Proposed Health Canada Supplement Label Changes: A SierraSil Perspective

Remember that feeling of freedom in your youth when heading out on your bike? A recent diagnosis of tendonitis in my right foot from too much running (and not enough stretching) refocused my activities to include more biking - and I am enjoying it!

Living in Vancouver, I've got a modest, commuter-style bike, as it seems any bike worth stealing will be stolen. While my bike isn't particularly light or quick, it is enough of both to be fun going around traffic-calming circles and breezing down hills (while wearing my helmet, of course!). It’s not too bad going up slopes, where I remind myself that I'm building strength in my legs that will serve me well. I still ogle the really cool e-bikes (like the Van Moof) or Specialized bikes that I see, but for now, my plain commuter bike will do just fine!

So before summer is gone, and in its place are the autumn rain and more hurried schedules, I encourage you to visit a joy of your past. That could be riding a bike, swimming in a lake or even flying a kite. Do something fun that brings about a youthful smile or gasp of humility (“gee, this was so much easier decades ago” or “hey, I’ve still got this”)!

Speaking of changes, for our Canadian customers, just thought I'd let you know that Health Canada has a Guidance document regarding labels that they are inviting feedback on by September 24th. See the Guidance document that was published on June 26th. The objective of the proposed Guidance is to help consumers more easily understand details about a product and to compare products, thereby aiding informed decisions.

Here are some highlights:

• Implementation of a Product Facts Table (PFT) for all self care products, with some exemptions, to help consumers find important information and compare similar products.
• New general legibility requirements, including dark print on light backgrounds (max 5% colour tint) and minimum font sizes and specific allowable font types.
• Some limited flexibility for items in small packages or "very small packages" (defined as 77.5 cm² or less – that may translate to a bottle size of about 125cc, but certainly no more).
• Allowance for innovative labels accessible at the point of purchase such as a peel backs, but excluding QR codes or other online links.
• A manufacturer may display either an email address, telephone number or website instead of a postal address, as currently required.
• Annex B: Single entity mineral supplements (such as calcium or iron) would require clarity about the form of the mineral as it affects potency (absorption characteristics).

The contents of the PFT, which are the major update, are similar to what is required on health supplement labels now, except for the standardized layout and greater clarity on allergen information, including gluten and aspartame if applicable, under the warning section. There will be exemptions for some products including for really small packages and the implementation would be phased in from when the new Guidance comes into force, allowing currently approved products up to six years to comply and new products three years.

So what are the implications? In my opinion, there are some positives and potential challenges.

On the positives, the Guidance will improve legibility, including on some of our products. Additionally, the Guidance Document recognized that the form of an ingredient, especially minerals, affects absorption characteristics and potency. We’ve suggested to Health Canada that the form of minerals should be recognized, as it can affect both safety and expected benefits. This is very welcome and we hope it's something that Health Canada builds on.

As for the challenges, there will be increased costs (design, inventory management, packaging costs, etc.) that will most impact Canadian small manufacturers and retailers, plus potential environmental costs due to impacts on packaging. As I was sharing these notes with a colleague, her response was "I like our labels, the proposed changes will make them ugly" and she may be right! As an illustration, our Joint Formula14 51 size capsule bottle is 150cc in size, convenient for travel or first time use. As with all our products, we endeavor to minimize packaging for environmental and cost reasons, even if it means they are harder to find on retail shelves. It's also one reason why we don’t make any products for retailing at big box retailers, as we feel they require wasteful ‘warehouse’ packaging.

Coming back to the illustration, we can’t put all the required (or appropriate) information in the prescribed format on this bottle (150cc in size) in compliance with the proposed Guidance; not even close. All of that information is there now, just not in the proposed format and font detail, and our white printing on a strong green background would need to be replaced with dark printing on a very light or white background. We would need to redesign the label and find alternate solutions such as a peel back label or larger bottle, or discontinue this “SKU”. However, the legibility ideas do have merit and I think we will review our Joint Formula Curcumin3 label sooner rather than later, even if the proposed Guidance doesn’t come into effect.

I was asked to share an update with the Council For Responsible Nutrition (CRN) on the proposed label Guidance. I was happy to consult with staff at the Canadian Health Food Association and in addition to what I’ve shared with you, I also noted for the CRN that despite the importance of the label changes, there are other high (or even higher) priority issues or policy changes at Health Canada. Some of these we welcome, as we believe they would be good for consumers and responsible industry participants. Others we feel may need better attention (or revisions) in order to achieve the stated objectives. If you would like to discuss these with me, drop me an email at mbentley@sierrasil.com and we can find time to talk.