FOODS SUBMISSIONS
Foods marketed as Natural Health Products.
Food submissions (TMAL, NFN, FAS), Health claim substantiation & supplement labeling. In Canada, food products can be either compliant or non-compliant. Compliant foods require only proper labeling with no pre-market approval process. The labels are bilingual and we can help create your bilingual label. Non-compliant foods may require pre-market approval before coming to market, such as genetically modified foods, foods fortified with vitamins/minerals/amino acids, and products which may be considered novel. We can help improve your compliance which will help get your products to market sooner.
Manufacturers of food-NHPs being transitioned to the food regulatory stream and not requiring reformulation, will be provided a transition period for the new allergen labeling requirements rather than being immediately subject to the new regulations on August 4, 2012. These products must fully comply with the enhanced food allergen labeling requirements along with all other labeling requirements by March 2014.
Temporary Marketing Authorizations (TMAs)
It is anticipated that most products at the food-NHP crossing point will need to be transitioned through TMAs, but some products may not require TMAs if they are already compliant foods. Furthermore, some products may not be eligible for TMAs without reformulation (or the need to change representation so as to not be confused for a food), if they have been identified as unsuitable to be sold as foods following a risk-based review.
Regulations for Selling Food products in Canada Health Canada is responsible for regulating and setting standards for foods and natural health products in Canada. Health Canada’s Natural Health Products Directorate (NHPD) regulates the sale of natural health products such as herbal drinks. Health Canada’s Food Directorate regulates the sale of foods. In the case of NHPs, the Canadian Food Inspection Agency (CFIA) becomes involved when natural health products are imported into Canada, as it is responsible for inspecting all food and natural health product shipments coming into Canada. The CFIA takes its direction on what natural health products can and cannot be imported from the NHPD. In the case of foods, the CFIA has a much greater role enforcing safety and nutritional quality standards set by Health Canada.
If ya drink is intended for sale in Canada, the first thing issue is whether or not your product falls under the Natural Health Products Regulations. If it is your plan to make a health claim (recommended use or purpose) for the product, then usually it automatically becomes an NHP under the regulations. Even if you don’t plan to make a health claim, it will likely still be considered an NHP, depending on a number of factors. It is necessary to review the regulations to be certain of the status of your drink or other food product. If your product is an NHP then you will have to secure a site license plus a product license from the NNHPD.
If your product is classified as a food, then you do not need the NHPD licenses, but Health Canada’s food regulations will apply.