What does CFIA consider to be a simulated meat or poultry product and how do the regulations differ and what requirements have been set for these products? It was just such industry questions that CFIA sought to answer in the recent publication of its updated Guidance for Simulated Meat and Poultry Products. Although the regulation itself has not changed, the guidance provides new information for producers, defining the regulatory definition, clarifying labelling and composition requirements, and explaining when food products do not meet the definition of simulated.
Simulated meat and simulated poultry products are defined under the Food and Drug Regulations (FDR) as foods that do not contain meat, poultry or fish products, but have the appearance of such. In contrast, foods that contain no meat, poultry or fish and do not have the appearance of meat or poultry are not considered to be simulated products. Both are often made mostly of plant-based ingredients, and may contain other animal products (e.g., milk and eggs). Following are some key points of the new guidance.
A simulated meat or poultry product:
- Resembles a meat or poultry product due to its visual appearance, texture, flavour, odour, etc., as well as how it is advertised and represented. For example, components are added in manufacturing to simulate the bleeding or marbling of a beef burger.
- Is to be identified on its label by the word simulated followed by the common name of the product it simulates. This could be the animal species (e.g., beef, pork) or the meat cut (e.g., sirloin, chicken tenders), with the word simulated in the same size and prominence as the common name. When a simulated product is not prepackaged, the common name shall be shown on a sign displayed on or adjacent to the product in letters that are legible and conspicuous.
- Must carry the declaration “contains no meat” or “contains no poultry” on the principal display panel of the label, in close proximity to the common name and in letters of at least the same size and prominence as those shown in the product’s common name. When a simulated meat or poultry product is not prepackaged, the “contains no meat” or “contains no poultry” declaration shall be shown on a sign displayed on or adjacent to the product in letters that are legible and conspicuous.
- Must carry a Nutrition Facts table (NFt) on the label, with added vitamins and minerals declared in absolute amounts and as a percent daily value per serving of stated size in the NFt.
- Must meet the minimum protein content and rating requirements, must not exceed the maximum requirements for fat content, are mostly made of plant-based ingredients but may contain other ingredients, animal products (such as dairy or eggs), or food additives.
- When used as an ingredient of another food (e.g., soup), the declaration “contains no meat” is not required, but the label may not display any pictures or vignettes suggesting that meat is present, unless added through another ingredient.
- Are subject to mandatory specific fortification requirements
- May use claims, advertisements and representations thatare truthful; are not misleading or prohibited; and are compliant with all requirements, including all the above. Examples of acceptable claims/information include
- the phrases: meat alternative, use in the place of (named meat), has the texture of meat, vegetarian (naming the species of meat), plant-based meat, etc.
- alternative spelling or phonetic renderings (e.g., chick’n) and brand names that include such terms
- graphical representations: pictures, vignettes, logos, endorsements and trademarks that are not deceptive, misleading or misrepresent the product
- graphical representation of the meat, animal source or poultry bird the product simulates (e.g., a turkey)
Unstandardized products that do not contain meat, poultry or fish; are mostly made of plant-based ingredients (cereals, legumes, seeds, vegetables) but may also contain other ingredients (water, salt, yeast); may contain other animal products such as dairy or eggs; may contain food additives. They are not considered to be “simulated” because, while they may have some characteristics similar to meat or poultry products, they are differentiated by the fact that they are not likely to be mistaken for meat or poultry, nor are they labelled or advertised as such (e.g., a tempeh patty is brown and shaped into a disk or ball.
The product must follow requirements of unstandardized foods, including:
- The common name, and other expressions on the principal display panel, must indicate the true nature of the product and accurately and truthfully describe the product. The common name can include terms such as burger, loaf, patty, jerky, sausage, as long as it is not likely to be mistaken for an actual or simulated meat or poultry product (e.g., veggie burger, tofu burger, soy sausage, etc.).
- The declaration “contains no meat” or “contains no poultry” is not required on the label, but may be applied provided that it is not false, deceptive or misleading.
- Unless otherwise exempted, fortification of these foods is prohibited, and they generally must declare a Nutrition Facts table (NFt) on their labels [B.01.401, FDR].
- Any claims, advertisements and representations must be truthful, not misleading, and not otherwise prohibited.
- They cannot compare the product to meat or poultry or represent it as a food similar to or comparable to meat or poultry products.
- Claims such as vegetarian, veggie, plant-based can be made, provided they are not used in conjunction with terminology that promotes the product as equivalent to meat (e.g., cannot use vegetarian chicken nugget, plant-based drumstick, etc.)
- Graphical representations must not be deceptive, misleading or misrepresent the product, and cannot imply that the food has the appearance of, or is likely to be mistaken for, a meat or poultry product.
If non-compliance is identified, the inspecting CFIA agent will allow time for corrective action as accorded by the Standard Inspection Process up to January 1, 2026, in keeping with the Health Canada-CFIA Food Labelling Coordination Policy that establishes predictable compliance dates for food labelling changes.