Ad Standards Advisory Regarding FOP Nutrition Symbols in Ads

Starting January 1, 2026, food manufacturers must comply with the new requirement for front-of-package (FOP) nutrition symbol labelling.  This requirement will apply for most prepackaged products containing nutrients deemed by Health Canada to be of public health concern (saturated fat, sugars and/or sodium) at or above specified thresholds.

While FOP nutrition symbol labelling is required for many foods, the Food and Drug Regulations do not specifically require that a FOP nutrition symbol be included on labels depicted in advertisements.  Ad Standards therefore looks to the treatment of labels in advertising under the Industry Labelling Tool, which permits partial reproductions of labels in advertising if the information shown is meaningful to consumers and is not misleading or deceptive.

When ads for food and non-alcoholic beverages are submitted to Ad Standards for preclearance, the analysts always consider whether the overall impression of the ad creates a false and misleading general impression. An ad could be misleading based on what is included, or what is omitted, from it.  In the case of a product that requires FOP nutrition symbol labelling, the analysts reviewing the ad will consider the overall impression created by the advertisement; this includes considering any claims made related to the nutritional value of the product, and whether or not there is an FOP nutrition symbol on the packaging as depicted in the advertisement.

In other words, while including the FOP nutrition symbol on packaging is not always mandatory in food advertisements, its omission from the ad when it is required to appear on the product on shelf could result in a misleading impression about the overall nutritional value of the food. If that is the case, Ad Standards Clearance analysts will advise the advertiser that the FOP nutrition symbol must be included on packaging depicted in the ad.