Food Allergen Labelling in Canada

by Carol T. Culhane, P.H.Ec. MBA

Food allergies affect an estimated 5 to 6% of Canadian children and 3 to 4% of Canadian adults. A much larger percentage of the population suffers from a food intolerance, which does not trigger a defense response from the body’s immune system following ingestion. A food intolerance, however, may exhibit symptoms similar to that of a food allergy.

Therefore, the accuracy of the ingredient information on the label of pre-packaged food is a very important safety concern for consumers.

The allergenic component of a food allergen is a protein. Proteins vary by nature in several ways, such that some can cause allergic reactions. In Canada, a ‘priority food allergen’ is one which health officials and regulators regard to be ‘frequently associated with food allergies and allergic-type reactions’.

Twenty-two different ‘priority food allergens’ have been identified by Canadian authorities including:

  • any gluten protein or modified gluten protein from barley, oats, rye, triticale and wheat;
  • any protein or modified protein portion of any tree nuts (almonds, Brazil nuts, cashews, hazelnuts, macadamia nuts, pecans, pine nuts, pistachios, walnuts);
  • peanuts, sesame seeds, wheat, triticale, eggs, milk, soybeans, fish, crustaceans, seafood and mustard seeds;
  • sulphites at a concentration equal to or exceeding 10 ppm (parts per million) present in either food or alcoholized beverages.

It is important to know thatCanada’s list of ‘priority food allergens’ differs from that of theUSA-Canada’s largest trading partner.

Canadian food labels will soon list priority food allergens to help you avoid an allergic reaction.

Food allergies are recognized as an important food safety issue and when not readily and easily identified, can pose a significant barrier to safe food access by food allergy sufferers. Effective August 4, 2012, detailed regulations will officially mandate, strengthen and greatly clarify the disclosure of priority food allergens in food offered for sale inCanada. Any food ingredient sourced from a ‘priority food allergen’ must declare the allergen by its official name, either within the list of ingredients or in a ‘Contains’ disclosure at the end of the ingredient list on the product label.

To realize the effect of these allergen-labelling regulations, consider the labels on the following foods purchased for a Grey Cup party which will all bear different information when Grey Cup season rolls around in 2012.

Packaged Food Product Current Ingredient Labeling New Ingredient Labeling
Cake Mix Sugar, flour, ovalbumin, [various additives] Sugar, flour (wheat), ovalbumin (egg), [various food additives].


Sugar, flour, ovalbumin [various food additives]. Contains: Egg, Wheat.

Potato Chips Potatoes, sunflower oil, salt, seasonings Potatoes, sunflower oil, salt, seasonings (mustard).


Potatoes, sunflower oil, salt, seasonings. Contains:  Mustard

Croissants Flour, butter, egg, milk, vegetable oil, sugar, modified gluten, lecithin, yeast Flour (wheat), butter1, egg, milk, vegetable oil (soybean), sugar, modified gluten (rye), lecithin (soybean), yeast.


Flour, butter, egg, milk, vegetable oil, sugar, modified starch, lecithin, yeast.  Contains: Wheat, Soybean,Ryegluten

Wine containing ≥10 ppm sulphite content Sulphite content not disclosed Contains: Sulphites2


1Repetition has been avoided. Although the source of the butter is milk, milk need not be identified in the ingredient list or in the Contains statement, as it is already declared as an ingredient.

2A full ingredient statement on the label of an alcoholized beverage is not currently required, nor will it become so, as a result of the new food allergen legislation.

An allergy to gluten, a wheat protein, is the only food allergy known to date, to be genetically inherited. This allergy is called Celiac disease and affects at least 1% of Canadians. A legal definition of ‘gluten’ and ‘gluten-free’ food were each subjected to extensive assessment with a broad range of stakeholders in preparation for the regulatory amendments, resulting in exclusive specifications for these terms in the amended food regulations.

The new Canadian food regulations specify that a ‘gluten-free’ food is one that does not contain any gluten protein, gluten protein fraction or modified gluten protein from barley, oats, rye, triticale or wheat. In contrast, theUSAand the EU do not recognize gluten from oats as a priority food allergen. Further, these countries permit a gluten concentration of up to 20 ppm for a food labeled as ‘gluten-free’.

Subsequently, some food recalls in Canada are triggered by foods imported from the USA and the EU, which comply with the allergen disclosure regulations in the countries of origin, but are non-compliant inCanada. Owing to this difference of opinion amongst Canada’s trading partners, and the needs and aspirations of affected consumers and the food manufacturing industry, Health Canada will be issuing a guidance document on the aspect of the < 20 ppm gluten threshold, and the Agency’s position on gluten derived from oats.

Consumers should continue to read food labels thoroughly and realize that changes in Canada’s food allergen labelling will come into force onAugust 4, 2012, designed to help them avoid an allergic reaction and enhance their access to safe food. More information is available on the Health Canada website:



Carol T. Culhane, P.H.Ec., MBA is a Toronto-based Professional Home Economist and President of International Food Focus Ltd. She is an expert on food law in Canada, USA, European Union and United Kingdom. Website: The author is a member of the Ontario Home Economics Association.

Ontario Home Economics Association (OHEA) a self-regulated body of Professional Home Economists promotes high professional standards among its members so that they may assist families and individuals to achieve and maintain a desirable quality of life.

For further information, please contact: Ontario Home Economics Association, 14 Totten Place, Woodstock, ON          N4S 8G7  Tel/Fax: 519-290-1843  Email:  Website:

2 thoughts on “Food Allergen Labelling in Canada

  1. Wendy Barker

    It’s interesting that the gluten-free label is going to be applied to foods which do not contain protein from oats when the Canadian Celiac Association says that uncontaminated oats are allowed ( and Health Canada has said that their scientific review shows that most people with celiac disease can tolerate uncontaminated oats ( The protein in oats, avenin, is sufficiently different from the protein in wheat, rye and barley that most people with CD do not react to it. Also the amount of protein in oats is significantly less than in the other cereals. My husband, who has celiac disease, has oatmeal for breakfast every day and his yearly blood tests for the antibodies to gluten have been fine. It would be a shame if people stopped eating oats because they can’t be labelled as gluten-free. I wonder what the people at Aveeno Foods, who produce uncontaminated oats for sale, are going to do now.

  2. Carol T Culhane

    Hello Wendy,

    I see that you are aware of Health Canada’s current position on the exclusion of oats in a food labelled as ‘gluten free’. Also, the Agency is aware of uncontaminated oats and the reduced likelihood of a celiac reaction to these oats, given their purity. My understanding is that Health Canada’s position has not been finalized. Canadian legislation continues to prohibit the presence of oats in a food labelled gluten-free.
    You may find it interesting that the FDA and thus, US food legislation, does permit oats to be present in a food labelled gluten-free, for several reasons:
    1. It adds variety and diverse nutrients to what is otherwise a bland and nutrient-narrow diet;
    2. Many celiacs can tolerate oats (as per US celiac association)
    3. A threshold of 20 ppm oats is in place, which, if exceed, negates the ability to label a food gluten-free.

    I have clients in the USA who use Canadian uncontaminated oats in their gluten-free formulations.

    In the interim, I am pleased to hear your husband can easily consume oats, for reasons of dietary variation and nutrient diversity.


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