In Canada, only substances listed in the List of Permitted Food Additives can be sold as food additives in Canada. In order to add a new food additive, or add a new purpose, level or food type, companies must complete a food additive submission which must be assessed and approved by Health Canada’s Food Directorate.
In Canada, there is no formal definition of a “food”, but there are a few legislative clauses that tell us what a food is not. Generally speaking, “food ingredients” are those which have a food purpose – i.e., calories, hydration, nutrition – and “food additives” are those which are added to food to affect its characteristics (such as texture, consistency, shelf life, etc).
The definition of a food additive does exclude some ingredients, including materials commonly sold as ingredients of food, vitamins, minerals and amino acids, spices, seasonings, flavouring preparations, essential oils, and some others. Under the Food and Drug Regulations, only substances listed in the Lists of Permitted Food Additives can be sold as food additives in Canada. The lists give the name of each food additive, its permitted area of use in food and its maximum permitted use level, with the lists including permitted colouring agents, food enzymes, sweeteners and preservatives, just to name a few.
Companies interested in selling a product with a food additive that does not appear on one of the lists (or a listed ingredient but for a different purpose, level or food type) must file a Food Additive Submission (FAS). Food additive submissions include information regarding substance identification, method of manufacture, physical and chemical properties, specifications, intended use, analytical methods of analysis, maximum limits, safety related data and proposed labelling.
Food additive submissions undergo a lengthy and mildly unpredictable assessment process with the Food Directorate of Health Canada. Following the completion of a scientific assessment and internal review/approval of the submission, Health Canada will provide notification of their intent to amend one of the lists of approved food additives via a Notice of Proposal posted on their website. At that time, the public will have 60 days to provide comments. If no new scientific/safety information comes to light during this period, the new additive will be enabled following the close of the notification period.
NHP Consulting will file a Food Additive Submission on your behalf, ensuring your product comes to market in full compliance and in a timely fashion.