CFIA/HC Consultation on Future Food Regulatory Modernization Priorities


Health Canada’s Food Directorate is currently seeking input to help inform potential future food regulatory modernization priorities. Concurrently, they are also working with the Canadian food Inspection Agency (CFIA) to solicit any comments on measures to reduce food waste, including the possibility of reviewing Canada’s currently regulations for best before date labelling.

FBC-ABC is reviewing the stakeholder questionnaire materials (attached) and will be submitting a response. If you (or your team) have any input you would like us to consider in our response, please provide it to me by 12:00pm EST on Friday, July 14, 2023. Further details on the consultation, alongside the questions, can be found below.

PART I: Health Canada is seeking input to inform potential future priorities for its food regulatory modernization agenda – a preliminary list of potential priorities are as follows:

    1. Modernize the regulatory frameworks for foods for special dietary use and infant foods (Division 24 and 25 of the Food and Drug Regulations)
    2. New regulations to enable clinical trials involving foods for special dietary purposes (FSDP).
    3. Targeted amendments to the regulatory framework for novel foods (Division 28) in light of the new guidance published on May 16, 2022, as part of our Regulatory Roadmap commitments.
    4. Modernize the dairy-related regulations under Division 8 of the Food and Drug Regulations related to pasteurization.
    5. Amendments to the allergen labelling regulations for high protein ingredients.
    6. Amendments to the regulations pertaining to smoked fish (Division 21 of the Food and Drug Regulations).
    7. Modernize the regulatory framework for food irradiation (Division 26 of the Food and Drug Regulations).
    8. Amend the Food and Drug Regulations to accommodate plant-based foods.
    9. Accommodate products of cellular agriculture within the Food and Drug Regulations.
    10. Modernize regulations for food fortification, including the minor use of flour, Vitamin D in yogurt, and addressing expired interim marketing authorizations (IMAs).
    11. Modernize the regulatory framework for health claims on food.
    12. Proposed new regulations for mandatory caffeine labelling on food.
    13. Repeal the prohibition in Part E of the Food and Drug Relations related to cyclamate sweeteners.
    14. Proposed new regulations for menu labelling.
    15. Proposed new regulations to address online labelling for the Nutrition facts Table and ingredients.


  1. In your view, does this list accurately reflect and describe the key outstanding items/issues that need to be addressed? If not, please indicate any that are missing along with a brief description of the issue.
  2. Of the items set out in the list (including any missing items that you’ve proposed for additional), please rank, in order of importance, your top 5 items and briefly explain why these items should be prioritized.


PART II: Addressing food waste including potential revisions to Canada’s regulations for best before date labelling on foods


In the context of the Government’s efforts to address food waste, as well as CFIA’s and Health Canada’s ongoing consumer outreach regarding best before dates and expiry dates, the CFIA has the following questions:


  1. What purposes do best before dates serve for you or your members? Do they perform a function beyond communicating quality and freshness? Have you identified that best before dates contribute to food waste? If so, please explain.
  2. What regulatory changes, if any, would you propose to best before dates in order to support the goal of reducing food waste?
  3. Are there any other approaches (including non-regulatory) that would be effective in reducing food waste?
  4. What costs or business impacts would result from regulatory changes to current best before date labelling regulations?
  5. In light of the Health Canada/CFIA food labelling coordination policy “Food labelling coordination: joint policy statement”, should you need to change food labels as a result of modifications to the requirements for best before date labelling, what is the feasibility of the January 1, 2026 or January 1, 2028 compliance dates?