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Selling soft drinks, water and juice in Canada

In Canada, non-alcoholic drinks are food under the Food and Drugs Act and the Safe Food for Canadians Act. Mineral and spring water have a compositional standard and their own label particulars, juices take names from the standards of identity, and drinks with added vitamins, minerals or caffeine are often supplemented foods with a Supplemented Food Facts table.

Updated · Each section links to the official source it comes from

Main rules
Food and Drug Regulations; Safe Food for Canadians Regulations
Enforced by
The Canadian Food Inspection Agency (CFIA)
Mineral and spring water
Source location, dissolved minerals and fluoride on the label
Added vitamins or caffeine
Often a supplemented food (Division 29, FDR)
Label language
English and French

Before a product goes on sale

The questions to answer, in the order they usually come up.

  1. 1Is it water, juice, a soft drink or a supplemented food? Read more
  2. 2Does it meet the standard for the name on the label? Read more
  3. 3What does the label have to show, in English and French? Read more
  4. 4If it has added vitamins, minerals or caffeine, are the facts table and cautions right? Read more
  5. 5Who makes, imports and traces it, and under which licence? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

Water and juice

Names and particulars for prepackaged water and processed fruit or vegetable juices.

  • Mineral or spring water comes from an underground source other than a public community water supply and meets the standard in volume 11 of the Canadian Food Compositional Standards; it may only be treated with carbon dioxide, ozone during bottling, and fluoride.
  • Mineral or spring water is labelled with the geographical location of the underground source, total dissolved mineral salts in ppm and total fluoride ion in ppm (B.12.002, FDR).
  • Other prepackaged water and ice declare total fluoride ion in ppm on the principal display panel (B.12.008, FDR), and treated water carries a descriptor such as "distilled" or "carbonated".
  • Water with added vitamins or minerals, other than fluoride, is a supplemented food.
  • Juice names come from the Canadian Standards of Identity, Volume 4, such as "apple juice from concentrate" or "frozen concentrated apple juice".

How we help: Compliant Always reads the name and particulars on your label against the standard it claims, and keeps the source and lab data behind each figure with the product. Ask about this

Core labelling and nutrition

What every prepackaged drink shows.

  • The core particulars apply: common name, metric net quantity, ingredients with allergens, name and principal place of business, date markings where required, and nutrition labelling.
  • Mandatory information is in English and French, except the name and principal place of business, which may be in either.
  • Water and ice are exempt from a Nutrition Facts table when all core nutrients would be declared as zero, but the exemption can be lost, for example when a voluntary claim is made.
  • A front-of-package nutrition symbol is required on prepackaged foods, drinks included, that meet or exceed set levels for saturated fat, sugars or sodium.

How we help: Compliant Always sets the particulars beside your English and French label and the nutrient analysis behind it, so the gaps are visible. Ask about this

Supplemented foods, including caffeinated drinks

Drinks with added vitamins, minerals, amino acids or other supplemental ingredients.

  • Supplemented foods are prepackaged foods with one or more added supplemental ingredients; the rules are in Division 29 of the Food and Drug Regulations and four documents incorporated by reference.
  • Only listed food categories may be supplemented, and only with supplemental ingredients on the List of permitted supplemental ingredients, under its conditions of use.
  • Supplemented foods carry a Supplemented Food Facts table, and cautionary statements where an ingredient calls for one.
  • A supplemented food needing a cautionary statement carries the supplemented food caution identifier on its principal display panel (B.29.021, FDR).
  • Claims are restricted on supplemented foods with a "high caffeine content" statement, and caffeine as a supplemental ingredient excludes some categories represented for physical performance.

How we help: Compliant Always reads each supplemental ingredient against its listed conditions of use and checks the cautionary statements and identifier your formula calls for. Ask about this

Licences, traceability and recalls

The Safe Food for Canadians duties that sit behind the product.

  • Food may not be imported unless the importer holds a Safe Food for Canadians licence.
  • Licence holders keep a written preventive control plan for their licensed activities.
  • Traceability documents are kept for two years and provided to the CFIA within 24 hours of a request; consumer prepackaged food carries a lot code.
  • Operators keep a recall procedure and run a recall simulation at least once every 12 months.

How we help: Compliant Always ties each document to the lot and the supplier it came from, so a CFIA request is answered from the record. Ask about this

Who answers for what

WhoWhat they answer forHow we help
BrandThe name, the label in both languages, and any claims or cautions.The label checked against the standard and the particulars, with the evidence in one place.
Bottler or manufacturerMeeting the standard, the preventive control plan and lot coding.Specifications, test reports and lot records kept with each product.
ImporterA licence to import, traceability and recall duties for imported drinks.Suppliers' documents read and dated before the goods arrive.

Provinces and territories

The federal Acts and regulations in these guides apply across Canada. Provincial regulations may add labelling requirements for products sold within a province, and Quebec has additional requirements on the use of French on products marketed there.

Alcohol is largely provincial: provincial and territorial liquor boards set their own requirements, and liquor imported into a province is consigned to the provincial body authorised to sell it.

Questions businesses ask

What must a mineral or spring water label show in Canada?
The geographical location of the underground source, the total dissolved mineral salt content in ppm and the total fluoride ion content in ppm, under B.12.002 of the Food and Drug Regulations, plus the core labelling particulars.
Can mineral or spring water be treated in Canada?
Only by adding carbon dioxide for carbonation, ozone for disinfection during bottling, and fluoride. It may not be subjected to any treatment that would modify the original composition of the water.
Does bottled water need a Nutrition Facts table in Canada?
Water and ice are exempt when all core nutrients would be declared as zero. The exemption may not apply because of sodium or mineral content, and can be lost when a voluntary claim is made.
Is an energy drink a supplemented food in Canada?
A prepackaged drink with added supplemental ingredients, such as vitamins, minerals or caffeine, falls under the supplemented food rules in Division 29 of the Food and Drug Regulations, where its category is permitted.
What is the supplemented food caution identifier?
A symbol that a supplemented food carries on its principal display panel when its label needs one or more cautionary statements (B.29.021, FDR). Products without cautionary statements must not carry it.
Is water with added vitamins a supplemented food?
Yes. The CFIA says water to which vitamins and minerals, other than fluoride, have been added is a supplemented food.
Do drink labels need to be in French and English?
Yes. Mandatory information on consumer prepackaged food, including drinks, is shown in both official languages; the name and principal place of business may be in either.
Do soft drinks need the front-of-package nutrition symbol?
Prepackaged foods that meet or exceed set levels for saturated fat, sugars or sodium carry the symbol, unless an exemption applies. Drinks are assessed like other prepackaged foods.
Do I need a licence to import drinks into Canada?
Yes. Food, including non-alcoholic drinks, may not be imported unless the importer is authorised by a Safe Food for Canadians licence.
How does Compliant Always help with selling in Canada?
Our team reads the rules for the markets you sell in, including Canada's federal rules and the bilingual labelling they share. Compliant Always shows which apply to your product, keeps the documents behind each one ready, and watches the sources for changes. It shows what the requirements say and what your documents show; you decide.

Sources

Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

Tell us what you make, and we will show you the rules for it.

Name the product and the markets you sell in. We will come back to you with what applies in Canada and what your paperwork needs to show.

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