Dear decision makers,
Please consider this to be my submission to the Canada Gazette, Part I consultation on front-of-package labelling.
Improving the overall health of Canadians is extremely important to me. I do not, however, support the Government of Canada's proposal to require products high in sodium, sugar, and saturated fat to carry front-of-package labels. I, therefore, ask government officials to reconsider their approach.
The dairy industry is important to me and I believe that dairy products play an important role in supporting the health of Canadians. According to Health Canada’s own 2015 scientific review, milk products are beneficial for bone health, and are associated with a reduced risk of a number of diseases, including: heart disease, hypertension, stroke, type 2 diabetes, and colorectal cancer. Milk products also provide key nutrients which Canadians do not get enough of: Vitamins A and D, calcium, magnesium, zinc, and potassium.
However, under the proposed regulations, foods (including dairy products) which contain more than 15% of the daily value for sodium, sugar and saturated fat would be forced to carry a front-of-package warning label. This is regardless of whether or not the foods contribute to reducing chronic disease or contain other nutrients that have been identified as under-consumed by Canadians such as those listed above.
As proposed, these regulations could discourage Canadians from eating dairy products which have proven health benefits, but not discourage them from nutrient-poor foods which, contrary to most dairy products, can be more easily reformulated to not carry a label. The proposed front-of-package regulations, as they focus on just three nutrients, is an oversimplification of what makes a product “healthy” and does not provide Canadians with the information needed to make informed food choices.
Illustrating this point, according to a recent Nanos poll, 1/3 of Canadians would simply avoid any product carrying a front-of-package warning label, without seeking further information on the Nutrition Facts table. This runs the risk of encouraging Canadians to choose snack foods over nutritious foods such as dairy products. How does this improve the health of Canadians?
Furthermore, I am concerned by inconsistencies in the proposed regulations. While whole milk and 2% milk have been exempted, many dairy products like cheese and yogurt will have front-of-package labels. This is despite the fact that they are proven to have many of the same nutrients and have an identical protective effect on health. Government regulations must be based on sound evidence.
I cannot support front-of-package labels which risk confusing Canadians and encouraging them to eat products that provide much fewer health benefits (or worse, have detrimental effects) than dairy products. The health outcome of this proposal will do nothing to support the Health Canada objectives of helping Canadians to make healthy food choices and improve their overall health.