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(November 6, 2006) Private Member’s Bill C-283 (An Act to amend the Food and Drugs Act: food labelling), has been tabled by MP Tom Wappel with good intentions, but it poses a number of serious problems. It will be impossible for restaurants to implement, costly for government to enforce, and misleading to consumers.
CRFA has urged Members of Parliament to vote against Bill C-283, for the following reasons:
Accurate nutrition information can be provided only in environments where there is a high degree of standardization. While standardization is a given in food manufacturing, it’s the exception in a restaurant setting.
Bill C-283 targets companies with sales over $10 million, but revenue is not a measure of menu or concept standardization. The bill would apply to a hotel chain that operates dozens of different restaurant concepts and room service menus; a company that owns three or four different high-end restaurants; and a contract catering company with rotating menus.
Restaurant ingredients change frequently. One ingredient change can affect the nutritional profile of dozens of items on the menu. For example, when one restaurant chain changed a sauce, it affected the nutritional composition of 40 menu items! In addition, chain restaurants may use regional suppliers and receive supplier substitutions that change the nutritional profile of menu items.
Unlike the food manufacturing industry, which packages single food items, restaurants offer menu choices in multiple varieties, sizes, flavours and options for customization. This makes it impossible to fit nutrition information on menus and menu boards in a way that is accurate, complete, legible and enforceable. For example:
A menu item that reads: |
Would require nutrition information for these options: |
Breakfast special – 2 eggs, toast, and choice of ham, bacon or sausage, plus juice, coffee or tea ($4.99) |
Eggs scrambled, poached, fried or boiled; white or whole grain toast with or without butter, jam, peanut butter or honey; ham, bacon or sausage or a combination thereof, or a fruit bowl instead of meat; orange, grapefruit, cranberry or apple juice; coffee or tea with or without milk or cream and sugar. |
Lunch special – soup, sandwich and beverage ($5.99) |
Choice of three daily soups; choice of five sandwiches custom-made with choice of breads, spread and toppings; choice of milk, juice, soft drink, coffee or tea prepared to taste. |
Medium Latte ($3.89) |
Prepared with choice of skim, 1%, 2%, whole or soy milk, with or without sugar and choice of flavour shot. |
Bill C-283 would require a new federal bureaucracy to inspect restaurants and ensure they are compliant. Even a complaint-based system would require extensive laboratory testing and analysis, along with investigation of financial records of every location within a restaurant chain to determine if the menu item in question generated at least $50,000 in sales for that company and was on the menu in every location for at least 60 days.
Bill C-283 ignores the reality that restaurant patrons increasingly customize their meals in terms of content, preparation method, side dishes, toppings and spreads. The toppings on a hamburger can alter the calorie count by up to 40%! A specialty coffee shop offers up to 19,000 beverage combinations.
By putting the focus on calories, rather than nutrition and balance, Bill C-283 delivers mixed messages to consumers. For example, a small serving of milk will show more calories than a small soft drink; a yogurt with granola will show more calories than a bag of potato chips; and a flax seed bagel will show more calories than a doughnut.
Canada’s Restaurant and Foodservice Industry is Working to be Part of the Solution
Education and Awareness: Through the Pan Canadian Healthy Living Strategy, restaurant operators have committed to helping government deliver messages to consumers about how to have a balanced diet and be more physically active. CRFA urges the government to follow through with funding for this important initiative, which has been endorsed by a multi-stakeholder working group representing federal and provincial governments, leading health organizations and industry groups.
Nutrition Information Program: Many chain restaurants provide their customers with detailed nutrition and allergen information for standard menu items. They do this in the form of website calculators and in-store posters and brochures. In 2005 CRFA launched the Nutrition Information Program to provide this information in a consistent format and to make consumers aware of its availability. Twenty-seven foodservice companies, representing more than 40% of chain restaurant locations, have so far signed on to the program.
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