Canadian Food Inspection Agency (CFIA) Finalizes Labelling Guidance for Plant-Based Egg Alternatives in Canada
CFIA’s guidance explains how plant-based egg alternatives should be labelled and advertised in Canada to avoid misleading consumers. It
Under Canada’s Food and Drug Regulations (FDR), plant-based products designed to resemble meat or poultry—without containing actual meat, poultry, or fish—are classified as simulated meat or simulated poultry products. To sell these products compliantly in Canada, manufacturers must adhere to strict regulatory standards covering product common names, principal display panel (PDP) statements, composition, fortification, and nutrition labelling.
This guide breaks down the core Canadian regulatory framework for plant-based meat and poultry alternatives. It covers how Health Canada and the CFIA classify simulated products, the mandatory common naming and “contains no meat” PDP statements, strict nutritional composition and fortification standards, and key rules regarding claims and nutrition labelling.
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Understanding Simulated Meat Products
What are Simulated Meat and Poultry Products?
In Canada, simulated meat and simulated poultry products are defined as foods that contain no meat, poultry, or fish, but possess the appearance of a meat or poultry product.
Typically made from plant-based ingredients alongside permitted non-meat animal inputs like milk or eggs, these items are assessed based on both physical sensory characteristics (such as visual appearance, texture, flavor, and odor) and how they are presented to consumers.
Ultimately, regulatory classification relies on the overall impression created by the product, meaning that product names, marketing claims, logos, imagery, and advertising representations all contribute to determining whether a food meets the definition of a simulated meat or poultry product.
Why Does the Classification Matter?
Products falling within the classification of a simulated meat or simulated poultry product are subject to specific provisions in Canadian regulations, which can have a significant impact on how the product is formulated and how it can be presented to consumers.
Simulated meat and poultry product are subject to:
- Specific composition and fortification requirements
- Specific labelling requirements
Composition and Fortification Requirements
Under the Food and Drug Regulations, simulated meat and poultry products must meet specific composition standards based on the item simulated:
- Ingredients: Cannot contain meat, poultry, or fish. Typically plant-based (cereals, legumes, nuts, seeds, vegetables), but may include milk, eggs, water, salt, and yeast.
- Protein: Must meet minimum content (e.g., 16% for general simulated meat under B.14.085; sausage variants differ) and quality thresholds.
- Fat: Cannot exceed maximum limits set in the Table of Chemical, Physical and Nutritional Characteristics of Food.
- Vitamins & Minerals: Must supply required levels of specified nutrients (e.g., vitamin B12, iron, zinc) via natural sources or permitted fortification; extra fortification is prohibited.
- Amino Acids: Essential amino acids can be added solely to meet protein quality standards.
- Food Additives: Only permitted additives may be used within regulated conditions.
Labelling Requirements
Beyond general Canadian prepackaged food labelling rules, simulated meat and poultry products must:
- Include “simulated” in the common name: Use the format “Simulated [meat/poultry product]” (e.g., Simulated Beef Burger). The word “simulated” must match the rest of the name in type size and prominence.
- Display “contains no meat/poultry”: Place this statement on the PDP adjacent to the common name without intervening text or graphics, matching the common name in size and prominence.
- Label non-prepackaged items: Display “contains no meat” or “contains no poultry” clearly and legibly on a sign placed on or directly next to the product.
Nutrition Facts table (NFt)
A Nutrition Facts table (NFt) is always required for simulated meat and poultry products. However, several requirements should be considered when preparing the NFt for these products:
- Added vitamins and minerals: Added vitamins and minerals must be declared in both absolute amounts and as a percent Daily Value (%DV) per serving of stated size.
- Reference amount and serving of stated size: Consult Health Canada’s Table of Reference Amounts for Food, to determine the mandatory reference amount and serving of stated size.
- Simulated meat and poultry products fall within the category “Meat, poultry, their products and substitutes”. The applicable reference amount depends on the type and form of the product.
- Note, the actual weight of the product does not necessarily correspond to the weight declared in the serving size.
For example, a 120 g cooked simulated cut of meat has a reference amount of 100 g, consistent with the reference amount for a cooked meat or poultry cut. Accordingly, the serving size must be expressed, as per 1 piece (100 g), in accordance with column 3B of Health Canada’s Table of Reference Amounts for Food. The nutrition information in the NFt must be based on the declared serving size, which, in this example, is 100 g.
Which Plant-Based Foods Fall Outside the Simulated Product Rules?
Tofu, Tempeh, Lentil Patties, and Jackfruit Products
Plant-based products may fall outside the definition of a simulated meat or simulated poultry product where their characteristics and overall presentation do not give the impression that they resemble or are intended to be comparable to a meat or poultry product. Factors to consider include:
Product Characteristics
Avoid features that imitate the sensory characteristics or appearance of meat or poultry, such as simulated muscle fibers, simulated bleeding, or fat marbling.
Labelling and Advertising
Avoiding claims, descriptions, imagery, or other marketing elements that create an impression that the product is a meat or poultry equivalent.
Overall Impression
Consider how the product is named, described, packaged, displayed, and promoted, to ensure the product is not likely to be mistaken for, or perceived as resembling, a meat or poultry product.
These elements are assessed together when determining whether a product meets the definition of a simulated product.
Products such as lentil loafs, mushroom burgers, tempeh patties, jackfruit products, and seasoned tofu will generally fall outside the simulated meat definition when they are presented based on their own characteristics, do not imply meat equivalence, and are not likely to be mistaken for meat. However, classification should be assessed on a case-by-case basis, taking into account the product’s characteristics and overall representation.
Avoiding Misleading Labelling
Packaging, Images, and Advertising
A product’s overall presentation goes beyond the information provided in its common name and ingredient list. Photographs, serving suggestions, product names, website copy, advertisements, and other representations can all contribute to the impression created for consumers. Comparisons to meat, or describing a product as a meat substitute or alternative, may be acceptable when they are truthful, accurate, and not misleading. However, these representations should not create an overall impression that the product contains meat or poultry when it does not.
Vegan, Vegetarian, Plant-based, and Meatless Claims
Terms such as “vegan,” “vegetarian,” “plant-based,” and “meatless” can help communicate the nature and composition of a food, but they must accurately reflect the product and its ingredients. For example, CFIA recognizes that vegetarian diets may include animal-derived ingredients that do not result from slaughter, such as milk, cheese, and eggs, while ingredients derived from slaughter are not considered compatible with vegetarian or vegan claims, including meat, fish, bone, stock, animal fats, and gelatin.
While “plant-based” and “meatless” do not have specific regulatory definitions or compositional standards in Canada, “meatless” indicates that the food does not contain meat, while “plant-based” generally communicates that the product is primarily or substantially derived from plant sources, but does not necessarily mean that every ingredient is plant-derived. The claim must accurately reflect the product’s composition and must not create a false, deceptive, or misleading impression about the source or nature of its ingredients.
These terms must also be considered in the context of the overall presentation of the food. The common name, prominent descriptors, images, vignettes, and other representations must work together to accurately communicate the true nature of the food.
For a product that meet the regulatory definition of a simulated meat or poultry product, using terms such as “plant-based,” “vegan,” or “meatless” do not replace the applicable mandatory labelling requirements, including the use of “simulated” in the common name and the applicable “contains no meat” or “contains no poultry” declaration. Conversely, “simulated” should not be used as a descriptor for a plant-based product that does not meet the regulatory definition of a simulated meat or poultry product.
Protein Claims
Protein claims are subject to specific regulatory conditions in Canada. A food making a “source of protein,” “good source of protein,” or “high in protein” claim must meet the applicable minimum protein rating.
Protein ratings are based on the amount and quality of protein in a reasonable daily intake (RDI) of the food, rather than simply the protein content of a single serving. The RDI is specified in Schedule K of the Food and Drug Regulations, where applicable; if no RDI is specified, the reference amount may be used. The protein rating can be calculated using either the FO-1 method or the PDCAAS method, both of which take into account the amount and quality of protein.
If a quantitative protein statement is made, such as “10 g protein,” the amount must be declared per serving of stated size, consistent with the serving size declared in the NFt. For example, “10 g protein per 60 g piece”.
What Should Brands Check Before Launching a Simulated Meat Product in Canada?
Before launching in Canada, brands should consider the following:
Product Classification
Determine whether the product meets the definition of a simulated meat or poultry product, considering both the characteristics of the food and how it is labeled, advertised, and represented.
Composition Requirements
Ensure the formulation satisfies applicable compositional requirements, including prescribed protein, protein quality, fat content and is reviewed against the permitted/required nutrient additions for simulated meat products.
Common Name
The common name should be the common name of the meat product being simulated, modified by the word “simulated.”
“Contains no meat” Declaration
Ensure the declaration appears on the PDP in close proximity to the common name, in letters at least the same size and prominence as the common name.
Overall Impression
Review the full label and advertising presentation to ensure that the overall impression is not false, deceptive or misleading.
General Label Requirements
Ensure the required label elements meet the Canadian Regulatory requirements.*
*Including: net quantity, ingredient and allergen declarations, NFt (verify the reference amount and serving of stated size), the front-of-pack (FOP) nutrition symbol, name and principal place of business, import or geographic origin declarations (where appliable), date marking, bilingual labeling, and claims before artwork approval.
Final Remarks
Bringing a simulated meat or poultry product to market in Canada requires more than simply adapting an existing plant-based product label. Product classification, composition, naming, claims, ingredient declarations, NFt requirements, and other labelling considerations can all come into play. Understanding these requirements early in the product development process can help avoid costly reformulation or label changes later.
Whether you are developing a new plant-based product, adapting an existing formula for the Canadian market, or reviewing an existing Canadian label, our team can help you navigate the regulatory requirements and bring your product to market with confidence. From formula review and development through regulatory label review and graphic design, we provide the support you need to move from concept to compliant, market-ready product.
Bring Your Plant-Based Products to the Canadian Market
Bringing a plant-based product to market requires navigating regulatory requirements while developing packaging that communicates your product clearly and effectively.
Source Nutraceutical, Inc. (SNI) can support you throughout the process – from reviewing an existing formula or developing a new or Canadian-specific formula, to label compliance and graphic design. Our regulatory team can help ensure your product’s claims, ingredient lists, NFt, FOP nutrition symbol, and other labelling elements meet Canadian requirements, while our graphic services bring your final packaging to life. Whether you’re launching a new plant-based product or updating an existing one, we can help streamline the process from concept to compliant, market-ready packaging.
Let's Ensure Your Plant-Based Food Compliance
Need our support? Contact SNI to discuss your plant-based product compliance.
Book an introductory call using the following form:
FAQ
Can a Plant-Based Burger Be Called a Burger in Canada?
Yes, but the use of these terms depends on how the product is formulated and presented. In Canada, terms associated with meat or poultry are not necessarily restricted to meat products. CFIA recognizes terms such as “burger,” “loaf,” “patty,” “jerky,” and “sausage” for certain non-meat foods, including “veggie burger,” “tofu burger,” “mushroom burger,” and “soy sausage.”
Importantly, compliance is assessed based on the overall impression created by the label and advertising. The common name, claims, images and other elements are considered together to determine whether the product creates a false, deceptive or misleading impression.
If the product meets the definition of a simulated meat or poultry product, it is subject to specific regulatory requirements, outlined above, including the use of “simulated” in the common name.
If a plant-based product does not meet the definition of a simulated meat or simulated poultry product, meat-related terms may still be used where the common name accurately and truthfully describes the food and the overall presentation does not create a misleading impression. For example, “Portobello Mushroom Burger” may be appropriate for a mushroom-based patty that is not presented as resembling or comparable to meat.
Does Every Meat Alternative Count as a Simulated Meat?
No. Not every meat alternative is considered a simulated meat product under Canadian regulations. The classification depends on the product’s composition, formulation, and how it is represented or described. Products that do not meet the regulatory criteria for a simulated meat product may be subject to different requirements.
Do Simulated Meat Products Require Added Vitamins and Minerals?
Usually. Simulated meat products must contain specified vitamins and minerals at prescribed minimum levels. While these nutrients may occur naturally in the ingredients, they will generally need to be added to the product to meet the required levels.
Can a U.S. Plant-Based Meat Label Be Used in Canada?
No. U.S. consumer labels cannot simply be used in Canada because Canadian and U.S. labeling requirements differ significantly. Canadian prepackaged consumer food labels must use a Canadian NFt another country’s NFt cannot be used as an alternative to, or in addition to, the Canadian NFt. Other elements of the label may also need to be modified to comply with Canadian requirements.
Are Vegan and Vegetarian Claims Regulated in Canada?
Yes, but there are no specific regulatory standards defining these claims. CFIA guidance indicates that foods making vegetarian or vegan claims are expected to contain only ingredients consistent with the type of diet claimed. As with all voluntary claims, they must be truthful, not misleading, and supportable.
When simulated meat or poultry product is used as an ingredient in another food, such as soup, do the simulated meat and poultry labelling and composition requirements apply?
No. When a simulated meat or poultry product is used as an ingredient in another food, the specific labelling requirements that apply to the simulated product itself do not apply to the final food.
For example, the final food is not required to include “simulated” in the common name or a “contains no meat” or “contains no poultry” declaration. However, any pictures, vignettes, or representations on the consumer packaging or advertising must not suggest that the product contains meat or poultry, unless meat or poultry are also present as an added ingredient. The final food must otherwise comply with the labelling requirements applicable to that food.
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