What Canadian Food Manufacturers Need to Know About Bilingual Labelling Under SFCR

Estimated reading time: 7 minutes

If you sell pre-packaged food in Canada, every mandatory label element must appear in both English and French. Federal law requires it. It applies in every province, not just Quebec.

The Consumer Packaging and Labelling Act (CPLA), the Food and Drug Regulations (FDR), and the Safe Food for Canadians Regulations (SFCR) define exactly what must be bilingual on food labels sold anywhere in Canada. CFIA enforces these requirements through its inspection and compliance framework, and bilingual labelling ranks among the most common areas of non-compliance.

In my experience reviewing how manufacturers handle label compliance, bilingual requirements create more preventable CFIA findings than almost any other area. The fix is straightforward once you know exactly what inspectors check.

This guide covers what must appear in both languages, what qualifies for exemption, the most common CFIA findings, and what to verify in your labelling process before your next inspection.

What Must Appear in Both English and French

Under FDR B.01.012 and the SFCR, the following elements must appear in both official languages on all pre-packaged food sold in Canada:

Product identity:

• Common name of the food (e.g., “Tomato Sauce / Sauce tomate”)
• Net quantity declaration (the numerical value can appear in one language, but the unit descriptor must use bilingual text or metric symbols)

Ingredient and allergen information:

• Complete ingredient list, in descending order by proportion
• All priority allergen declarations (see next section)
• Component ingredients within composite ingredients
• Food colour and flavour declarations

Nutrition information:

• Nutrition Facts table headers, footnotes, and descriptors
• Front-of-package (FOP) nutrition symbol (Health Canada began enforcement in January 2026)

Other mandatory elements:

• Storage instructions (“Keep refrigerated / Garder réfrigéré”)
• Preparation instructions if safe consumption depends on them
• Durable life date declarations (best before / meilleur avant)

Note: The name and principal place of business of the manufacturer, dealer, or importer can appear in either English or French. It does not need to be bilingual.

What Does Not Need to Be Bilingual

Not every element on your label requires French translation:

• Brand names and trademarks remain in their registered form
• Numerical values in the Nutrition Facts table (calories, grams, percentages)
• Origin of vintage wines under certain conditions
• Test market products under limited exemptions
• Certain exemptions exist for local products, test market products, specialty products, and shipping containers. Packages with a small available display surface have reduced Nutrition Facts table requirements, though allergen declarations still apply

A common mistake: manufacturers treat “mostly bilingual” as compliant. Leaving one element untranslated on an otherwise bilingual label still counts as non-compliance during a CFIA inspection.

Priority Allergens, Gluten Sources, and Sulphites: Both Languages Required

Health Canada requires that all priority food allergens, gluten sources, and added sulphites be declared on pre-packaged food labels in both English and French. In practice, this means 11 substances that must be declared bilingually:

1. Eggs / Oeufs
2. Milk / Lait
3. Mustard / Moutarde
4. Peanuts / Arachides
5. Crustaceans and molluscs / Crustacés et mollusques
6. Fish / Poisson
7. Sesame seeds / Graines de sésame
8. Soy / Soja
9. Sulphites / Sulfites (technically a sensitivity rather than an allergen, but subject to the same declaration requirements)
10. Tree nuts / Noix
11. Wheat and triticale / Blé et triticale

Canada requires declaration of 11 substances. The US FDA requires 9. The additions that matter for Canadian labels: mustard, sulphites, and molluscs. The US list covers crustacean shellfish only, not molluscs. If you export to both markets, your labels need to handle both lists, which often means maintaining separate label versions or building a label template that covers the superset.

Sesame now appears in both countries’ lists, but Canada added it years before the US (the FASTER Act took effect in January 2023).

Front-of-Package Nutrition Symbol

Health Canada began enforcing the front-of-package (FOP) nutrition symbol in January 2026. Products high in saturated fat, sugars, or sodium must display the FOP symbol, and it must comply with bilingual requirements.

Health Canada standardizes the symbol and provides the design, but any accompanying text or modifications must appear in both languages. Manufacturers reformulating products to avoid triggering the FOP threshold should verify that their reformulated Nutrition Facts panels still meet bilingual formatting requirements.

Common CFIA Findings on Bilingual Non-Compliance

Based on CFIA inspection patterns, the most frequently cited bilingual labelling issues include:

Incomplete French allergen declarations. The English label lists all allergens correctly. The French translation misses one or uses an incorrect common name. This ranks as the most common finding because allergen lists change when formulations change, and teams do not always update the French version at the same time.

Incorrect French terminology. Machine translation or unchecked contractor translations produce technically inaccurate French terms. Health Canada’s labelling guidance uses specific French terms for each priority allergen. If your translator uses a different French term, verify it matches the regulatory standard before printing.

Missing French storage instructions. “Keep frozen” appears in English. The French equivalent does not appear on the label. Inspectors check this.

FOP symbol text not bilingual. New as of January 2026, this is an emerging finding as inspectors add FOP compliance to their checklists.

Partial bilingual compliance on imported products. Products from outside Canada entering the Canadian market must still meet full bilingual requirements. Importers sometimes add a bilingual sticker to the back of a unilingual product but miss elements on the front panel.

Getting Bilingual Labelling Right: Practical Steps

1. Audit your current labels against the full CPLA/FDR bilingual checklist. Every mandatory element listed above needs a French equivalent. Not most of them. All of them.

1. Use a qualified regulatory translator, not general translation services. Food labelling has specific terminology. Health Canada’s guidelines specify acceptable French terms for allergens, nutrients, and food components. A general translator may produce grammatically correct French that uses the wrong regulatory terms.

1. Update French labels when formulations change. Build French label review into your formulation change process. Do not treat it as a separate step that happens later or that the team forgets entirely.

1. Verify FOP symbol compliance. If your product triggers the FOP threshold, confirm the symbol placement and any associated text meet bilingual requirements.

1. Keep records of your bilingual review process. CFIA’s inspection framework assesses your preventive controls documentation. Having a documented label review process that includes bilingual verification strengthens your position during an inspection.

1. Test your recall readiness with bilingual labels in scope. In a mock recall, can you identify every product with a specific label version, including the French text? If your label management system does not track French versions separately, that gap needs attention.

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