'Sweet' Labelling Question - Imported Chocolates

Open Forum
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A local distributor in Vancouver is selling vegan chocolate bars from the UK (with UK nutritional facts and ingredients statement) but they want a Canadian compliant label to sticker over it to expand in sales here.
I've seen stores sell imported products this way, but I'm not sure how to approach the ingredient statement. Since we don't have the ingredient formulation % of the product and Canada requires grouping sugars together, what would be the best way to declare the ingredients?

My interpretation is - Cane sugar, Cocoa butter, Cocoa mass, Maltodextrin, Rapeseed lecithin, PGPR, Natural vanilla flavor, Salt, Potato starch, Peanut butter, Coconut oil, Ammonium bicarbonate, Sodium bicarbonate
Reasoning - I gathered that cane sugar is the ingredient with the largest % composition, so I consolidated it from the 'Plant-Based Style Milk Chocolate' and the second* ingredient (Cane Sugar). Additionally, I grouped together the Rapeseed lecithin and Salt since it was used in the 'Plant-Based Style Milk Chocolate'

Looking forward to hearing your thoughts! Appreciate your input, thank you! :)
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Hi Shishira,

CFIA has some guidance on grouping sugars-based ingredients, including

Sugars-based ingredients in components

It is not required to group sugars-based ingredients in components. This means when components such as sugar or dextrose appear in parentheses after an ingredient, they will stay ungrouped in those parentheses along with other components. None of the components need to be part of the overall "Sugars" grouping in the list of ingredients.

However, when suppliers sell certain foods in Canada, the sugars-based ingredients would already be grouped. In such cases, manufacturers are allowed to keep the sugars-based ingredients grouped when declaring components.


This may or may not be applicable to your product so would recommend having a regulatory specialist conduct a full compliance review of the label, including NFT, serving size, net weight, claims, romance copy etc.. I know we've got many helpful product development consultants on YODL!


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For labeling questions you could reach out to

Bernie Desgagnés

President & CEO, Source Nutraceutical, Inc.