Can my product (an aseptically shelf stable ready-to-eat pudding) that is made in the U.S. and labeled for sale in Canada state “2% or 1% or less” in the ingredient statement?
(November 2010) Canadian regulations make no mention of an “X% or less” clause for ingredient statements. In the U.S., the clause “2% or less of the following” (or 1.5%, 1%, or 0.5%, as appropriate) can be used at the end of the ingredient statement to list minor ingredients in any order. Canadian regulations specify that ONLY specific classes of ingredients can be shown at the end of the ingredient statement in any order. For these specific classes of ingredients in Canada, the “X% or less of the following” clause could be used, but it is not common practice because it significantly lengthens the ingredient statement given the English-French bilingual labeling requirement. In Canada, the specific classes of ingredients that can be shown in any order at the end of the ingredient statement include: spices, seasonings and herbs (except salt), natural and artificial flavors, flavor enhancers, food additives, and vitamin and mineral nutrients and their derivatives or salts. For more inform