Food Regulatory Modernization

In 2018, Treasury Board launched a targeted review to identify regulatory practices and requirements that are bottlenecks to economic growth and innovation in the agri-food sector.  In 2019, Health Canada and the Canadian Food Inspection Agency (CFIA) committed to re-design the Food and Drug Regulations (FDR) through: 

• Modernizing compositional standards. 
• Modernizing regulatory frameworks governing health and safety rules related to microbiological criteria, methods of analysis, and food additives. 

Health Canada and CFIA presented their update on the Part B food regulatory modernization project in October 2022, which CHFA attended as a key stakeholder.

Health Canada’s plan includes amendments that would touch upon several hundred provisions.

At a high level, the proposed interventions can be grouped into 3 broad categories, as follows:

• Decoupling the Health and Safety rules from the Compositional Standards 
• Modernizing outdated frameworks
• Completing the modernization of the food additives framework that was initiated in 2012 (bring all under FDR)

The proposed modernization work would touch 3 existing frameworks.

1. Food Compositional Standards
2. Microbiological Criteria and Associated Methods of Analysis
3. Food Additives

The modernization WILL focus on the framework within which the technical rules are found, and WILL NOT include changes impacting labels or technical rules.

• The proposal includes removing trade and commerce content from the regulations and transcribing the same information into newly developed documents that will live outside the regulations and be incorporated by reference (IbR) to enable agility for future revisions.
• For the most part, health and safety content will remain in the regulations with the exception of areas of redundancies or duplications.

Current Advocacy Efforts

Starting spring 2023, CHFA will be working with government to improve Part B of the Canadian Food and Drug Regulations.  While the agility will offer timely response to new science, technology, & innovation, as well as flexibilities with international trading partners, CHFA will be closely evaluating the conditions in which they are set and possible future implications on industry.

We will advocate for agile regulatory change that can keep pace with advancements in science/technology, environmental changes, and an increasingly complex global food system. 

We are aiming for outcome-based regulatory measures that not only safeguard and promote the growth and innovation within of the health food industry, but also provide Canadian consumers with access to a wider array of safe and innovative food products.

• On July 28, 2023, CHFA provided feedback on Health Canada’s Future Food Regulatory Modernization Priorities to advocate for plant-based foods, food for special dietary purpose, and further consumer education of best before date labelling.
• On August 28, 2023, CHFA provided feedback on the Notice of Intent to Permit Vitamin D Fortification of Yogurt and Kefir in support of this initiative and requested the expansion of these efforts to plant-based alternatives.
• CHFA is aligned with modernizing the Food Compositional Standards to better reflect today’s market dynamics and evolving consumer preferences. On October 13, 2023, CHFA shared comments on the consultation for Engaging on Strategy for Modernizing Food Compositional Standards.
• CHFA continues to advocate for a more agile and transparent regulatory framework that aligns with emerging science and market innovations. On February 2, 2024, CHFA submitted feedback on Proposed Regulations Amending Certain Regulations Concerning Food Additives and Compositional Standards, Microbiological Criteria and Methods of Analysis for Food.
• CHFA supports modernizing food regulations to reduce regulatory burden and provide flexibility that allows for expanded business opportunities in new product categories. In addition, CHFA responded to the proposal to modernize the regulations for foods for special dietary use and infant foods with a feedback letter on February 26, 2024.
• On February 28, 2024, CHFA submitted comments on the Proposed Updates to the Table of Reference Amounts for Food.