March 7, 2000
The Hon. Allan Rock, P.C., M.P., Minister of Health
Room 441-S, Centre Block
House of Commons
Ottawa, Ontario Canada K1A 0L2
Dear Minister Rock:
The Alliance for Food Label Reform is a coalition of 17 non-profit organizations representing nearly 2 million consumers, health professionals and scientists from all across Canada. The Alliance is committed to improving the federal government's nutrition labelling laws and policies.
In the two years since Health Canada commenced a review of federal nutrition labelling rules, it has failed to deliver an options paper (promised for September 1998) or a policy recommendation (promised for June 1999 and then promised for late fall 1999). A Health Canada official indicated to CBC Radio on December 24, 1999 that a policy recommendation would be announced in "the new year." No recommendation has been announced as yet. The Alliance is troubled by the repeated delays in action on this important public health matter.
Canadians need comprehensive, easy-to-read nutrition labelling on all foods to help them improve their families' diets, and reduce their risk of heart disease, cancer, osteoporosis, diabetes, and other illnesses or conditions. Accordingly, nutrition information should be provided on all food labels, not just on foods for which manufacturers choose to make marketing claims that trigger disclosure requirements. The overall objective should be to achieve nutrition labels on nearly 100% of foods sold in Canadian retail stores. We recognize the need to make special arrangements to accommodate very small packages, very small food companies and foods used in religious ceremonies, however, those measures should not unnecessarily detract from the overall objective of 100% coverage.
Public health priorities, not manufacturers' marketing considerations, should govern what nutrition information appears on food labels. This information should be clearly reported for all nutrients related to the incidence of chronic disease, including: calories, total fat, saturated fat, trans fat, cholesterol, fibre, sodium, potassium, total carbohydrate, added sugars, protein, iron, calcium, folic acid, vitamin A and vitamin C. This nutrition information should be based on standardized customary serving sizes and presented in a manner that helps consumers determine how much a serving of a food contributes to the appropriate daily intake of nutrients.
In last year's public consultation on the subject, there was near-unanimous support for mandatory nutrition labelling from 130 health, consumer and educational organizations that submitted comments. In addition, submissions from the provincial governments of Ontario, British Columbia, Saskatchewan and Prince Edward Island, and municipal health authorities in Toronto and Ottawa-Carleton strongly favoured a mandatory nutrition labelling system. We were also delighted to see considerable support for mandatory nutrition labelling from the food industry. Nearly half of the food industry comments that addressed the issue supported, or at least did not oppose, a mandatory requirement for nutrition labelling. Furthermore, a recent public opinion poll commissioned for Health Canada shows that an estimated 93 per cent of Canadians believe that nutrition information should be on all or most foods.
This growing agreement among all stakeholders, including the food industry, in support of mandatory nutrition labelling sets a clear direction for action to be taken by Health Canada on this vital public health matter. We remain convinced that the government should support amendments to the Food and Drugs Act to require complete nutrition labelling on all foods. A legislative amendment would give this important public health measure the stature it deserves and provide Health Canada with a mandate to complete its consultation in a timely manner.
Therefore, we urge you, as Minister of Health, to support Mr. Tom Wappel's Bill C-319, An Act to Amend the Food and Drugs Act (nutrition information on food). With our assistance, Mr. Wappel has obtained endorsements from at least 103 MPs for his petition to by-pass the lottery system and bring his mandatory nutrition labelling bill to a debate and vote in the House of Commons. (Only seven of the 248 private members' bills introduced in this session have been supported by such a petition.)
We also urge you to ensure that the Canadian Food Inspection Agency has adequate resources to properly enforce the standards proposed by the bill, and ensure that Health Canada has adequate resources to educate consumers about the use of this important health information.
We look forward to your prompt response to our concerns and note, with considerable regret, that we have not yet received a reply to our letter dated July 5, 1999.