CSPI Centre for Science in the Public Interest
Centre pour la science dans l’intérêt public

July 5, 1999

The Hon. Allan Rock, P.C., M.P., Minister of Health
Room 441-S, Centre Block
House of Commons
Health Canada
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 weak nutrition labelling laws and policies.

While we are encouraged by Health Canada’s efforts to reassess nutrition labelling rules, we have not seen any evidence of a commitment by the federal government to require food manufacturers to put comprehensive nutrition information on all foods, not just when a nutrient claim is made. We would like to stress that Canadians need comprehensive, easy-to-read nutrition labelling on all foods to help them improve their diets and reduce their risk of heart disease, cancer, osteoporosis and other illnesses. Accordingly, nutrition information should be provided for all foods, not just foods for which manufacturers choose to make marketing claims that trigger disclosure requirements. While we recognize the need to provide exemptions from such requirements for very small food manufacturers, the overall objective should be to achieve nutrition labels on nearly 100% of all foods sold in Canada.

Public health priorities, not manufacturers’ marketing considerations, should govern whether nutrition information appears on food labels. This information should be 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, folacin, 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.

We trust that Health Canada will not falter in providing mandatory, comprehensive, and easy-to read nutrition labelling on all foods. We also expect Health Canada to provide adequate resources to properly enforce those standards and educate consumers about the use of this important health infomration. Our members look forward to seeing Health Canada’s regulatory proposal this fall.



Bill Jeffery, L.LB.
Centre for Science in the Public Interest
Linda Piazza, R.N.
Canadian Nurses Association


Claude Renaud, BSc, MD, CCFP, FCFP
College of Family Physicians of Canada
Anne Marie Tassé
Action Réseau Consommateur


Edith Johnston
National Pensioners & Senior Citizens Federation
Linda Peterat, Ph.D., R.P.H.Ec.
Canadian Home Economics Association


Pierre Douville, MD, FRCP(C)
Canadian Association of Medical Biochemists
Ellen Desjardins, B.Sc., M.H.Sc.
Ont. Soc. of Nutrition Professionals in Public Health


Debbie Field
FoodShare Metro Toronto
Maude Barlow
Council of Canadians


Rod MacRae, Ph.D.
Toronto Food Policy Council
Pamela Martin
Canadian Home Care Association


Laurie Beachell
Council of Canadians with Disabilities
Libby A. Gardon
Consumer Health Organization of Canada


Paula Robeson, R.N., B.N.
Canadian Institute of Child Health
Rob Henderson
Canadian Dental Assistants’ Association


Leonard Harrison, President
National Retired Workers Advisory Council


cc.The Right Hon. Jean Chrétien, P.C., M.P.
Dr. Grant Hill, M.P., Reform Party Health Critic
Ms. Judy Wasylycia-Leis, M.P., New Democratic Party Health Critic
Mr. Greg Thompson, M.P., Progressive Conservative Party Health Critic
Madame Pauline Picard, M.P., Bloc Québécois Health Critic
Mr. Tom Wappel, M.P.
CSPI Canada