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The CFIA Wants to Make It Easier to Mislead Consumers About Meat, Dairy, and Eggs

Animal Justice February 24, 2017

The Canadian Food Inspection Agency (CFIA) is overhauling food labelling regulations, which include animal welfare claims on meat, dairy, and egg packaging like “free range” and “grass fed.” But instead of cracking down on the epidemic of false animal welfare claims, the government plans to weaken regulations and introduce new loopholes.

The CFIA wants to make animal welfare and related “consumer values” claims its lowest enforcement priority. In other words, the agency won’t proactively define and regulate claims about how farmed animals are treated, and may not even bother investigating companies for blatantly false animal welfare claims.

Instead, the CFIA wants to make it consumers’ responsibility to contact companies themselves to find out what their animal welfare claims mean. According to the CFIA, industry has a “legal and ethical responsibility” to ensure labelling claims are not misleading. But consumers have no way of verifying information provided by companies, which stand to benefit financially from misleading consumers.

If consumers are concerned about false labelling claims made by companies, the CFIA is proposing that consumers make their complaints directly to the companies themselves. In other words, if a company’s packaging uses misleading imagery or language, consumers have to first complain to the company. The CFIA will only pay attention to a consumer complaint if a company has provided an insufficient response, and will only investigate once multiple complaints are received.

cfia labelling

The CFIA wants to make it consumers’ responsibility to monitor and verify animal welfare claims.

Animal farming is notoriously secretive. It takes place on private property in windowless facilities, with virtually no government oversight. Consumers have no ability to monitor these industries ourselves, which is why we expect our government to step in and protect consumers from being duped by false claims.

Labelling is a crucial component of informed consumer choices. Consumers should be able to rely on the words and images used on labels being accurate and truthful. And in fact, polling shows 82 percent of consumers want clearer animal welfare labelling.

Previous work by Animal Justice has highlighted an epidemic of false animal welfare claims, misinformed consumers, and a nonexistent government response. We’ve filed consumer protection complaints against slaughterhouse Maple Lodge Farms for claiming to treat chickens humanely even while on probation for illegal animal cruelty; against supermarket chain Safeway for marketing chicken meat as “certified humane,” even though birds are crowded in dark barns and deprived of anything that makes life worth living; and against the Dairy Farmers of Canada for running deceptive dairy ads disguised as public health announcements.

Meanwhile, the European Union understands the importance of addressing animal welfare labelling, recognizing that if consumers lack information, “there is very little motivation for more producers to improve animal welfare and market their products accordingly.”

It’s not too late to tell the CFIA to monitor animal welfare labelling claims! Here’s what to do: Simply go to their online survey before March 15. Skip ahead to “Stream 2,” which is 88% of the way through the survey.

For Question 2, select “no.”

For Question 2i), explain that animal farming lacks transparency and government must ensure consumers are able to make informed choices.

For Question 2ii), explain that welfare claims must be regulated, and they must be the responsibility of government (not industry and consumers).

If you’re pressed for time, you could also simply fill in our petition here.

Thank you for taking action for animals.

Image: Egg-laying hens inside a “cage-free” farm, courtesy Direct Action Everywhere.

Animal Justice

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Canadian Food Labels Guide

Animal Justice December 23, 2014


Food labels are intended to enable consumers to make informed food choices. Unfortunately, food labels in Canada are largely unregulated and can be misleading. Thus, the use of food labels such as “cage free”, “organic”, “free range”, “grass fed”, “natural”, and so on, may not mean what you think they mean. This guide sets out what food labels do—and don’t—mean for animal welfare.

 

 

 

 

Food Labels*

Cage free”: means hens are not confined to battery cages. However, they don’t have access to the outdoors, and there are no assurances about what they are fed or what kinds of medications they are given.[1] Further, these claims are unverified and uncertified, meaning that no independent inspection or verification ensures that producers using these labels are in fact raising their animals in the method indicated.[2]

Certified local sustainable”: means that eggs and poultry products come from cage-free chickens. Producers will only be certified once inspected to ensure their chickens are kept in free-range or free-run conditions and that they are given a minimum amount of space allowance that is far higher than the industry norm.[3]

Certified organic”: means the animal was raised according to the standards of an organic certifying body and verified by an independent inspector (for example, “SPCA Certified”, “BC Certified Organic”, “Canada Organic”, “Quality Assurance International” and “USDA Organic”).[4] Certified organic means eggs and poultry products come from cage-free chickens. Producers will only be certified once inspected to ensure their chickens are kept in free-range or free-run conditions and that they are given a minimum amount of space allowance that is far higher than the industry norm.[5] Additionally, only products with organic content that is greater than or equal to 95% may be labeled or advertised as “organic” or bear the organic logo.[6]

 Farm fresh”: implies that eggs were distributed directly from the farm to the store. The label is only to be used if a grader grades their own eggs in a registered on-farm operation and ships them directly to the store.[7] No standards for animal welfare.

Free range”: means that hens are kept in open barns, uncaged, with access to the outdoors. “Access to the outdoors” means that hens see the light of day (depending on the weather) and their feet actually come in contact with the earth.[8] However, hens in these systems may still be kept in very crowded conditions inside the barn. Also, there is no independent inspection or verification to ensure that producers using these labels are in fact raising their animals in the method indicated.[9]

Free run”: hens are kept in open barns, uncaged. However, hens in these systems may still be kept in very crowded conditions inside the barn. Also, there is no independent inspection or verification to ensure that producers using these labels are in fact raising their animals in the method indicated.[10]

Fresh”: when used for eggs, the label is only permitted if it appears as part of a statement (like “all eggs are fresh”), or in order to distinguish them from other physical forms of eggs such as powdered, because the Canadian Food Inspection Agency (CFIA) believes that all eggs are fresh.[11] For meat and poultry, “fresh” means the animal has not been treated by any means, other than by refrigeration, vacuum packaging or modified atmosphere packaging to ensure their preservation. However, “fresh sausage” made with frozen meat may be described as “fresh”.[12] No standards for animal welfare.

Grain-fed” or Vegetable grain-fed”: means animals were fed a grain diet, where the macro feed ingredients, added as sources of energy and protein, were made up solely of grains and grain by-products with no ingredients of animal origin. Minerals and vitamins as well as non-nutritive feed additives such as medications, biologics, pellet binders, enzyme supplements, anti-caking agents, flavouring agents, etc., may be added regardless of origin. So, additives such as Vitamin D3 derived from the lanolin of sheep wool and vitamins and minerals which are encapsulated in gelatin of animal origin may be added without disqualifying the final product from making the claims “grain fed” or “vegetable grain fed”.[13] No standards for animal welfare.

Grass fed”: means that an animal was fed a grass diet. The use of this label is unverified, meaning that producers who use these labels on their products have not been inspected or verified to make sure they are raising their animals in the method indicated, unless they are also certified under a program that includes that method in its requirements.[14] No standards for animal welfare.

Genetically modified” or “genetically engineered”: applies to food that consists of organisms that have undergone genetic engineering and to food derived from these organisms. Genetically modified foods in Canada do not need to be labeled as such, although there is a voluntary system in place. Similarly, a producer may label a product as “not genetically engineered” provided such claims are truthful, not misleading or deceptive, and not likely to create an erroneous impression of a food’s character, value, composition, merit or safety, and in compliance with all other requirements set out under the Canadian Food and Drug Administration (FDA), the CPLA (Consumer Packaging and Labelling Act) and other applicable legislation.[15]

Halal”: when a food is certified as Halal, it means that the animal was slaughtered in a certain way: “A sharp blade and skill in slaughtering is required to minimize pain and unnecessary suffering for the animal. This is accomplished by a quick cut to sever the veins and arteries of the neck of the animal, without cutting the nervous system or spinal cord. The massive bleeding makes the animal unconscious in seconds. Leaving the spinal cord intact allowing for convulsions that result from the contraction of the muscles in response to the lack of oxygen in the brain cells. This will allow for the maximum drainage of blood, carrying away in part the waste and micro-organisms, thereby improving the meat’s taste, shelf-life and healthiness”.[16]

Humane certified” (e.g. “BC SPCA certified” + “Winnipeg humane society certified”): means that the animal was raised according to the standards of a humane society or SPCA, and verified by an independent inspector. In Canada, “Winnipeg Humane Society Certified” and “BC SPCA Certified” are the two existing Canadian certifiers.[17] “Humane certified” eggs and poultry products come from cage-free chickens. Producers will only be certified once inspected to ensure their chickens are kept in free-range or free-run conditions and that they are given a minimum amount of space allowance that is far higher than the industry norm.[18]

Kosher”: describes foods and practices that are specifically permitted by Jewish dietary laws. Some animals or animal products may not be eaten at all, but those that can be must be processed in accordance with the requirements of the Kashruth.[19] Pigs, rabbits, shellfish and insects are not kosher. Meat from permitted animals may only be consumed if the animal is slaughtered in a specified manner by a trained butcher or shochet.[20] In addition, milk and meat products must never be mixed. Most cheeses must be prepared either in whole or in part by Jewish people. The labels “Jewish-style food” or “Jewish cuisine” are not necessarily considered to create the impression that the food is kosher.[21]

Natural”: a food or ingredient of food that is represented as natural is expected not to contain, or to ever have contained, an added vitamin, mineral, nutrient, artificial flavouring agent or food additive; not to have any constituent or fraction thereof removed or significantly changed, except the removal of water; and not to have been submitted to processes that have significantly altered their original physical, chemical or biological state.[22] For eggs, the label “natural” is only permitted if it appears as part of a statement (like, “all eggs are natural”) because the CFIA believes all eggs are natural.[23] No standards for animal welfare.

No hormones” or “Hormone-free”: cannot be used on labels for eggs because the use of hormones is not permitted in poultry in Canada; a “no hormones” claim can only be made as part of a statement like “use of hormones is not permitted in poultry in Canada”. Also, the label should not be used on meat, poultry or fish products because to do so would be misleading given that they all contain naturally occurring hormones.[24]

Omega 3”: has nothing to do with the care and welfare of the chickens. It simply means that the feed given to the chickens was enriched with omega 3. Does not mean the feed was organic or antibiotic-free.

Organic aquaculture”: refers to seaweeds, aquatic plants or animals cultivated in a controlled or managed environment (e.g. fish farms). Organic claims should meet Canadian General Standards Board’s “National Standard of Canada for Organic Aquaculture”, which outlines principles for organic aquaculture production and specifies minimum criteria that should be met to use “organic”, however, this is a voluntary national standard: a producer or processor may ask an independent certifying body to certify the product and may then label the product as organic, but may not bear the “Canada Organic” logo.[25]

Pasture raised”: producers who use these labels on their products have not been inspected to make sure they’re raising their animals in the method indicated, unless they are also certified under a program that includes that method in its requirements.[26]

“Raised without the use of antibiotics”: the animal or fish must not have received antibiotics from birth to harvest. In addition, no antibiotics can be administered to the mother of the animal in question in any manner which would result in antibiotic residue in the animal. Vitamins and minerals given to the animal may only be given at the level of physiological action for dietary supplement, not for antimicrobial effect.[27]

Raised without the use of hormones”: no hormones shall be administered in any way (including through the mother) to the animal that forms the food product carrying the claim “raised without the use of hormones” on the label or advertisement.[28]

Vegetarian feed”: once again, this label has nothing to do with the care and welfare of the animal. It simply means they were fed vegetarian feed.

 

Summary

Many food labels sound meaningful, but in fact have little or nothing to with animal welfare. Additionally, very few claims are regulated, standardized, or subject to compliance mechanisms. In the absence of strong government regulations, consumers should read food labels with a skeptical eye and remember that many terms are nothing more than marketing.

*These food labels apply to animals and animal products grown or produced in Canada.

 


Written by Sarah Ure – BA, JD – Articling Student for Animal Justice Canada

This blog and the contents herein are for informational purposes only and do not constitute legal advice. Readers are advised to seek legal counsel prior to acting on any matters discussed herein. The opinions expressed are those of the author.


Citations

[1] Lindsay Coulter, Choose eggs from happy chickens, online: David Suzuki Foundation <http://www.davidsuzuki.org/blogs/queen-of-green/2011/03/choose-eggs-from-happy-chickens/>.

[2] Animals on the Farm, “Farm Animal Welfare Certification”, online: Canadian Federation of Humane Societies <http://cfhs.ca/farm/humane_labelling/>.

[3] Animals on the Farm, “Farm Animal Welfare Certification”, online: Canadian Federation of Humane Societies <http://cfhs.ca/farm/humane_labelling/>.

[4] Humane Choices, online: Canadian Coalition for Farm Animals <http://www.humanefood.ca/humane.html>.

[5] Animals on the Farm, “Farm Animal Welfare Certification”, online: Canadian Federation of Humane Societies <http://cfhs.ca/farm/humane_labelling/>.

[6] Canadian Food Inspection Agency, Organic Claims, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/organic-claims/eng/1389725994094/1389726052482?chap=3>.

[7] Canadian Food Inspection Agency, Requirements for Shell Egg Products, “Other Claims – Shell Egg”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/shelled-egg-products/eng/1392837654394/1392837698515?chap=13>.

[8] Lindsay Coulter, Choose eggs from happy chickens, online: David Suzuki Foundation <http://www.davidsuzuki.org/blogs/queen-of-green/2011/03/choose-eggs-from-happy-chickens/>.

[9] Animals on the Farm, “Farm Animal Welfare Certification”, online: Canadian Federation of Humane Societies <http://cfhs.ca/farm/humane_labelling/>.

[10] Animals on the Farm, “Farm Animal Welfare Certification”, online: Canadian Federation of Humane Societies:<http://cfhs.ca/farm/humane_labelling/>.

[11] Canadian Food Inspection Agency, Requirements for Shell Egg Products, “Other Claims – Shell Egg”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/shelled-egg-products/eng/1392837654394/1392837698515?chap=13>.

[12] Canadian Food Inspection Agency, Labelling Requirements for Meat and Poultry Products, “Voluntary Claims and Statements”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/meat-and-poultry-products/eng/1393979114983/1393979162475?chap=21>.

[13] Canadian Food Inspection Agency, Method of Production Claims, “Additional Information”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/method-of-production-claims/eng/1389379565794/1389380926083?chap=9#s3c9>.

[14] Animals on the Farm, “Farm Animal Welfare Certification”, online: Canadian Federation of Humane Societies <http://cfhs.ca/farm/humane_labelling/>.; Lindsay Coulter, Choose eggs from happy chickens, online: David Suzuki Foundation <http://www.davidsuzuki.org/blogs/queen-of-green/2011/03/choose-eggs-from-happy-chickens/>.

[15] Canadian Food Inspection Agency, Method of Production Claims, “Novel Foods, Including Novel Foods that are Products of Genetic Modification, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/method-of-production-claims/eng/1389379565794/1389380926083?chap=3>.

[16] Hala, Haram, Zabiha, online: ISNA Halal Certification Agency <http://www.isnahalal.ca/info.html>.

[17] Humane Choices, online: Canadian Coalition for Farm Animals <http://www.humanefood.ca/humane.html>.

[18] Animals on the Farm, “Farm Animal Welfare Certification”, online: Canadian Federation of Humane Societies <http://cfhs.ca/farm/humane_labelling/>.

[19] What is Kosher, online: Kashruth Council of Canada, Kosher Certification Agency <http://www.cor.ca/view/54/what_is_kosher.html>.

[20] What is Kosher, online: Kashruth Council of Canada, Kosher Certification Agency <http://www.cor.ca/view/54/what_is_kosher.html>.

[21] Canadian Food Inspection Agency, Method of Production Claims, “Kosher”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/method-of-production-claims/eng/1389379565794/1389380926083?chap=4>.

[22] Canadian Food Inspection Agency, Method of Production Claims, “Nature, Natural”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/method-of-production-claims/eng/1389379565794/1389380926083?chap=2>.

[23] Canadian Food Inspection Agency, Labelling Requirements for Shell Egg Products, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/shelled-egg-products/eng/1392837654394/1392837698515?chap=0#c13>.

[24] Canadian Food Inspection Agency, Method of Production Claims, “Additional Information”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/method-of-production-claims/eng/1389379565794/1389380926083?chap=9#s3c9>.

[25] Canadian Food Inspection Agency, Organic Claims, “Organic Aquaculture”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/organic-claims/eng/1389725994094/1389726052482?chap=8>.

[26] Lindsay Coulter, Choose eggs from happy chickens, online: David Suzuki Foundation <http://www.davidsuzuki.org/blogs/queen-of-green/2011/03/choose-eggs-from-happy-chickens/>.

[27] Canadian Food Inspection Agency, Method of Production Claims, “Additional Information”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/method-of-production-claims/eng/1389379565794/1389380926083?chap=9#s3c9>.

[28] Canadian Food Inspection Agency, Method of Production Claims, “Additional Information”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/method-of-production-claims/eng/1389379565794/1389380926083?chap=9#s3c9>.

[29] Lindsay Coulter, Choose eggs from happy chickens, online: David Suzuki Foundation <http://www.davidsuzuki.org/blogs/queen-of-green/2011/03/choose-eggs-from-happy-chickens/>.

Animal Justice

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