Off label: the unintended consequences of label changes for consumers

While it is important for Canadians to be aware of the contents in products they consume, they already have the information they need to make informed choices.

In recent years, there has been a growing demand for clear and accessible information about the foods and beverages we consume. In response, Health Canada has introduced new labelling regulations to inform parents and consumers in making “healthy choices,” and to educate about the risk of overconsumption. These changes have significant implications for beverage producers, both large and small. While they may appear to increase transparency and certainty for consumers, there is a hidden cost to these changes: business competitiveness.

As a leading voice for the beverage industry in Canada, the Canadian Beverage Association (CBA) is committed to ensuring that consumers have the data they need to make informed choices about beverage products. With that said, we believe that any changes to labelling requirements must be made with a clear understanding of the impact they will have on the market, as well as the costs and challenges that they will pose for our industry.

We recognize that labelling requirements can play an important role in helping consumers to make informed choices about the products they consume. That is why we have been working closely with regulators and other stakeholders to ensure that our labels provide clear and accurate information about the products we produce and distribute. Our members, including some of the most recognized brands in the world, have voluntarily listed calories on the front panel of packaging since 2011, through the “Clear on Calories” initiative.

The average cost to producers when product labels change due to government regulation can vary widely depending on the specific regulations and the size of the producer. Generally, the cost of changing product labels includes expenses such as design and printing of new labels, updating marketing materials, and potentially reformulating products to meet new requirements. These costs increase exponentially when labelling changes lack predictable timelines and are not co-ordinated across government jurisdictions such as Environment and Climate Change Canada, and Health Canada.

For smaller producers, the cost of label changes can be a significant burden, potentially leading to decreased competitiveness, as they may have fewer financial resources to invest in compliance. While the public may think larger producers may have greater financial resources and economies of scale that allow them to more easily absorb the costs of label changes, they often have an even greater challenge. Large producers face cross-jurisdictional challenges with labelling compliance, and have bigger logistical challenges.

While we agree that it is important for consumers to be aware of the contents in the products they consume, consumers already have the information they need to make informed choices on labels. Any changes to labelling requirements must be made in consultation with industry, and with a clear understanding of the impact they will have on the market, and a plan to inform consumers on what it means. For example, the soon-to-appear front-of-package label symbols will likely create uncertainty and confusion in the market without an effective education program.

Moreover, we believe that there are other, more effective approaches to educate consumers about product choice. For example, the beverage sector has spent millions of dollars on public education campaigns and incentives for retailers to stock healthier beverage options. These approaches promote healthier choices among consumers without imposing unnecessary costs and burdens on our industry.

Today, low-calorie non-alcoholic beverage servings, including those that contain aspartame, have outstripped their full-calorie counterparts and become mainstream over the past decade. Consumers are making informed choices.

In conclusion, the CBA is committed to ensuring that consumers have the information they need to make informed choices about the products they consume. However, we believe that any changes to labelling requirements must be made in collaboration with industry, and with a clear understanding of the costs and challenges that they will pose for our industry. Without taking this regulatory burden into account, Canadian food and beverage producers, regardless of their size will have yet another barrier to innovation and growth.

Krista Scaldwell is president of the Canadian Beverage Association, an industry association representing Canada’s non-alcoholic refreshment beverage industry. In 2020, Scaldwell was named one of Canada’s Top 100 Women of Influence by the Women’s Executive Network.

The Hill Times