart idea to require us to list total sugars under added sugars, as if that wouldn't confuse consumers even more as to why all-natural honey has 'added' sugars).
There are some links in the guidance doc that might take you to information pertinent to you.
Attached Files
so Caramel colour has zero sugar and is just used for colour it WOULD NOT have to be included in the CFIA sugar grouping rules
Burnt sugar, regardless of what you use it for, is still sugar and MUST be included in the sugar grouping rules