Beware of ingredients of ingredients!

Determining whether ingredients are ambiguous especially applies to ingredients of ingredients. Sometimes you have to get a bit creative and guess what these might be. For instance, a prepackaged tuna salad sandwich might list “tuna salad” as an ingredient. The mayonnaise in the tuna salad could be made with corn oil and/or corn starch, dextrose, etc., since some prepackaged products are exempt from the Canadian legal requirement to list all ingredients.

  • The kinds of prepackaged products exempt from listing ingredients of ingredients are: mixtures of nuts, individual portions of snacks served in restaurants, roasted or barbecued or broiled meat or poultry baked on the premises of food stores, and “prepackaged individual servings of food that are prepared by a commissary and sold by automatic vending machines or mobile canteens,” such as prepackaged sandwiches, according to our Food and Drug Regulations, B.01.008).

As well, certain ingredients of ingredients are almost never required to be listed. Ingredients that can be listed without listing their ingredients include margarine, shortening, starches, modified starches, graham flour, baking powder, jams and jellies (if they are 5% of a prepackaged product or less), hydrolyzed plant protein, spice or seasoning preparations, and a number of other minor constituents of prepackaged products. (This is described in our Food and Drug Regulations, B.01.009).

Canada launched amendments to the requirements for listing ingredients of ingredients of prepackaged food in August of 2012. Unfortunately, corn products are not among the ingredients that will now need to be flagged.