Food labeling requirements in Canada

Here is a useful bit that I wish I had known about from the beginning: In Canada, food manufacturers are legally obligated to disclose gluten ingredients in pre-packaged foods.

From the Pepsico Health & Wellness newsletter:

"In August 2012, Health Canada implemented new enhanced labelling regulations for specific priority food allergens, gluten sources and added sulphites in pre-packaged foods sold in Canada."  (emphasis added)

However, food makers are not obligated to have a statement regarding the possible "inadvertent" presence of gluten in foods:

"According to Health Canada, a food allergen precautionary statement is a declaration of the possible inadvertent presence of an allergen in a food. These statements may be made on food labels on a voluntary basis and are not regulated by Health Canada or part of the new labelling regulations. "  (emphasis added)

You can find confirmation and additional information on this on the Health Canada website.


Therefore, in Canada, it is a matter of discretion for manufacturers regarding just how clearly they disclose the potential presence of gluten.  Obviously various companies might take different positions.

This itself different than the USA.  In the USA, "major food allergens" as defined by the FDA must be disclosed.  This list includes wheat, but not barley, rye, or oats.  Companies are, therefore, free to not disclose barley, rye, or oats as secondary ingredients or potential cross-contaminants if they choose not to.


Fortunately, there are several major brands that do voluntarily disclose the potential presence of gluten.  Except - which ones?

Gizmodo has this somewhat handy-dandy graphic showing that most of the major brands are owned by just a handful of parent companies.  While some might be against this, it certainly makes things simpler when determining their policy and/or position on gluten labeling in food.

So far, I have been able to find the following indications that various brands are or are not intending to clearly mark their foods for the presence or possible presence of gluten.


Note: I have not personally confirmed these with any of the companies involved.  Their "reputation" is as reported by others, and not experienced by me.  Use this information at your own risk.


Kraft Canada:  Kraft has a reputation for clear disclosure.  Their statement:

"Kraft Canada ensures that any priority allergens, sulphites and gluten sources that are present in the formula, are listed in the ingredient line. In addition, many products have a separate CONTAINS statement immediately following the ingredient line restating priority allergen(s), sulphites and gluten sources present in the product. Our product formulas do change, so it is important that you read the label every time to ensure that a product is right for you. "

My experience thus far is that Kraft is very good at marking potential gluten content.  List of Kraft brands here.


Nestle:  Their email to Abisaac Saraga is a little confusing since it simultaneously says they label for nine priority allergens - none of which are gluten - while Health Canada has actually identified twelve (12) plus gluten.  But the email does initially say:

"If a priority food allergen, such as gluten, is not mentioned on the ingredients list or in the warning label on the product package then you can be assured it is not in the product."

From this I would expect they mean that gluten will be marked it if can be present.


P&G / Proctor & Gamble:  Their statement:

"If wheat and/or gluten aren't directly added to a product by us, these ingredients won't be listed on our packages.  Like many companies, we often purchase the scents for fragranced products from outside suppliers, and the components of these substances are proprietary information belonging to those companies. Therefore it's possible that a very small amount (generally parts per million) of gluten may be present. "  (Source)


Unilever:  Unilever has a good reputation for clear disclosure.  Their statement:

"Common ingredients that may contain gluten are rye, wheat, oats and barley, and noodles and pasta prepared with any of the previously mentioned grains. HVP, TVP, flavorings, are likely to contribute gluten as well, however, if they contain any gluten, the source would always be listed in the ingredient statements.

Since product formulations change from time to time, we do not have a printed list of products that identifies those products that contain specific allergens or gluten. The best advice we can give you is to check the ingredient list on the label."  (Source)  List of Unilever brands here.


Pepsico:  I cannot find evidence of any global allergen policy at Pepsico.  They did say:

"The Pepsi- Cola Company said there is no gluten in any carbonated soft drink produced by the company in North America."  (Source)



Coca-Cola:  "Diana Garza Ciarlante, a spokeswoman for the Coca- Cola Company, said the caramel color used in Coke products is derived from either corn or cane sugar. If an ingredient contains wheat, barley or rye it is labeled as such in the ingredient statement.

Consumers can also check the gluten- free status of Coke products by calling the 1–800 number on the product’s package."  (Source)