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Open consultation for standardized beer: Our recommendations

The Canadian Food Inspection Agency (CFIA) is requesting public input by September 14, 2018 on the proposed amendments they want to make to the Food and Drug Regulations so beer compositional standards can be updated.

The amendments include new requirements for brewers to identify food allergens, gluten sources, and added sulphites for prepackaged standardized beer, ales, stouts, porters, and malt liquor. Currently, standardized beer is exempt from this labelling.

Below is our submission to the CFIA for this consultation. Have your say and provide your submission to the CFIA before September 14, 2018, click here to learn more.


July 30, 2018

Director, Consumer Protection and Market Fairness Division
Food Safety and Consumer Protection Directorate
Canadian Food Inspection Agency
1400 Merivale Road, Tower 2
Ottawa, Ontario K1A 0Y9

Sent via email: labelling_consultation_etiquetage@inspection.gc.ca

Re: Beer Compositional Standards Consultation Canada Gazette Part I

Food Allergy Canada has been pleased to participate in the ongoing public consultations related to beer compositional standards. With the recent publication of the proposed amendments in Canada Gazette Part I, we are very pleased that the current exemption for the declaration of food allergens, gluten sources, and added sulphites for prepackaged standardized beers, ales, stouts, porters, and malt liquors is being removed, and new requirements for brewers to identify these ingredients on the product label will now be required.

On behalf of the over 2.6 million Canadians with food allergies that we serve, this is very welcome news. The exemption afforded to the beer industry in the 2012 Enhanced Allergen Labelling Regulations has been an ongoing concern. Canadians with food allergies, and those who shop for them, depend on complete and accurate ingredient information on the foods and beverages they purchase to make an informed and safe choice. As even a small  amount of an allergen, if ingested, can cause a potentially life threatening allergic reaction, it is critically important that allergen information be clearly labelled. We appreciate that Health Canada recognizes that all Canadians  have a right to know what is in their beer.

We would like to reiterate the recommendations we put forth last year during the initial public consultation, which we believe are consistent with the Government of Canada’s approach to providing greater transparency and openness to further strengthen Canadians’ trust in the regulatory decisionmaking process. This includes the specific recommendation that allergen labelling be extended to individual bottles, cans, kegs, and on-tap containers. These recommendations will help to keep consumers with food allergy safer and create practices that are consistent with current labelling requirements for pre-packaged food products in Canada.

Specific recommendations (as per our July 2017 submission):

  1. List all applicable priority allergen information on standardized beer products
    If the definition of standardized beer is changed, a provision must be added that requires all priority allergens contained in the beer to be listed in a “Contains” statement on the outside packaging of these products, and on each individual container of beer (e.g. bottle, can, keg, or on-tap container). This is particularly important if the criteria for standardized beer is expanded to include additives and flavouring ingredients, which could include priority allergens.
  2. Remove the exemption for priority allergen labelling for standardized beer 
    It is imperative that the product labelling of beer be brought in line with the 2012 Enhanced Allergen Labelling Regulations for alcoholic beverages, which requires manufacturers to declare food allergens or gluten sources, either by adding a list of ingredients or using a “Contains” statement on the label.
  3. Enhance education and consultation
    If the standardized beer formula is changed to include allergens it must be accompanied with rigorous education for industry, consumers and for those who sell and serve standardized beer.

Going forward, we ask that patient and medical groups always be consulted, along with industry, on food or beverage issues pertaining to possible allergen concerns. As the leading national patient organization advocating for Canadians with food allergies, we are pleased to work with government, industry, the medical community, and other key stakeholders to develop reasonable policies to accommodate people with food allergies and reduce the risk of serious reactions. Our approach to reducing the risk of allergic reactions is focused on self-management, community engagement, understanding, and respect.

We thank Health Canada and the Canadian Food Inspection Agency for their support of Canadians living with food allergy and their commitment to provide clear and accurate product information for this growing consumer segment. As always, we remain committed to working with Health Canada and all stakeholders to ensure their swift and effective implementation.

We are also inviting members of our community to share their comments on these proposed regulations.

If you have any questions, please do not hesitate to contact me. We look forward to further opportunities to share the views of the food allergy community on this important safety issue.

Sincerely,

Jennifer Gerdts
Executive Director, Food Allergy Canada