While federal and state regulators here in the U.S. debate how to label analogue meat, poultry and fish products, the Canadian Food Inspection Agency (CFIA) has been using the term “simulated,” and the agency recently published new guidance on how to label and market these products.
Here in the States, Congress is debating requiring the word “imitation,” as proposed just last week in the reintroduced Real MEAT Act.
“Although the [Canadian] regulation itself has not changed, the guidance provides new information for producers, defining the regulatory definition, clarifying labeling and composition requirements and explaining when food products do not meet the definition of simulated,” wrote The Acheson Group (achesongroup.com), a food safety and regulatory consulting agency.
Simulated meat and simulated poultry products are defined under the Food and Drug Regulations as foods that do not contain meat, poultry or fish products but have the appearance of such. Some key points of the new guidance, according to Acheson Group:
- A simulated meat or poultry product resembles a meat or poultry product due to its visual appearance, texture, flavor, odor, etc., as well as how it is advertised and represented. It is to be identified on its label by the word simulated followed by the common name of the product it simulates. This could be the animal species (e.g., beef, pork) or the meat cut (e.g., sirloin, chicken tenders), with the word simulated in the same size and prominence as the common name.
- It must carry the declaration “contains no meat” or “contains no poultry” on the principal display panel of the label, in close proximity to the common name and in letters of at least the same size and prominence as those shown in the product’s common name.
- The product must carry a Nutrition Facts table (NFt) on the label, with added vitamins and minerals declared in absolute amounts and as a percent daily value per serving of stated size in the NFt.
- It must meet the minimum protein content and rating requirements, must not exceed the maximum requirements for fat content, are mostly made of plant-based ingredients but may contain other ingredients, animal products (such as dairy or eggs) or food additives.
When these products are not prepackaged, the “contains no meat” or “contains no poultry” declaration shall be shown on a sign displayed on or adjacent to the product in letters that are legible and conspicuous.
When used as an ingredient of another food (e.g., soup), the declaration “contains no meat” is not required, but the label may not display any pictures or vignettes suggesting that meat is present, unless added through another ingredient.
Generally, marketers may use claims, advertisements and representations that are truthful, are not misleading or prohibited and are compliant with all requirements.
For Acheson Group’s deeper dive into the Canadian regulations, click here.