Home/Food and Beverage/CFIA Update on labeling for Plant-based and Simulated Meat Products

This past summer the CFIA released a report on feedback received from an online open survey to stakeholders and consumers regarding what labelling information is important to them for plant-based and simulated meat products.

Once relegated to the confines of health food stores and farmers markets, plant-based and simulated meat substitutes are finding their way into mainstream channels.  Their rising popularity is driven mainly by consumer focus on health and concerns with the impact that traditional meat products are having on the environment.

In light of these shifting consumer preferences, industry and government agencies both in Canada and around the world have engaged in debates surrounding labelling policies, practices, and regulations for plant-based and simulated meat products versus traditional meat and poultry products. For example, earlier this year in the United States, traditional meat industry participants were seeking to prohibit the use terms like “meat” and “milk” on plant-based products even though the products used qualifiers such as “diary-free” or “plant-based”.

As the plant-based and simulated meat industry is expected to continue to grow and expand, the CFIA’s goal is to establish how these non-traditional products will be labelled whereby product types are clearly and accurately communicated in order to help consumers to make informed choices.

The CFIA proposed solution breaks down product types across three categories and are as follows as outlined in their update:

  • Category 2: These include simulated meat and simulated poultry products that purposely intend to resemble and substitute the look and taste of a category 1 meat product (e.g., the non-meat product formulated to resemble a traditional burger by adding components to simulate bleeding or fat marbling effect).
    • Products must meet the minimum protein content and rating, fat content, vitamins and minerals, and amino acids requirements of the meat or poultry product intended to substitute as per [D.03.002, FDR]
    • The products would need to use the term “simulated” in their common name alongside the meat product or poultry category name.  For example, “simulated chicken breast” or “simulated beef tenderloin” would be used.
    • The products would also need to declare “contains no meat,” or “contains no poultry” on the principal display panel. When the simulated meat is used as an ingredient, the declaration “contains no meat” will not be required provided the product does not contain a category 1 product.
  • Category 3: These products fall into the plant-based foods category and do not intend to act as substitutes for meat or poultry products (e.g., tofu and soy burgers).
    • These products may, but need not, declare “contains no meat” on their labels. However, they must be clearly labelled and advertised in a manner that truthfully and accurately describes the product. For example, the common name on the packaging can be include the major ingredient in the product such as “veggie burger, tofu burger, Portobello mushroom burger, lentil loaf, soy patty”.
    • Fortification of these products is prohibited.

Highlights from the survey revealed that the majority of respondents were confident distinguishing traditional meat products from simulated meat and plant-based products.  As well, respondents were also open to the idea of expanding terms like “meat”, “burger” and “sausage” to include non-traditional meat products. The concern from the traditional meat industry argued against the plant-based industry using these terms as the true nature, composition and nutrition of plant-based products may mislead consumers. Collectively, the plant-based and animal-based industries along with many consumers agreed that plant-based foods are separate and unique and should not be compared to meat and poultry products.

Final Guidelines for Simulated Meat and Poultry

The CFIA published the final guidelines for simulated meat and poultry on September 17th. The CFIA defined simulated meats as “as having the physical and nutritive characteristics of meat or poultry” and a minimum protein rating as sold (prior to cooking). For example, “a simulated meat product that resembles ground beef must have a protein rating of not less than 40.”

The guideline establishes the common name for simulated meat products through the use of “simulated” followed by the meat or poultry type to be displayed on labelling and across advertising. As well, the phrase “contains no meat” or “contains no poultry” is also required on the principal display panel of the label in close proximity to the common name, using a similar text size or having the same prominence. Additional guidelines include nutrition labelling requirements for specifying added vitamins and minerals.

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At MCS Associates, our food safety and quality experts are keeping a close eye on developments as they materialize. Contact us at enquiries@mcs-associates.com to support your labeling, registration, and Preventive Control Plan requirements.

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