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Page 1: Révision 1 - Global Wine & Spirits · This guide is intended to assist the SAQ’s suppliers and their agents in labelling their products in accordance with the labelling standards

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Révision 1

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Contents 1 Basic labelling standards _______________________________________________ 4

1.1 Wine ________________________________________________________________ 5

1.2 Beer ________________________________________________________________ 6

1.3 Cider ________________________________________________________________ 7

1.4 Spirits _______________________________________________________________ 8

1.5 Unstandarized alcoholic beverages________________________________________ 9

1.6 Batch (lot) number ____________________________________________________ 10

1.7 Character height _____________________________________________________ 10

1.8 Language ___________________________________________________________ 10

1.9 Refundable deposit ___________________________________________________ 10

1.10 Best before and expiry date ____________________________________________ 11

2 Information relating to allergies and intolerances ________________________ 11

2.1 May contain allergens _________________________________________________ 12

2.2 Allergen-free ________________________________________________________ 12

3 Sustainable development ____________________________________________ 12

3.1 Organic products _____________________________________________________ 12 3.1.1 Standards recognized in Canada _______________________________________________ 12 3.1.2 Labelling of organic products _________________________________________________ 13 3.1.3 Prohibited wordings ________________________________________________________ 14

3.2 Biodynamic products __________________________________________________ 14

3.3 Natural wines ________________________________________________________ 14

3.4 Fair-trade products ___________________________________________________ 14

3.5 Integrated farming ____________________________________________________ 15

3.6 Sustainable development ______________________________________________ 15

3.7 Environmental claims _________________________________________________ 15

4 Health claims and other warnings _____________________________________ 15

4.1 Health claims ________________________________________________________ 15

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4.2 Alcohol consumption warning __________________________________________ 15

4.3 Standard drinks (UK units or standard drinks of alcohol) _____________________ 16

5 Dealcoholized or low-alcohol beverages ________________________________ 16

5.1 Alcohol by volume declaration __________________________________________ 16

5.2 Ingredients permitted in dealcoholized wines ______________________________ 17

6 Other labelling concepts _____________________________________________ 17

6.1 “Product of Canada” and “Made in Canada” claims _________________________ 17 6.1.1 Product of Canada __________________________________________________________ 17 6.1.2 Made in Canada ____________________________________________________________ 17 6.1.3 Other Canadian content claims ________________________________________________ 17

6.2 Nutrition facts table ___________________________________________________ 18

6.3 List of ingredients ____________________________________________________ 18

6.4 Low-calorie and calorie-reduced drinks ___________________________________ 19

6.5 Proof _______________________________________________________________ 19

6.6 Imported by an organization other than the SAQ ___________________________ 19

6.7 Artificial flavours and graphic representation ______________________________ 20

7 Packaging ________________________________________________________ 20

7.1 Tamper-proofing of containers __________________________________________ 20

7.2 Standardized container size ____________________________________________ 20

7.3 Alternate containers __________________________________________________ 20 Appendix 1 Batch (Lot) Number Guidelines __________________________________________ 22 Appendix 2 Tamper-Proofing of Containers __________________________________________ 23

Note to the reader This guide is intended to assist the SAQ’s suppliers and their agents in labelling their products in accordance with the labelling standards in effect in Quebec and Canada. In the event of divergence between this guide and an existing law or regulation, the law or regulation shall prevail. Please note that this guide covers the labelling concepts generally used for alcoholic beverages and is not necessarily exhaustive. Blue highlighting is used to indicate documents and websites that can be referred to for more information.

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1 Basic labelling standards The diagrams on the following pages are a graphical representation of the main labelling requirements for various types of products. All labelling information is mandatory. The subsequent sections of this guide cover other labelling-related issues. Please note that some of the information must appear on the main label, while other information may be placed on the main label or the back label. Food and Drugs Act Food and Drugs Regulations Food Labelling for Industry Act Respecting the Sale and Distribution of Beer and Soft Drinks in Non-returnable Containers Regulation Respecting Cider and Other Apple-Based Alcoholic Beverages Product Identification Standards for Use in the Distribution of Beverage Alcohol

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1.1 Wine

Brand name: Must not cause confusion as to the type or origin of the product.

Regulatory, geographic and traditional designations: Can be in the language of the country of origin if in compliance with that country’s regulations.

Product’s brand name

2010 Controlled appellation

Grape variety Common name: Mandatory in French and English.

Country of origin: Mandatory in French and English. Vin Wine

Produit de France Product of France Alcohol by volume (actual alcohol): Mandatory with the unit “X% alc/vol”, “X% alc./vol.”, “alc. X% vol.” or “alc X% vol”.

12% alc./vol. 750 ml Net contents (volume): Mandatory in millilitres (ml or ML) if the container size is less than 1 litre and in litres (l or L) for containers 1 litre or larger in size.

Allergen warning: Mandatory in French and English. See section 2 of this guide for more information.

Contient des sulfites Contains sulfites

Supplier’s name: Mandatory. It is the name of the product’s manufacturer or of the company the product was made for.

Supplier’s name Supplier’s address: Mandatory. Must at the very least include the name of the city and country.1,2

Supplier’s address, city, country

Lot 180219 Batch number or production code: Mandatory on the bottle or label. See Appendix 1.

CUP/EAN code: Mandatory.

The mandatory common name, country of origin, alcohol by volume and net contents information must be grouped together in a single visual field. They may be located on the main label or the back label.

1. For Canada and the United States, the name of the province or state can replace the country name. 2. An alphanumeric code, such as the European postal code, is not an acceptable way of stating the supplier’s address.

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1.2 Beer

Brand name: Must not cause confusion as to the type or origin of the product.

Common name: Mandatory on the main label, in French and English, as per the category (bière extra-légère/extra light beer 1.1% to 2.5% alc./vol., bière légère/light beer from 2.6% to 4.0% alc./vol., bière/beer from 4.1% to 5.5% alc./vol., bière forte/strong beer from 5.6% to 8.5% alc./vol., bière extra-forte/extra strong beer 8.6% alc./vol. or higher).

Product’s brand name

Bière forte Strong beer

Alcohol by volume (actual alcohol): Mandatory with the unit “X% alc/vol”, “X% alc./vol.”, “alc. X% vol.” or “alc X% vol”.

8.6% alc./vol. 341 ml Net contents (volume): Mandatory in millilitres (ml or ML) if the container size is less than 1 litre and in litres (l or L) for containers 1 litre or larger in size.

Batch number or production code: Mandatory on the bottle or label. See Appendix 1.

Lot 180219 Refundable deposit: Mandatory as shown here, with characters at least 4 mm (12 points) in height. The amount of the deposit is 5¢ for cans* 450 ml and smaller, 10¢ for glass bottles 450 ml and smaller and 20¢ for all containers larger than 450 ml.

QUÉBEC 5¢ CONSIGNÉE/REFUND

Supplier’s name: Mandatory. It is the name of the product’s manufacturer or of the company the product was made for.

Supplier’s name Supplier’s address: Mandatory. Must at the very least include the name of the city and country.3,4

Supplier’s address, city, country

Lot 180219 Batch number or production code: Mandatory on the bottle or label. See Appendix 1.

CUP/EAN code: Mandatory.

*For cans, the refundable deposit must be shown on the top of the container.

3. For Canada and the United States, the name of the province or state can replace the country name. 4. An alphanumeric code, such as the European postal code, is not an acceptable way of stating the supplier’s address.

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1.3 Cider

Country of origin: Mandatory in French and English on the main label.

Brand name: Must not cause confusion as to the type or origin of the product.

Produit du Québec Product of Québec

Product’s brand name

Common name: Mandatory in French and English on the main label and according to the category (cidre/cider, cidre aromatisé/flavoured cider, cidre apéritif/aperitif cider, etc.).

Cidre fort Strong cider Designation of effervescence: Mandatory on the main label, if applicable. Crackling, Crackling carbonated, Sparkling, Sparkling Carbonated.

Cidre mousseux

Sparkling cider

Alcohol by volume (actual alcohol): Mandatory on the main label with the unit “X% alc/vol”, “X% alc./vol.”, “alc. X% vol.” or “alc X% vol”.

12% alc./vol. 750 ml Net contents (volume): Mandatory on the main label in millilitres (ml or mL) if the container size is less than 1 litre and in litres (l or L) for containers 1 L or larger in size.

Allergen warning: Mandatory in French and English. See section 2 of this guide for more information.

Contient des sulfites Contains sulfites

Supplier’s name: Mandatory. It is the name of the product’s manufacturer or of the company the product was made for. (For cider made in Quebec, it is the name of the permit holder that must be shown. The number of the permit under which the cider is made must also be included.)

Supplier’s name Supplier’s address: Mandatory. Must at the very least include the name of the city and country.5 6 (For cider made in Quebec, it is the address of the cider maker permit holder that must be shown.)

Supplier’s address, city, country

L180219 Batch number or production code: Mandatory on the bottle or label. See Appendix 1.

CUP/EAN code: Mandatory.

5. For Canada and the United States, the name of the province or state can replace the country name. 6. An alphanumeric code, such as the European postal code, is not an acceptable way of stating the supplier’s address.

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1.4 Spirits Brand name: Must not cause confusion as to the type or origin of the product.

Regulatory, geographic and traditional designations: Can be in the language of the country of origin if in compliance with that country’s regulations.

Product’s brand name

10 years of age

Common name: Mandatory on the main label in French and English.

Brandy Country of origin: Mandatory on the main label in French and English for wine-based eaux-de-vie entirely distilled in a country other than Canada.

Produit de France Product of France

Alcohol by volume (actual alcohol): Mandatory on the main label with the unit “X% alc/vol”, “X% alc./vol.” or “alc. X% vol.”.

40% alc./vol.

750 ml

Net contents (volume): Mandatory on the main label in millilitres (ml or mL) if the container size is less than 1 litre and in litres (l or L) for containers 1 L or larger in size.

Allergen warning: Mandatory in French and English. See section 2 of this guide for more information.

Contient (nom des allergènes)

Contains (names of allergens)

Supplier’s name: Mandatory. It is the name of the product’s manufacturer or of the company the product was made for.

Supplier’s name Supplier’s address: Mandatory. Must at the very least include the name of the city and country. The address may be shown in the language of the country of origin.7, 8

Supplier’s address, city, country

L180219 Batch number or

production code: Mandatory on the bottle or label. See Appendix 1.

Code CUP/EAN: Mandatory.

For Armagnac, cognac, tequila, mezcal, Scotch whisky and Irish whiskey bottled in Quebec, the country of origin and permit number must also be included.

7. For Canada and the United States, the name of the province or state can replace the country name. 8 An alphanumeric code, such as the European postal code, is not an acceptable way of stating the supplier’s address.

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1.5 Unstandarized alcoholic beverages9 Brand name: Must not cause confusion as to the type or origin of the product.

Common name: Mandatory in French and English on the main label. Product’s brand name

Boisson alcoolique aromatisée aux fraises

Strawberry flavoured liquor Alcohol by volume (actual alcohol): Mandatory on the main label with the unit “X% alc/vol”, “X% alc./vol.”, “alc. X% vol.” or “alc X% vol”.

18% alc./vol. 750 ml Net contents (volume): Mandatory on the main label in millilitres (ml or mL) if the container size is less than 1 litre and in litres (l or L) for containers 1 L or larger in size.

Allergen warning: Mandatory in French and English. See section 2 of this guide for more information.

Contient (nom des allergènes)

Contains (names of allergens)

List of ingredients: Mandatory in French and English in decreasing order of proportion.

Ingrédients: Alcool, Sucre (sucre, jus de fraise), Sulfites, Rouge Allura

Ingredients: Alcohol, Sugar (sugar, strawberry juice), Sulphites, Allura Red

Supplier’s name: Mandatory. It is the name of the product’s manufacturer or of the company the product was made for.

Supplier’s name Supplier’s address: Mandatory. Must at the very least include the name of the city and country. The address may be shown in the language of the country of origin.10,11

Supplier’s address, city, country

L180219 Batch number or

production code: Mandatory on the bottle or label. See Appendix 1.

CUP/EAN code: Mandatory.

Note: The refundable deposit is mandatory for beer-based alcoholic beverages. It must be in characters at least 4 mm (12 points) in height. The amount of the deposit is 5¢ for cans 450 ml and smaller, 10¢ for glass bottles 450 ml and smaller and 20¢ for all containers larger than 450 ml.

9. Unstandardized alcoholic beverages are all beverages for which no legal definition is found in the Canadian Food and Drug Regulations. 10. For Canada and the United States, the name of the province or state can replace the country name. 11 An alphanumeric code, such as the European postal code, is not an acceptable way of stating the supplier’s address.

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1.6 Batch (lot) number A batch number is a series of numbers of letters, which often refers to the production date and is printed on bottles and cases to assure traceability of the batch. The manufacturer’s batch number is mandatory on all products. Using batch numbers is a good manufacturing practice and we encourage all our suppliers to include one on their bottles. Appendix 1 contains recommendations regarding batch numbers. Note: The Safe Food for Canadians Regulations, which will enter into force soon, will require having in place a traceability system that makes it possible to track the movement of food products. We strongly recommend that all our suppliers have such a system in place before the regulations enter into force. 1.7 Character height The characters must be at least 1.6 mm in height, except for the net contents numbers, which must be at least 3.2 mm in height. Character height is based on the height of the lowercase o. Different requirements may apply depending, for example, on the available surface on small containers and packaging. Food and Drug Regulations 1.8 Language All information and wordings included on the main label, back label, neck label and packing carton or affixed to the container and appearing in a language other than French must also be printed in French in characters of equal or greater height than those of the wordings in the other language. In addition, all descriptive marks and informative wordings in a language other than French must be translated into French. Charter of the French Language 1.9 Refundable deposit Mandatory only for beer and beer-based (malt) alcoholic beverages. The wording must be “QUÉBEC X¢ CONSIGNÉE / REFUND” in characters at least 4 mm (12 points) in height. The amount of the deposit is 5¢ for cans 450 ml or smaller, 10¢ for glass bottles 450 ml and smaller and 20¢ for all containers larger than 450 ml. The refundable deposit must be shown on the top of cans. The refundable deposits applicable in other jurisdictions are not allowed on labels, irrespective of the type of product. Act Respecting the Sale and Distribution of Beer and Soft Drinks in Non-returnable Containers

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1.10 Best before and expiry date Products with a short life span and products with a best before date must be sold within their estimated life span. The SAQ must therefore ensure they have a reasonable sales period in its sales network. The SAQ considers products whose estimated life span is less than one year to be products with a short life span. A best before date is required for bag-in-box (BIB) products. The best before date must allow for a life span of 10 months from the bagging date. For imported products, the SAQ requires that the time period between the best before date estimated or shown on the container and the order pick-up date be greater than nine months. Any product not meeting this requirement will be sold by the SAQ until its best before date. The product will then be pulled from the outlets and all products in inventory, including in the warehouses, will be destroyed (handling, disposal). The fees for non-compliant products will then be billed to the supplier. 2 Information relating to allergies and intolerances The declaration of allergens on labels of alcoholic beverages is mandatory in Canada. The substances covered by the regulation are listed in Table 1. Food and Drug Regulations Table 1 List of allergens covered by Canadian regulations Almonds Pecans Sesame seeds Soybeans Gluten*

Brazil nuts Pine nuts Wheat Shellfish Sulphites**

Cashews Pistachios Triticale Fish

Hazelnuts Walnuts Eggs Molluscs

Macadamia nuts Peanuts Milk Mustard seed *Gluten from the following grains: barley, oats, rye, triticale, wheat, kamut and spelt. **When the total amount of sulphites in the pre-packaged product is 10 ppm or more. The presence of allergens can be declared either in the ingredients list or in wording that begins with “Contient… / Contains….” The wording must be in both French and English. Please note that fining agents such as egg whites, casein and isinglass must be declared using the wording “Contient de l’œuf / Contains eggs,” “Contient du lait / Contains milk” and “Contient du poisson / Contains fish” to make them more understandable to consumers. However, for pre-packaged beer, ale, stout, porter and malt liquor, the allergen alert is mandatory only if a list of ingredients also appears on the label.

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For vintage-dated products, the allergen alert is required for products from the 2012 vintage and all subsequent vintages. It should be noted that for products considered as possibly containing undeclared allergens, the SAQ may ask its suppliers to fill out an allergen declaration form. 2.1 May contain allergens This type of wording may encourage the abusive use of precautionary labelling. Health Canada will soon finalize rules governing this practice. At present, we do not accept such wording on the products that we sell. 2.2 Allergen-free This notion may be confusing to consumers. Stating that a product does not contain allergens or sulphites may lead consumers to think that other similar products must contain them. For example, the wording “sulphite-free” on a bottle of Japanese sake may confuse consumers about other Japanese sakes that do not have the wording on their labels (sulphite use is prohibited in sake-making in Japan). 3 Sustainable development 3.1 Organic products Various laws and regulations in Quebec and Canada govern the use of the term “organic” and its terminological equivalent “ecological.” For a product distributed by the SAQ to be considered organic, it must comply with these laws and regulations. Furthermore, the supplier must be able to provide a certificate attesting to its organic status in conformance with the Canadian Organic Products Regulations and the Act Respecting Reserved Designations and Added-Value Terms. 3.1.1 Standards recognized in Canada Organic products regulations have been in force in Canada since June 30, 2009. The regulations require that, to be sold on Canadian territory, organic products must be certified in compliance with the Canadian Organic Regime (COR) or any other standard for which there exists an equivalency arrangement with Canada. The certification bodies that issue the certificates must be accredited by the competent authorities in the country where the standards apply. Organic Products Regulations The following table lists the countries for which an equivalency arrangement exists. The recognized standards and the names of the government agencies responsible for accrediting the certification bodies are also listed.

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Country Standard Government agency responsible for

accrediting certification bodies Canada Canadian Organic Regime (COR) Canadian Food Inspection Agency (CFIA) United States

National Organic Program (NOP) United States Department of Agriculture (USDA)

Europe (EC) No. 834/2007 (EC) No. 889/2008 (EC) No. 1235/2008

Direction Générale de l’Agriculture et du Développement Rural

Japan Japanese Agricultural Standards Food Safety and Consumer Affairs Bureau

Switzerland Switzerland’s Organic Farming Ordinance

Office fédéral de l’agriculture (OFAG)

Costa Rica Organic Agriculture Regulation – Decree No. 29782 from Ministry of Agriculture and Livestock

Servicio Fytosanitario del Estado

3.1.2 Labelling of organic products Prior to printing your labels, you must submit the mock-ups to your certification body for validation. The body must ensure that the specific requirements of the organic regulations and standards of the country where your ordered products will be sold are complied with.

A) Organic product (>95% organic products):

The following are mandatory: • The wording “Biologique / Organic” • Name of the company that holds the product’s certificate • The wording “Certifié par… / Certified by…” or “Certifié biologique par… /

Certified organic by…” followed by the full name of the certifying body.12 • Identification of the organic ingredients in the list of ingredients (if applicable).

Logos are optional (e.g. Bio Canada, USDA Organic, etc.)

B) Organic product 70% to 95% of whose contents are organic ingredients:

The following are mandatory: • The wording “Produit contenant x% d’ingrédients biologiques / x% organic

ingredients” • Name of the company that holds the product’s certificate • The wording “Certifié par… / Certified by…” or “Certifié biologique par… /

Certified organic by…” followed by the full name of the certifying body.12 • Identification of the organic ingredients in the list of ingredients.

12. Use of the certification number alone (e.g. FR-BIO-01, IT-BIO-009, DE-ÖKO-03) is not acceptable. Also, use of the logo of the certification body does not replace the requirement that the full name of the certifier be listed after the wording “Certified by…”.

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The list of ingredients must allow the organic ingredients to be distinguished from the non-organic ingredients. However, the size, colour and style of the characters must be similar to those used for the declaration of non-organic ingredients. Examples: Ingredients: Vodka*, Sugars (grapefruit juice*, sugar), Citric acid, Natural flavours (*organic). Ingredients: Organic Vodka, Sugars (organic grapefruit juice, sugar), Citric acid, Natural flavours.

Please note that any reference to the organic production method in a text is unacceptable if the product is not certified organic in compliance with the laws and regulations in effect. 3.1.3 Prohibited wordings The following wordings are not allowed on the labels of organic products in Canada:

• “Wine made from organic grapes” or equivalent wordings13 • “100% organic” • “Certified organic” without mention of the certifier • “Made with organic (ingredient name)” or “Made using organic ingredients” • “Converting to organic farming” or equivalent wordings.

3.2 Biodynamic products You must be able to provide us with a certificate issued by a competent body supporting such a claim. In addition, your product must be certified organic in compliance with Canadian regulations. 3.3 Natural wines The SAQ requires that the wines identified as “natural” that it sells be certified organic in compliance with Canadian regulations. 3.4 Fair-trade products The labels of fair-trade products can carry the Fairtrade Canada mark and the wording “”Certifié Équitable / Fair Trade Certified” may be written on the label. Use of the FAIRTRADE logo is not mandatory. You must be able to provide the certificates proving your compliance with the fair-trade rules. Fairtrade Canada

13. Only the wording “Vin biologique / Organic Wine” is acceptable in Canada. However, for vintage products made before 2010 (made before the year in which the regulations entered into force), we will accept the working “Wine made from organic grapes”.

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3.5 Integrated farming This notion – also known as integrated production – is not regulated in Canada. However, if you want to include this wording on a label, you must be able to provide a certificate issued by a competent body supporting such a claim. 3.6 Sustainable development This notion is not regulated in Canada. However, if you want to include this wording on a label, you must be able to provide a certificate issued by a competent body supporting such a claim. 3.7 Environmental claims By “environmental claims” we mean all declarations, other than organic and fair trade, that are regulated by their own body. Examples of this would be the use of lightweight glass in bottle manufacturing, recycling of manufacturing materials or energy conservation. Environmental claims may not be misleading or confusing. They must be accurate, true and verifiable. We reserve the right, if necessary, to require that you provide authenticating documents (certificates or other) and to question you about your practices. We refer you to Environmental Claims: A Guide for Industry and Advertisers, which is published by the Canadian Standards Association. Environmental Claims: A Guide for Industry and Advertisers 4 Health claims and other warnings 4.1 Health claims By “health claim” we mean any wording that could imply that the consumption of alcoholic beverages has a beneficial effect on one’s health. No wording of this type is acceptable on the labels of alcoholic beverages that we distribute. Code of Ethics of the Alcoholic Beverage Industry in Quebec 4.2 Alcohol consumption warning Warnings regarding the consumption of alcohol, such as the U.S. government warning or the European warning about consuming alcohol during pregnancy, are acceptable if they are provided in French. CFIA decision regarding the labelling of alcoholic beverages The acceptable French translation of the U.S. government warning is as follows:

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AVIS GOUVERNEMENTAL : Selon le chef de santé des États-Unis, les femmes ne devraient pas consommer de boissons alcoolisées pendant la grossesse vu le risque de malformation congénitale. La consommation de boissons alcoolisées diminue la capacité de conduire un véhicule ou d’utiliser de la machinerie et peut causer des problèmes de santé.

4.3 Standard drinks (UK units or standard drinks of alcohol) When the notion of a drink or standard serving is referred to on the label, it must correspond to the definition of a standard drink or serving found in Canada’s Low-Risk Alcohol Drinking Guidelines issued by the Canadian Centre on Substance Abuse (CSSA), in which a drink means a volume of an alcoholic beverage that contains 13.5 g or 17.05 ml of pure alcohol14. In specific cases where the container corresponds to a single drink, the volume of the container must be used to define the drink. The notional standard drink is defined differently in different countries. As a result, descriptions of this type, whose definition is likely to be unknown to consumers, risk creating confusion or being misunderstood. Accordingly, wordings such as “standard drinks” are not authorized in Canada. For the same reasons, the logos and warnings of the British body Drinkaware.co.uk are not acceptable. In addition, the maximum serving sizes recommended by the body are different from those in Canada’s Low-Risk Alcohol Drinking Guidelines issued by the Canadian Centre on Substance Abuse (CCSA). These logos and warnings risk confusing consumers or being wrongly interpreted by them.

5 Dealcoholized or low-alcohol beverages In Canada, to be considered a dealcoholized or low-alcohol wine, a wine must contain less than 1.1% alcohol. Accordingly, a wine whose alcohol by volume is 1.1% is not considered “dealcoholized” and would have to be described by a common name such as “partially dealcoholized wine.” Food and Drug Regulations CFIA decision regarding the labelling of alcoholic beverages 5.1 Alcohol by volume declaration The alcohol content must be printed on the label in the form “…% alc./vol.” or, if the product contains less than 0.5% alcohol, in the form “Less than – Moins de 0.5% alc./vol.”

14. Alcohol and Health in Canada: a Summary of Evidence and Guidelines for Low-Risk Drinking, page 15.

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If the alcohol content is 0.5% or less, the product is not considered an alcoholic beverage and a nutrition facts table must be included on the label. 5.2 Ingredients permitted in dealcoholized wines Any ingredients that are permitted in “wine” (B.02.100 of the Food and Drug Regulations) are permitted in “dealcoholized wine.” However, ingredients added directly to the dealcoholized wine after dealcoholization must be declared in the list of ingredients (e.g. dealcoholized wine, sugar, glucose). If ingredients are added that are not permitted to be added to “wine,” whether they are added before or after dealcoholization, the common name “dealcoholized wine” is not acceptable. Such a beverage could be called a “dealcoholized wine beverage.” In such cases, a list of ingredients is required. “Dealcoholized wine” may contain added water as an ingredient but only in an amount to replace that which is removed during the dealcoholization process, which generally removes water as well as alcohol. The water is returned to the wine after dealcoholization and need not be declared as an ingredient. 6 Other labelling concepts 6.1 “Product of Canada” and “Made in Canada” claims Use of the “Product of Canada” and “Made in Canada” claims is subject to guidelines. 6.1.1 Product of Canada This claim is allowed only if at least 98% of the ingredients contained in the product are sourced from inside Canada and the processing and labour used to make the product are also Canadian. The term “Canadian” is considered to be the same as a “Product of Canada” claim. 6.1.2 Made in Canada This claim may be used when the last substantial transformation of the product occurred in Canada. It must be accompanied by a qualifying statement indicating the source of the ingredients. For example, “Made in Canada from domestic and imported ingredients”15 or “Made in Canada from imported ingredients.” 6.1.3 Other Canadian content claims Other types of claims may be used provided they are factual and not misleading. Examples: Distilled in Canada, Packaged in Canada, Made with Canadian maple syrup.

15. The terms “domestic” and “imported” must be reversed when the percentage of imported ingredients is greater than the percentage of Canadian ingredients.

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6.2 Nutrition facts table Beverage alcohol products are usually exempt from having to include a nutrition facts table on their label. However, in some very specific cases, a nutrition facts table may be required. For example, this is the case for beverage alcohol products labelled with claims regarding the calories they contain, for products that contain artificial colourings and for dealcoholized products. Food and Drug Regulations The Canadian Food Inspection Agency has prepared a nutritional labelling toolkit. Please note that use of the provided templates is mandatory. Nutrition labelling New rules effective December 14, 2021 6.3 List of ingredients Standardized alcoholic beverages, as defined by the Canadian Food and Drug Regulations, are exempt from the requirement of including a list of ingredients on their labels. A standardized alcoholic beverage is a beverage for which a legal definition exists in Canada. Such beverages include wine, whisky and beer, among others. Food and Drug Regulations Accordingly, all unstandardized alcoholic beverages must include a list of ingredients, in French and English, on their labels. The list of ingredients must meet the following requirements16:

• Black type on a white or neutral background. • Use of lowercase and uppercase letters for ingredients that appear in the list.

Only the first letter of each ingredient should be capitalized. • The ingredients are separated by bullet points or commas. • The ingredients are listed in decreasing order by weight. • Sugar-based17 ingredients are grouped together between parentheses after the

word “Sugars” in decreasing order by weight. • Food colourings are designated by their unique usual name. • The titles “Ingredients” and “Contains” are in boldface type.

16. On December 14, 2021, the new Canadian labelling rules will enter into force as part of the CFIA initiative to modernize food labels. You can begin complying with the new rules immediately or wait until they enter into force. For the sake of conciseness, we here present only the new rules pertaining to the list of ingredients. 17. Sugars may include white sugar, beet sugar, raw sugar or brown sugar, agave syrup, honey, maple syrup, barley malt extract, fancy molasses, fructose, glucose, glucose-fructose (also know as high-fructose corn syrup), maltose, sucrose, dextrose, concentrated fruit juice and fruit purée concentrates. .

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• The minimum height of the characters is 1.6 mm (1/16 inch), based on the height of the lowercase “o.”

• The same formatting rules apply to any “contains” declaration indicating the presence or possible presence of priority food allergens, of sources of gluten or of added sulphites.

Example of a list of ingredients: Note that, in cases where all the ingredients used are mentioned in the product name, the list of ingredients is not necessary. For example, this would be the case for a vanilla-flavoured vodka whose only ingredients are vodka and vanilla. 6.4 Low-calorie and calorie-reduced drinks18 Use of the term “calorie-reduced” is allowed only if the product contains at least 25% fewer calories than the original product. Use of the term “low calorie” applies only to products that contain no more than 40 calories per serving. The notion of serving to be used for labelling purposes is the one defined in in Canada’s Low-Risk Alcohol Drinking Guidelines issued by the Canadian Centre on Substance Abuse (CSSA), in which a drink means a volume of an alcoholic beverage that contains 13.5 g or 17.05 ml of pure alcohol. In cases where the container corresponds to a single serving, it is the volume of the container that is used to define the serving size. All references to calories must appear on the back label. A nutrition facts table must also be included. Food labelling for industry 6.5 Proof Use of the PROOF scale as a means of declaring alcoholic strength is not authorized in Canada. Besides being poorly understood by consumers, the presence of this wording may create confusion about the product’s actual alcohol content and is therefore not authorized. 6.6 Imported by an organization other than the SAQ As only the SAQ is entitled to import alcoholic beverages into Quebec, the declaration “Imported by…” is unacceptable. 18. The same rules apply to claims related to the nutrient content of sugar or alcohol, for example.

Ingredients: Alcohol, Cream, Sugars (sugar, maple syrup), Whisky, Citric acid, Natural flavours, Sun Yellow FCF. Contains: Milk

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However, if the declaration is meant for a market other than Quebec and this is clearly indicated, the presence of such a declaration will be tolerated. In such cases, it must take the following form, for example: “For the USA, imported by Maison du vin.” An alternate acceptable wording would be “Imported for…” 6.7 Artificial flavours and graphic representation Fruits and herbs are often depicted on the labels of alcoholic beverages. However, rules apply if artificial flavours, whether alone or in combination with natural flavouring agents, have been added to the product. The use of an image of a fruit or herb on a label normally implies that product contains the fruit or herb. If that is not the case but rather artificial flavours have been used, the declaration “imitation,” “artificial” or “simulated” must appear on or adjacent to the image of the fruit or herb. Food labelling for industry 7 Packaging 7.1 Tamper-proofing of containers Containers must be sealed so that any attempt to open the container will leave marks or signs visible to consumers. Appendix 2 presents a summary of the requirements by container type and opening type. Consumer Packaging and Labelling Regulations 7.2 Standardized container size Standardized container sizes exist for wine. Wine may be sold online in container sizes of 50 ml, 100 ml, 200 ml, 375 ml, 500 ml, 750 ml, 1 L, 1,5 L, 2 L, 3 L or 4 L. For spirits, the accepted formats are 50 ml, 200 ml, 375 ml, 750 ml, 1,14 L et 1,75 L. Consumer Packaging and Labelling Regulations 7.3 Alternate containers By “alternate container” we mean any container or material that is in direct contact with the beverages and that is not traditionally used in the beverage alcohol industry. For each type of alternate container, you must fill out a form that specifies the materials used. The materials in direct contact with the liquid must comply with part B of the Food and Drug Regulations. You must also be able to provide to the SAQ proof of health protection agency approvals, any other documents necessary to demonstrate that the

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packaging material satisfies the regulatory requirements and all documents supporting the conditions of use of the packaging material. Guidance for Food Establishments Concerning Construction Materials and Packaging Materials and Non-Food Chemicals

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Appendix 1 Batch (Lot) Number Guidelines The purpose of the following guidelines is to ensure that the batch numbers printed on the sales units are easily found, decipherable and interpretable. Recommended location We recommend using one of the following three locations.

Legibility The characters in which the batch number is printed must be at least 1.6 mm in height. They must also be printed so as to provide sufficient contrast with the background. Recommended format We recommend using one of the following two batch number formats:

• L070121, i.e. the letter L followed by the two-digit year number (07 for 2007), two-digit month number (01 for January) and two-digit day number (21 for the 21st day).

• L7021, i.e. the letter L followed by the one-digit year number (7 for 2007) and

three-digit number of the day of the year (021 for January 21).

614141000012L070501

L070501

L070501

1 At the bottom of the back label

2 In the area located at the base of the neck

3 In the area located at the base of the bottle

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Appendix 2 Tamper-Proofing of Containers

PACKAGING CLOSURES

TYPE TAMPER-PROOFING (SALEABLE PRODUCTS)

Bottles

Non-twist-off crown caps

These are typically found on imported beer products and require the use of an opener to remove. Once removed, the cap is deformed and cannot be put back on the bottle.

Twist-off crown caps

These are typically found on North American beer products and are removed by twisting the cap or using a bottle opener. Beer products using this type of closure must be sold in a sealed consumer unit or otherwise be made tamper-evident by the application of a tamper evident feature, e.g. foil overwrap, shrinkable seals, paper seals.

Shrinkable seals over the caps

These seals: • are frequently found on twist-off caps; • extend up the neck and over the bottle cap; • must be firmly attached to both the bottle and neck.

Foil overwrap The foil overwrap: • is frequently found on beers and coolers with twist-off caps; • extends up the neck and over the bottle cap; • must be firmly attached to both the bottle and neck.

Cork finish Cork finish is used: • mostly in wine but also in some premium spirits, fruit brandies and liqueurs; • together with an over-covering capsule, seal or disc made (normally) of paper, plastic, wax or metal foil. Note: Paper or wax discs placed directly on corks must adequately adhere to the cork and provide visible evidence of tampering when removed.

Screw caps A metal ring or plastic is attached directly underneath the cap and breaks when the cap is removed.

Bag-in-box (BIB)

All BIB products must be winery sealed. The valve opening in the box must also be sealed.

Tetra Pak/Flexi pack (Cheer Pack®)

Tamper-evident rings with bridge seals

The plastic ring is attached just under the cap on the Tetra Pak and is designed to break when the cap is removed. Plastic caps with hidden bridge seals require paper strip-seals to make them tamper-evident.

Twist-off caps These are removed by twisting the cap. Tetra Pak products using this type of closure must be sold in a sealed consumer unit or otherwise be made tamper-evident by the application of a tamper evident feature, e.g. plastic pull tab seal.

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Cans Pull tabs The metal pull tab is intact Screw caps A metal or plastic ring is attached just under the

cap and is designed to break when the cap is removed.

Enclosed packages Enclosed package (e.g. beer packages) that completely encloses the product. The seal must be broken to have access to the contents.


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