Allergen and Gluten Labelling on Natural Health Products are Changing

What are Natural Health Products?

According to Health Canada, “Natural health products (NHPs) are naturally occurring substances that are used to restore or maintain good health. They are often made from plants, but can also be made from animals, microorganisms, and marine sources. They come in a wide variety of forms like tablets, capsules, tinctures, solutions, creams, ointments, and drops. Many everyday consumer products, like certain toothpaste, antiperspirants, shampoos, facial products, and mouthwashes are also classified as natural health products in Canada.”[1]

Natural health products often called “complementary” or “alternative” medicines, include:

• vitamins and minerals
• herbal remedies
• homeopathic medicines
• traditional medicines like traditional Chinese and Ayurvedic (East Indian) medicines
• probiotics
• other products like amino acids and essential fatty acids

Why Natural Health Products Matter to People with CD

Until July 2022, natural health products had no standards on how priority allergens, gluten or aspartame ingredients were to be identified on natural health products, leaving the celiac community open to serious adverse reactions to products meant to improve their health.

How is the CCA Involved?

From 2018 – 2021, CCA was one of the major stakeholders working with Health Canada to help advance the introduction of priority allergen labelling including gluten on natural health products. In September, 2021, the CCA, along with local chapters, submitted a formal submission to the federal government advocating for the protection of the gluten-free community’s health.

Click to read the CCA’s official submission

In July 2022, we are pleased to announce that these regulations have been approved by the federal government. Implementation will take up to six years for compliance, so we encourage our community to be diligent during this time. 

“This is a major milestone for people with celiac disease,” says Melissa Secord, National Executive Director of the CCA.  “Health Canada has shown its commitment to protect Canadian consumers with severe food reactions and make it a priority to protect their health, safety and increase accessibility. We also applaud their efforts to assist citizens who have visual impairments by standardizing text size and colour contrast on labels.” 

 “We also want to thank the gluten-free community and local chapters who supported us in the public consultations by sending letters which helped these regulations come into force for the protection of our health.” 

 “We look forward to working with Health Canada, the Canadian Inspection Agency (CFIA) and gluten-free NHP product partners during the transition and ongoing monitoring to keep our community safe. “

 CCA will be participating in post-launch regulation meetings and stay tuned for updates and more useful tools to help you navigate your stores. 

  To read more about these changes, please visit Canada Gazette, Part 2, Volume 156, Number 14: Regulations Amending the Natural Health Products Regulations.  

What You Need to Know

What do these changes include? 

Product Facts Table 

• For consumers it means the Product Facts Table will be standardized in appearance with text that will be clean (sans serif), not decorative for easy reading, with good contrast to help people with visual impairments or reduced vision.  

• Text must appear on a white or plain neutral background. 
• The font will be no less than 5.5-point size for non-medicinal ingredients like gluten sources. 
• As a consumer the Product Facts table shall contain only the following headings in the following order: 
• (a) “Medicinal ingredients / Ingrédients médicinaux”; 
• (b) “Uses / Usages”; 

• (c) “Warnings / Mises en garde”; 
• (d) “Directions / Mode d’emploi”; 
• (e) “Other information / Autres renseignements”; 
• (f) “Non-medicinal ingredients / Ingrédients non médicinaux”; and 
• (g) “Questions?”. 

Allergen and Gluten Labelling 

• All priority allergens including gluten and aspartame-containing ingredients will be required to be on both product inner and outer packaging both listed as Warnings/Mise en Garde Section (in bold type) followed by the food allergen source, gluten source and added sulphites statement, also in bold type.
• Note: if there is no risk information, including any cautions, warnings, contra-indications or known adverse reactions associated with the use of the natural health product, the heading “Warnings / Mises en garde” or the headings “Warnings” and “Mises en garde” can be omitted from the table. 
•  If gluten is to be listed as an ingredient, it should indicate gluten with the common name of the source in brackets immediately following. For example: gluten (wheat) 

Modernized Contact Information

• Contact information will now include website and email addresses so that you can contact the company with your questions. 

Digital Labelling

•  The information that is required to be shown in a package insert or on a website shall appear in a table that complies with the requirements of the outer label and product display. Priority has been given to what information people need to make a point of purchase versus point of use. 

What is not covered? 

Certain exemptions are provided to accommodate products in very small packages, products that are relatively low-risk, products that are to be used within one day or less (as per the directions on the label), and products with package(s) that contain, at most, three dosage units. 

For more information from the CCA, please contact info@celiac.ca  

What else needs to be done?

• On-line Shopping – There needs to be regulations surrounding how natural health products are sold online. Consumers need to have access to the same product information online as they would shopping in person. In addition, manufacturers cannot ‘bait and switch’ or substitute products. Products shown must be available for sale in Canada and meet the regulatory requirements as if sold in store.

How you can help!

• Click here to learn more about what is changing.
• Click here to read the CCA’s official submission to the government.
• Have a question? Email info@celiac.ca with your questions or comments.
• Click here to make a donation to support advocacy efforts for people with celiac disease.

References.

1 About Natural Health Products – Canada.ca

Learn More

Melissa Secord, CCA Executive Director, sits down to chat about changes to the Natural Health Product regulations and what it means for the gluten-free community with Matthew Bown, Associate Director of the Bureau of Policy, Risk Management and Stakeholder Engagement in the Natural and Non-Prescription Health Products Directorate from Health Canada.