As communicated on July 16, 2019 in a letter to the trade, the Canadian food safety regulations are evolving and modernizing to better protect consumers. As part of Health Canada’s Food Labelling Modernization Initiative, new regulatory requirements apply to the labelling of beverage alcohol products. One of these updates pertains to the declaration of sugar-based ingredients within an ingredient list.

The Food and Drug Regulations require sugar-based ingredients be grouped after the term “Sugars” within an ingredient list. The Canadian Food Inspection Agency (CFIA) defines barley malt as a sugar- based ingredient.

After further consultation, Health Canada and CFIA updated the guidance on sugar-based ingredients that require grouping to highlight that barley malt, when it is subject to fermentation, may be listed outside of the sugars grouping in the list of ingredients – see updated Annex 1: Examples of Sugars-based ingredients that require grouping to the List of Ingredients and allergens on food labels documentation that can be found on the CFIA Food Labelling for the Industry pages.

Standardized alcoholic beverages (those with compositional standards in Division 2 of the Food and Drug Regulations (FDR), such as beer, wine, rum and bourbon whiskey) are exempt from the requirement to show a list of ingredients on the label [B.01.008(2)(f), (FDR)]. However, when a manufacturer chooses to voluntarily display the list of ingredients in a standardized beer, barley malt is not required to be grouped in the sugars bracket. An ingredient list must be truthful and not misleading.

Suppliers are also encouraged to read the LCBO Summary of Regulatory Updates Specific to Beverage Alcohol linked below for an overview of the regulations, frequently asked questions and list of resources, as updated from time to time. As we progress towards the deadlines for compliance, the LCBO will continue to update trade partners in the event of any changes.

Your assistance in sharing this information with your members is greatly appreciated. Inquiries about the regulations or Canadian Food Inspection Agency (CFIA) or Health Canada requirements should be directed to CFIA via their website.

Inquiries about LCBO label reviews may be directed to the LCBO’s Quality Assurance department, at or (416) 864-6724.

LCBO Summary of Regulatory Updates Specific to Labelling of Beverage Alcohol