In 2022, Health Canada made a decision that requires new Front Of Package (FOP) Nutrition Symbols be added to certain products.
While the change is aimed at better educating consumers about their purchasing decisions, for brands, it means adding an unsightly icon or maybe even undertaking an entire packaging revamp.
What Are the Canadian FOP Packaging Requirements for 2026?
Basically, packaged food companies will have to include a magnifying glass symbol next to the nutrition information to make consumers more immediately aware of high saturated fat, sodium, or sugar levels in their product.
It looks like this:
The level considered “high” is different depending on the type of product. Some products are even wholly exempted from the new requirements for nutrition labelling.
To handle these differences, Health Canada’s summary1 of the Canadian consumers labelling requirements separates applicable products into three categories and offers three exemption categories.
Category 1: General Prepackaged Foods
Most affected products fall into this category. Those that meet or exceed 15% of the daily value (DV) for saturated fat, sugar, or sodium will need to have the corresponding symbol on their packaging.
Category 2: Prepackaged Foods With a Small Reference Amount
This category covers any prepackaged foods that you eat a little bit at a time, like pickles or cookies. Their limit is lower, at 10%. The thought behind this is that the high amount of saturated fat, sugar, or sodium is concentrated into a smaller — and less filling — amount of food.
Category 3: Prepackaged Main Dishes With a Large Reference Amount
If a prepackaged main dish has a serving size greater than 200 grams, it falls under this third category. The threshold here is a higher 30% for the exact opposite reason than the rationale behind category two — a frozen pizza or pasta dish is likely to be a larger part of someone’s daily intake.
And now the exemption categories...
Exemption 1: Health-related
This exemption avoids discouraging vulnerable or undernourished populations from making sustaining food choices that are high in sodium, sugar, or saturated fat. The following foods are exempt from FOP nutrition labelling requirements for health reasons:
- Foods that have some recognized health benefit (like fruits and vegetables in multiple forms without significant added sugar or salt)
- Foods made to meet the specific needs of a population (think military meals)
- Foods that provide an important source nutrients that most people lack (such as dairy products for calcium)
Exemption 2: Technical
Foods prepackaged in incredibly small amounts or that otherwise don’t require a nutrition facts label are also exempt. These include:
- Foods not sold directly to consumers (think coffee creamer cups)
- Foods with very small packaging (like mini chocolate bars)
- Foods that contain raw or single ingredient ground meat, poultry, or fish (un-spiced)
Exemption 3: Practical
Foods that very obviously have high amounts of saturated fat, sugar, or sodium may also be exempt. After all, consumers don't need extra labelling to tell them that a bag of sugar has a high sugar content or that table salt is high in sodium. Other exempted products for practicality include:
- Honey
- Maple syrup
- Butter
- Olive oil
Crew's Advice For Dealing With Regulations
As a consumer goods agency we have a lot of experience in food marketing space, and we've seen regulations before.
Here's how this change might affect brands and the food industry as a whole with insights from Crew's CEO, Braden Douglas, and Creative Director, Dan Ryu.
How will these changes impact brands?
Two major changes will be evident for food brands. The obvious is that adding an FOP symbol will bring more consumer attention to the nutrient content behind products with high sodium, fat, or sugar. Secondly, let's face it, the labels are a bit intrusive, meaning they may not be easy to incorporate into existing artwork — and this may force some brands to reimagine packaging designs.
“This change provides an opportunity for brands to rethink their brand, communication and packaging to decrease the weight or intrusion of these labels.” - Braden Douglas, Crew CEO
What have previous labelling regulations taught us?
If implementing the nutrition fact table has shown us anything, it’s that consumers and brands adapt fairly quickly to change. While consumers did have an initial reaction to calories being exposed, It ultimately didn’t have a big, lasting impact on people’s eating patterns.
Is there a first-mover advantage to adopting labelling quickly?
No, highlighting that your product has high levels of sodium, fat, and sugar faster than necessary doesn’t offer much of an advantage. There is, however, an advantage to planning early.
Creating innovative solutions to packaging design issues will take time, so it’s smart to be productive instead of reactive. You might even want to make changes in your formula to offer lower sodium, sugar, or saturated fat levels. Alternatively, creating new packaging can better highlight your product’s benefits alongside the new symbol.
Ultimately, we recommend communicating with packaging manufacturers and retailers on changes as soon as possible. This will show your leadership and may even give you more shelf space over slower moving brands that don’t adopt quickly enough.
How can brands respond to the changes?
No getting around it — the clear guidelines for how this symbol needs to show up on your packaging may not be pretty. The size requirements are set to get consumers’ attention very quickly and for some packaging, that might make the symbol compete with the product or brand name.
At first, this symbol might be seen as a negative identifier for foods with potential health risks. As Crew Creative Director, Dan Ryu says: “We know consuming high quantities of any of those nutrients isn’t good for us, so just by seeing the symbol on a product you were considering purchasing, it may now deter you from actually buying it... Consumers will need to really read the nutrients and dive deeper.”
Ryu also points out: “If you have multiple SKUs or flavours in one box that fall under this new regulation, you could have up to three or four symbols on the FOP.” For example, if a variety box has three different types of bars in it, you could have up to three symbols. The first flavour might be high in saturated fat and sugars, the second might be high in only saturated fat, and the third might be only high in sugars — each one requiring a symbol to show that.
When this is the case, Ryu recommends leveraging messaging that speaks to the benefit behind the high amount of these nutrients in your product or making other distinctions. For example, consider highlighting the type of sugar in your product — natural, refined, or added. This may help consumers see past the symbol in their buying experience.
FOP Labelling FAQs
Still wondering what the new regulations might mean for your brand? Learn answers to common questions about the upcoming change.
What are the sizing requirements for the symbol?
It depends on how big your packaging surface area is. For example, if the principal display surface is more than 600 squared centimetres, then the symbol has to be 4.42 by 3.3 centimetres.
Health Canada provided updated regulations about buffer zones between symbols in 2023.2 Their webpage on this offers detailed tables for the size requirements and buffer zones for each symbol.
Will other countries face FOP labelling requirements?
In Europe, brands already display health ratings on the front of their packaging. Following suit, all brands will have to adapt to the Canadian FOP packaging requirements by 2026.
As for brands in the US, FOP labelling is not yet a legal federal requirement but is most likely on the way. It seems that the FDA is planning to propose similar regulations soon.3
The FDA's Mark Kantor told Crew that "[The FDA] is planning to propose a new regulation regarding front-of-package nutrition labeling."
Where can I find more information?
The Canada Gazette released a full webpage explaining all of the nutrition labelling changes.4
To assist food manufacturers and brands in meeting the new standards, Crew offers downloadable .eps files for the Canadian FOP nutrition symbols, fully compliant with Health Canada's guidelines and easily integrated into your packaging designs.
References
1. Health Canada. (2022, June 30). Front-of-package nutrition labelling. Canada.ca. https://www.canada.ca/en/health-canada/news/2022/06/front-of-package-nutrition-labelling.html
2. Health Canada’s notice of proposal regarding the buffer zone between the front-of-package nutrition symbol and the supplemented food caution identifier or between nutrition symbols. (2023, September 25). Canada.ca. https://www.canada.ca/en/health-canada/services/food-nutrition/public-involvement-partnerships/proposal-buffer-zone-front-package-supplemented-food-caution-identifier-nutrition-symbols/consultation.html
3. FDA. (2024, May 2). Front-of-Package Nutrition Labeling. https://www.fda.gov/food/food-labeling-nutrition/front-package-nutrition-labeling
4. Government of Canada, Public Works and Government Services Canada, Public Services and Procurement Canada, Integrated Services Branch, Canada Gazette. (2022, August 26). Canada Gazette, Part 2, Volume 156, Number 15: Regulations amending the Food and Drug Regulations (Nutrition symbols, other labelling provisions, vitamin D and hydrogenated fats or oils). https://canadagazette.gc.ca/rp-pr/p2/2022/2022-07-20/html/sor-dors168-eng.html
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