Mind the gap: Buffer zone changes for front-of-pack nutrition symbol and supplemented food caution identifier

Health Canada has confirmed modifications to the buffer zone requirements for front-of-pack nutrition symbols and the supplemented food caution identifier. This is good news for products with smaller labels, as this change will free up available label space on a product’s principal display panel.

On July 17, 2024, Health Canada issued a Notice of modification to the Directory of Nutrition Symbol Specifications and the Directory of Supplemented Food Caution Identifier Specifications (collectively the Directories) that permits displaying the front-of-pack (FOP) nutrition symbol and the supplemented food caution identifier (SFCI), or multiple FOP nutrition symbols, with no buffer space between them where they share a border. The modifications came into force July 15, 2024.

Since July 20, 2022, and July 21, 2022, respectively, the Food and Drug Regulations have required:

• prepackaged products to display an FOP nutrition symbol on their labels if they surpass certain thresholds of sugars, sodium, and/or saturated fats; and
• supplemented foods to display an SFCI on their labels if they carry cautionary statements.

As a result of these legislative amendments, the labels of certain supplemented foods are required to carry both an FOP nutrition symbol and an SFCI (for example, when a product is high in sugars and requires cautionary statements), while some prepackaged products are required to carry multiple FOP nutrition symbols (for example, when there is an assortment of foods in a package and one may be high in sodium while another is high in saturated fats).

Prior to the Directories' modifications, products that carried more than one FOP nutrition symbol, or carried an FOP nutrition symbol and an SFCI, required a buffer between these figures, resulting in a significant impact on label space, in particular for those products with smaller labels. The modifications to the Directories has removed the buffer zone requirements for those symbols that are contiguous, thus permitting variability in how these symbols are displayed and freeing up available label space¹.

Notwithstanding these modifications, a minimum buffer is still required for the other borders of each symbol when a product contains multiple FOP nutrition symbols, or when a product contains an FOP nutrition symbol and an SFCI. The minimum buffer zone requirements for all four borders also continue to apply for those products with a single FOP nutrition symbol or SFCI.