How Food Companies Can Ensure Label Compliance Under Canada’s Sugar Grouping Rule

Introduction 

Canada's food labelling landscape is undergoing a significant transformation. With Canada’s new regulation to group sugar-based ingredients, food labels must now list all added sugars together under one name. This seemingly simple change is part of a broader push towards labelling transparency. For Indian food exporters, this means more than just label edits. It requires a comprehensive understanding of ingredient classification, regulatory nuance, and how the Canadian food regulation views added sugars. This aspect might be very different from how labels are done in the Indian market. 

In this article, we break down what the new rule means, how it impacts Indian manufacturers, and what steps you need to take to ensure your products remain export-compliant and shelf-ready.

What Does the Grouping Sugar-Based Regulation Say?

Under Canada’s Food and Drug Regulations [B.01.008.3(1)], all sugar-based ingredients in prepackaged food must be listed together right after the word “Sugars” on the ingredient label.

It is the manufacturer’s responsibility to:

• Determine whether an ingredient qualifies as a sugar-based ingredient

• Be able to justify their classification approach if reviewed by the CFIA (Canadian Food Inspection Agency)

What Defines a Sugar Based-Ingredient?

In a prepackaged food product, a sugars-based ingredient refers to:

• An ingredient that is a monosaccharide or disaccharide, or a combination of these (e.g., glucose, fructose, sucrose)

• Any ingredient that is a sweetening agent

• Any ingredient that contains 1 or more sugars and that is added as a functional substitute for a sweetening agent. 

a. Sugar Grouping Requirements

Sugar-Based Ingredients are one among the following: 

1. Ingredients made up of simple sugars (monosaccharides or disaccharides) - Monosaccharides are the simplest sugars, and there are three main types: glucose, fructose, and galactose. Disaccharides are made from two monosaccharide units joined together. Common examples of disaccharides are sucrose, lactose, and maltose. 

So, when you look for sugar-based ingredients, those that are either monosaccharides or disaccharides usually have names ending in “-ose” or contain the word “sugar” (e.g., glucose-fructose, cane sugar, beet sugar).

Some examples of monosaccharides, disaccharides, or a combination of both: 

Source: https://inspection.canada.ca/en/food-labels/labelling/industry/list-ingredients-and-allergens#s16c7 

2. Ingredient used as a sweetening agent - This refers to sweetening agents as described in Volume 15 of the CFCS (Canadian Food Compositional Standards) document. The CFCS document consists of 19 volumes, each covering standards for different food categories. Volume 15 focuses on sweetening agents, detailing definitions, compositional requirements, and labeling standards for various sweetening substances.

According to the FDR (Food and Drug Regulations), a "sweetening agent" refers to any food that meets the standards set out in Volume 15 of the CFCS. 

Some examples of sweetening agents: 

Source: https://inspection.canada.ca/en/food-labels/labelling/industry/list-ingredients-and-allergens#s16c7 

3. The ingredient that performs one or more functions of a sweetening agent - In the context of prepackaged products, a functional substitute for a sweetening agent refers 

• To a food that is not a sweetener or sweetening agent, including any sugars. 

• This substitute replaces a sweetening agent and serves one or more of its functions, such as sweetening, thickening, texturing, or caramelizing. 

Sweetening agents can also serve other purposes, including flavoring, preserving, browning/caramelizing, and coloring.

A "functional substitute for a sweetening agent" typically does not include an obvious source of sugars.

• For example, fruit juice concentrates may not be recognized by consumers as sugar sources, even though they perform similar functions. 

• Grouping such ingredients under “Sugars” on labels helps consumers identify these hidden sugars in food products.

Let us understand the above with an example of a Strawberry-Flavored Breakfast Cereal:

Consider a packaged strawberry-flavored breakfast cereal that uses apple juice concentrate instead of white sugar to sweeten the product. While “apple juice concentrate” might sound healthier, it still performs the same function as sugar.

• Ingredients: Corn flakes, Apple juice concentrate, Strawberry purée, Salt, Natural flavour, and Vitamins. 

• In this case, “apple juice concentrate” would need to be grouped under “Sugars” on the label, since it acts as a sugar substitute.

Under Canada’s new sugar grouping rule, these ingredients are classified as functional substitutes for a sweetening agent.

To make this transparent to consumers, they must be grouped under the term "Sugars" in the ingredient list.

Some sugar-based ingredients that are functional substitutes for sweetening agents: 

Source: https://inspection.canada.ca/en/food-labels/labelling/industry/list-ingredients-and-allergens#s16c7 

b. Sugars that require no Grouping 

There are certain sugar-based ingredients that require no grouping under the new rule. 

• These include sugar alcohols such as maltitol, and sweeteners like steviol glycosides or aspartame.

• Ingredients that are commonly recognized as sources of sugar, like chocolate, do not need to be grouped. 

• Additionally, there is no need to group ingredients that are visible in whole pieces or layers, such as yogurt coating or frozen fruits.

Some ingredients do meet the definition of sugar-based ingredients, but they do not need to be grouped in the following types of prepackaged products [B.01.008.3(4), FDR]:

1. When sold as sweetening agents themselves

If a product is packaged and sold as a sweetening agent, it is exempt from the grouping rule. Since these are already understood by consumers to be sweeteners, grouping under “Sugars” is not required.

Examples of such products include: Icing sugar, Maple syrup, Lactose, Agave syrup, Table sugar, Golden corn syrup, and molasses. 

2. Fruit or vegetable juice or vegetable drink that does not have any sweetening agent

Prepackaged fruit or vegetable juices, or their blends, that do not have any added sweetening agents are not required to be grouped with sugars.

3. (a) Fruit or Vegetable Juice or Drink Without Added Sweeteners  

This category includes juices and drinks made from fruits or vegetables, or a mix of both. It also covers any juices or drinks that have fruit or vegetable purées or blends, as long as they don’t contain added sweeteners.  

• For example, the product “ABC Fruit and Vegetable Juice” is a mix of fruit and vegetable juices with added fruit and vegetable purées. The ingredients are:  

• Ingredients: Apple juice, Carrot juice, Mango purée, Sweet potato purée, Natural flavor, Vitamin C

(b) Reconstituted Fruit or Vegetable Juice or Drink without Sweetening Agents

This category includes prepackaged fruit or vegetable juices, vegetable drinks, or blends of these that contain no added sweetening agents and have been reconstituted to their regular strength.

(c) Fruit or Vegetable Juice or Drink Concentrate without Sweetening Agents

This category covers prepackaged fruit or vegetable juice or vegetable drink concentrates, including blends, that are intended to be diluted with water before consumption, and contain no added sweetening agents.

4. Fruit or Vegetable Purée without Sweetening Agents

This category includes prepackaged fruit or vegetable purées, or blends of these purées, that do not contain any added sweetening agents.

• Example: A jar of unsweetened guava-apple purée, made from concentrated guava and apple purées, without any added sweetening agent. Water is added to reconstitute it to regular strength.

• Ingredients: Guavas • Apples • Water • Concentrated guava purée • Concentrated apple purée • Ascorbic acid • Natural flavour

5. Prepackaged Products Containing Only One Sugar-Based Ingredient

This category includes prepackaged products that contain a single sugar-based ingredient, where the ingredient's common name includes the word "sugar."

6. Formulated Liquid Diets, Human Milk Fortifiers, and Infant Formula

Prepackaged products like infant formula, human milk fortifiers, and formulated liquid diets are exempt from the requirement to group their sugar-based ingredients. These products are highly regulated, and their consumption should not be discouraged due to the presence of added sugar-based ingredients.

7. Prepackaged Products with Less Than 0.5 g of Sugars per Serving

Prepackaged products containing less than 0.5 g of sugars per serving are exempt from grouping sugar-based ingredients under "Sugars" in the ingredient list, even if the total sugars are declared as 0 g in the Nutrition Facts Table (NFT). This exemption also applies when the NFT is not required.

However, sugar-based ingredients may still be grouped voluntarily when the total sugars are listed as 0 g in the NFT.

8. Single Sugar Ingredient Exemption

If a single sugar-based ingredient is added under the Sugars section in Canada’s labelling step, the ingredient need not appear as a grouped entry in the label preview. The ingredients will be declared in the following manner: Flour, Palm Oil, Honey, and not Flour, Palm Oil, Sugars (Honey).  This mirrors the India-style descending order format and follows the exemption rule for single sugar ingredients under Canadian labelling regulations.

The Intent Behind Grouping Sugar-Based Ingredients 

Grouping sugar-based ingredients is more than just a labelling regulation - it’s a move towards greater clarity, transparency, and consumer empowerment, helping Canadians see the full picture of sugars in their food.

1. Simplifies Consumer Understanding

The purpose of grouping sugar-based ingredients is to empower consumers by providing clearer insights into their relative proportions in food alongside other ingredients. This approach not only identifies unfamiliar sources of sugars but also allows consumers to make informed choices about the products they consume.

2. Reveals Hidden Sugars 

Many Canadians might not realize that ingredients like agave syrup, isomaltose, and pear juice concentrate are, in fact, forms of sugar. When a food product contains a lot of these less obvious forms of sugar, grouping them on the ingredient list pushes the "sugars" category closer to the beginning of the ingredient list. This regulation might help consumers to better identify the hidden sources of sugar in their food. 

3. Enhanced Label Transparency and a clear picture of the total proportion of sugars 

This change positively improves the transparency of food labels. By grouping all sugar ingredients, those used in significant amounts are positioned at the beginning of the ingredient list, which makes it easier for you to recognize their presence and make informed choices. 

Also, this simple change clearly shows you the true proportion of sugar-based ingredients in what you're buying.

The Labelling Challenge for Indian Food Companies  

Canada’s updated food labelling regulation requires all sugar-based ingredients to be grouped and listed simply as “Sugars” in the ingredient list, as explained above. This includes not only obvious sugars like sugar and honey but also ingredients that function like sugar, such as fruit juice concentrates and purées.

For Indian food exporters, this means a significant challenge in:

• Reformulating labels to comply with the new grouping of sugar-based ingredients. 

• Identifying ingredients that act as sweeteners or sugar substitutes, even if they aren’t sugars by name.

Indian products often include traditional recipes with natural sweeteners like jaggery, dates, or fruit pulps or Ayurvedic formulations that may use herbal extracts or natural sweeteners or Fruit-forward products that use fruit concentrates or purées. As a result, many Indian brands need to reassess their ingredient declarations to ensure transparency for consumers about sugar content and regulatory compliance with Canadian labelling laws.

This adjustment is essential for maintaining market access and consumer trust in Canada.

FolSol®: One Solution For all Your Food Labelling Needs 

This regulation will call for an update in the existing food labels that are being shipped to Canada. FolSol® Global Exports Labelling Software will make this easier and ensure that you food labels are regulation compliant! 

FolSol®’s Labelling Software makes sugar grouping effortless and intuitive. It automatically detects the sugar-based ingredients in the product and combines them for easy labelling.. With a simple drag-and-drop interface, users can easily move relevant ingredients into the designated “Sugars” section. 

The SaaS also includes a comprehensive, dedicated list of sugar-based ingredients that require grouping, helping ensure full compliance with Canada’s updated grouping of sugar-based ingredients regulations.

For more details on how FoLSol® Global Exports Labeling Software can simplify your regulatory labeling processes, write to support@foodlabelsolutions.com. 

Conclusion 

Canada’s sugar grouping regulation marks a pivotal shift in how food labels communicate added sugars to consumers. For Indian food exporters, this is both a challenge and an opportunity. It challenges existing label structures and ingredient classifications but also opens the door for greater transparency and trust in international markets. 

The key to navigating compliance is understanding the details, and that’s where FolSol can help! With its smart classification of sugar-based ingredients, easy drag-and-drop grouping, and built-in exemptions, FolSol® takes the guesswork out of the process. 

Whether you’re exporting biscuits, cereals, or condiments, FolSol® makes sugar grouping clear, simple, and regulation-ready. As global labelling standards tighten, Indian companies equipped with the right tools and clarity will lead with confidence. 

About LabelBlind®

Established in 2018 and based in Mumbai, LabelBlind® specialises in the area of Digitising Food Labelling and Regulatory Compliance. FoLSol® by LabelBlind® presents India’s 1st Digital Food Labelling Solution. The SaaS platform supports food businesses in being labelling compliant and Building Consumer Trust. 

The software is designed to strengthen the food labelling ecosystem across multiple categories:

• Packed Food Labelling

• Menu Labelling

• Exports Labelling

• Nutraceuticals & Food Supplements Labelling

• Labelling for E-commerce Platforms

FoLSol® by LabelBlind® is a comprehensive digital food labelling solution. It is a Digital Food Labelling Solution that is fast, accurate, and cost-effective. The company is ISO9001 certified.

References: 

1. List of Allergens and Food Labels - www.inspection.canada.ca

2. Canadian Food Compositional Standards - Volume 15 Sweetening Agents 

3. Canada Food and Drug Regulations