Health Canada Proposed Plant-Based Egg Alternative Guidance

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Health Canada Solicits Comments on Plant-Based Egg Alternative Labeling Guidance

by: Food and Drug Law at Keller and Heckman of Keller and Heckman LLP - The Daily Intake

Wednesday, September 25, 2024

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At the end of July Health Canada announced a proposed guidance document on the labeling of plant-based egg alternatives with comments due by October 28, 2024.
The guidance is not highly prescriptive and instead applies a flexible approach which evaluates the product labeling as a whole to determine whether the product avoids creating a false or misleading impression by providing sufficient information so that consumers understand what the product is and that it is not an egg product.
In determining whether a product complies with this standard, Health Canada will look to information including the product’s common name, any claims or statements made on the label, the list of ingredients, images on the product, and how the product as a whole appears or is represented.
For example, the guidance indicates that a common name such as “‘plant-based omelette’ does not accurately and precisely describe what the food is” and that a more explicit name such as “soybean protein omelette” is preferred. As this example implies, terms associated with egg products are acceptable so long as they are appropriately qualified.
Nutrient content claims are permitted so long as they are truthful and not misleading and they meet the specific regulatory requirements for such claims. Negative claims (e.g., egg-free) may also be useful in communicating the nature of the product to consumers, although such claims are only permitted if the product contains no sources of egg allergen. Furthermore, product images and other features contributing to the product’s general appearance which imply that the product is an egg product (e.g., an image of a farm and/or packaging similar to traditional egg products) must be considered and balanced with other complimentary information.