New Canadian Front-of-pack Nutrition Labelling
The who, what, where, why and when of the new regulations
What products will be required to display the new front-of-pack symbol?
Trademarks
Under the new regulations registered and unregistered Canadian trademarks can continue to appear in their original language without translation, provided that no French language trademark exists in the Canadian trademark database. Generic terms and descriptions that are part of a trademark are not exempt from translation.
Generic terms & product descriptions that require translation
Generic Term: describes the type or nature of the product (cookie, chip, milk...)
Product Description: describes features or qualities of a product (sweet, avocado, gluten-free...)
Any generic terms (e.g., "cookies," "juice") or product descriptions (e.g., "organic," "gluten-free") that is not part of the name of the enterprise must be translated into French, even if they are part of a trademark.
There are of course some exceptions.
Exemptions to the requirement to translating generic terms and product descriptions
The following do not require translation:
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The name of a company or enterprise even if it contains generic terms or descriptions
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Designations of origin: Names tied to specific regions, like “Champagne” or “Parmesan.”
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Cultural or traditional product names: Terms like “Sushi”, “Chorizo”, or “Poutine”.
Examples
If the trademark is Happy Snacks Organic Chips and the company name is Happy Snacks, "Organic Chips" must be translated.
If the trademark is Happy Snacks Organic Chips and the company name is Happy Snacks Organic, only "Chips" must be translated.
If the trademark is Happy Snacks Organic Parmesan Chips and the company name is Happy Snacks, only "Organic Chips" must be translated.
Timeline
The packaging and labelling requirements of Bill 96 comes into full effect on June 1, 2025. There is a two year grace period for products manufactured on or before June 1, 2025, and no French language trademark was registered prior to June 1, 2026.
Next steps
In spite of some initial concern there is no need to run out and change your brand name or translate all your trademarks into French. You do need to take a look at your labels and determine if anything has to change.
Two things you can do right away? Register your trademarks and call Brand Natural.
At Brand Natural we make Canadian food labelling compliance easy. We believe in the right hands food labelling regulations can a competitive advantage.
On December 31st 2025 new Canadian front-of-pack nutrition labelling requirements take effect. The new labelling regulations are intended to work in tandem with Health Canada's Healthy Eating Strategy and Canada Food Guide to identify foods high in saturated fat, sugar and sodium to address “to help consumers make quick and informed decisions abouttheir health when shoppingfor groceries”
Products exempt from displaying the front-of-pack nutrition facts symbol.
There are several foods which are exempt from displaying the front-of-pack nutrition symbol. Foods packaged in small containers with a display surface of less than 15 cm2, and most single ingredient food including fruits, vegetables and meats, as well as plain milk, yogurt, butter, cheese and and vegetable oils exempt. For a complete list of fully exempt and conditionally exempt food refer to the Front-of-package nutrition symbol labelling guide for industry.
Any pre-packaged food products that contain 15% DV or more of saturated fat, sugar and sodium per serving (10% DV for foods with a reference amout less than 30g, and 30% DV for main dishes with a reference amount over 200 g).
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