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Turn Lemons into Lemonade: Canada's Front-of-Package Labelling Deadline Offers Strategic Opportunities.



The January 2026 deadline for Canada’s food industry to add mandatory front-of-package nutrition (FOP) symbols to consumer packaged foods grows near. Viewed from a nuts-and-bolts executional perspective, businesses lacking an immediate strategy, resources, or a strong grasp of the impact of FOP regulations will struggle to meet the target. On the flip side, the regulatory imposition presents forward-looking businesses with a stellar opportunity for innovation and renewal.

 

Adding to earlier labelling requirements, Canada joined numerous countries in overhauling its front-of-package food labelling requirements. FOP symbols are considered an effective tool that helps consumers make healthy eating choices while reducing the risk of diet-related chronic diseases. At the same time, the symbols encourage manufacturers to improve product nutrition. Chile, Peru, Uruguay, Argentina, Mexico, Brazil, and Israel introduced mandatory FOP nutrient warning systems. Europe and the U.K., China, South Africa, and Australia have published voluntary industry guidelines.

 

Nutrients of Concern

Health Canada’s requirements for FOP nutrition symbols pertain to certain packaged foods containing three nutrients considered to be ‘of public health concern’ when present at or above specific thresholds. In other words, foods which are high in saturated fat, sugars and/or sodium.

 

On-pack disruption

Required foods must carry the FOP nutrition symbol on the front, upper half of their principal display surface (typically on the right), with warnings that reflect offending nutrient levels. Symbols must be bilingual (English and French), but may appear as separate, unilingual symbols. There is no shortage of complexity in determining which symbol format corresponds to a given package shape, size, or configuration.

 

Ushering in the new FOP symbol to the front panel also means shifting branding, marketing, product features, and other information from front of pack to other surfaces where they jostle for space and attention. Stating the obvious, esoteric language and the 78 unique FOP symbol formats listed in the Food and Drug Regulations suggest that businesses consult experienced packaging firms offering regulatory advisory services.

 

Exemptions

Many packaged foods are not required to carry FOP symbols. These include health-related exemptions for foods with a protective effect on health; technical exemptions for raw, single ingredients or foods not sold directly to consumers; practical exemptions for products such as butter, maple syrup, and salt, where the symbols would be redundant.

 

Operational risk

The clock is ticking for businesses that have yet to identify affected products, audited packaging inventories, and factored in supply chain logistics. Key to successfully managing FOP execution is understanding that the web of industries driving or supporting Canada’s packaged food sector extends beyond manufacturers and retailers to importers, offshore exporters, printing and packaging companies, marketing, and regulatory advisory services, to name a few. 

 

Bearing in mind that the food industry is currently competing for the same labelling resources, businesses without a solid plan should be reaching out for help. A rushed, poorly executed packaging transition is detrimental on many levels. Beyond causing administrative and logistical headaches, potential dangers include expensive product recalls due to incorrect labels plus the resulting rework effort and costs, followed by associated delays leading to missed print deadlines, deliveries and launch dates, as well as lost revenue.


Businesses that treat FOP changes as simple label updates are subject to the greatest risk of negative business outcomes.

 

Protecting assets

Looking beyond execution, businesses are wise to consider new, go-to-market strategies that solve for modified esthetics and potentially chilly consumer reception of existing products now bearing honest-but-alarming nutrition warnings.

 

Companies regularly bounce back from late releases and missed projections, but living brands are at the mercy of fickle customers. Businesses that treat FOP changes as simple label updates are subject to the greatest risk of negative business outcomes. Namely, customers reducing their purchases in favour of competitor products which appear to be healthier, or trading over to brands that seize the occasion to become more engaging. Brand neglect results in competitors elevating presence at-shelf and in-market – even if their products are of equal quality. Mediocre labelling of any kind harms brands and the companies that own them.

 

Strategic Opportunities

The silver lining to the FOP changes is that done right, they represent a timely opportunity for businesses to differentiate and connect with their customer base in new and more powerful ways. Several possibilities for strategic reinvention are offered.

 

The first is packaging renewal. From a design standpoint, the FOP modifications impose serious limitations on esthetics, communication, and impact, for products and brands. Existing packaging can be refreshed to more current trends, with new on-pack strategies that work harder to communicate and appeal in service of product and brand.

 

Depending on product type, there also exists the possibility of improving products via reformulation. Ingredients and processing methods may be adjusted to meet evolving consumer preferences and expectations around healthier foods. In doing so, businesses reduce the risk of customers migrating to products with healthier profiles when they no longer accept existing products ‘as is.’ Is it safe to suggest the exemptions are incentive for manufacturers to reformulate products to avoid having to carry the warnings? A 2022 study of processed beverages in Peru found that after FOP label changes, reformulations involving a decrease in sugar (replaced with sweeteners) resulted in a drop from 59% to 31% in beverages requiring FOP symbols.

 

A third strategy, specific to retailers, is to reconsider planograms in certain categories to provide the best ‘trade-over’ products on standby for customers discouraged by products with high FOP ratings.

 

Brands can own new, fertile territories which anticipate customer reactions to the warnings.

 

Lastly, and perhaps most importantly, progressive-thinking CPG manufacturers and retailers will recognize this labeling challenge as an opportunity to separate from the herd and define an approach akin to turning lemons into lemonade. By initiating health-centric customer communications – on pack, in store merchandising or through marketing programs – brands can own new, fertile territories which anticipate customer reactions to the warnings.

 

FOP changes represent a commitment to promoting consumer health and transparency in the food industry. While not without challenge, it’s important that businesses that have not yet undertaken the transition think beyond compliance and quickly pivot. Guided by experienced packaging resources, there is tremendous opportunity for businesses to better their packaging and products, while realigning their overall offer. The January 2026 deadline is fast approaching. Businesses should be developing a strategy NOW to evolve their brands – and overall brand strategy – into these requirements, in the most favourable context.

 

 

APPENDIX

 

 

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