CURRENT STATUS
The supplemented foods transition period ended on December 31, 2025. Products covered by that transition must now comply with the framework, with supplemental-ingredient rounding continuing under Health Canada’s interim policy.
Ingredient permissions and conditions can still change. We review the applicable lists and guidance for the product being developed, rather than relying on an older formula or label template.
AUGUST 13, 2026 MODIFICATION
An August 13, 2026 modification permits up to 30% combined juice, purée, pulp, or nectar content in certain qualifying caffeinated beverages, subject to the applicable caffeine entries and their conditions. This is not a blanket permission for caffeinated juice products or unrestricted juice-related marketing.
THE PATHWAY
A supplemented food must fit a permitted food category and meet the applicable conditions for its supplemental ingredients. Products outside those permissions may require reformulation, a different regulatory pathway, or a submission requesting a change to the permitted lists. We assess the product as a whole: composition, format, intended consumer, serving instructions, and proposed positioning. An ingredient’s use in another country or in an NHP does not establish its eligibility in the proposed Canadian food.
WHERE PRODUCTS FAIL
Not every ingredient permitted under a TMAL made the final permitted list. L-carnitine in caffeinated beverages is the clearest example: allowed under temporary authorisation, not permitted in supplemented foods. Where an ingredient was dropped, the product needs reformulating, not relabelling.
The permitted food categories are defined, and a product that sat comfortably under a TMAL may not fall cleanly into any of them. Category determines which supplemental ingredients and which levels are available to you.
Levels above the defined thresholds trigger cautionary statements and the front-of-pack caution identifier, with consequences for artwork, prominence and available claims. This is usually discovered at artwork stage, after the formula is locked.
The table has its own format and content requirements, distinct from the Nutrition Facts table. Rounding for supplemental ingredients currently follows Health Canada’s interim policy rather than the rule as drafted, which is a detail commonly missed.
PRODUCT DEVELOPMENT
Different product concepts create different formulation and regulatory questions. We assess the intended benefit, consumer, format, and ingredient combination before recommending a development route.
Functional beverages
Assess water-based beverage concepts, ingredient combinations, serving size, and proposed positioning.
Mixes and concentrates
Review the reconstituted product, preparation instructions, ingredient exposure, and category-specific restrictions.
Bars and eligible food formats
Assess the precise food category, supplemental ingredient permissions, serving size, and labelling implications.
Existing international products
Identify the formula, claims, and packaging changes needed for a Canadian-market assessment.
These are concept-assessment areas, not confirmation that every ingredient or format is permitted. Eligibility depends on the specific product and applicable conditions.
Assess the formula, format, and intended use together.
FORMULA & POSITIONING
We map ingredient levels, serving size, and intended positioning together. The objective is a product concept that is technically workable and supported by an appropriate regulatory assessment.
Ingredient identity : Confirm the substance, permitted form, specifications, and supplier information.
Total contribution : Review relevant amounts from added and naturally occurring sources.
Serving and preparation : Assess the applicable serving basis and the product as consumed.
Conditions of use : Check category restrictions, maximum amounts, caution thresholds, and other requirements.
Claims and audience : Review whether proposed benefits, target consumers, and marketing are compatible with the formulation.
Technical feasibility : Identify sensory, solubility, processing, and stability questions for development.
CAFFEINE-SPECIFIC NOTE
Caffeine requires particular attention. Certain caffeine permissions exclude products represented for physical performance, hydration, or electrolyte replacement, so those positioning choices must be checked before the concept is finalized.
Resolve the information requirements before committing to artwork.
PACKAGING INTEGRATION
We bring the formula assessment into the artwork process, coordinating product information, mandatory statements, claims, and available label space before print.
Supplemented Food Facts table preparation and review.
Supplemental-ingredient declarations and applicable rounding policy.
Required cautionary statements and caution identifier.
Front-of-package nutrition-symbol assessment.
Ingredient list, applicable allergen declarations, and bilingual information.
Serving instructions, preparation directions, and claims.
Consistency between approved artwork and online product information.
The supplemented food caution identifier and the front-of-package nutrition symbol serve different purposes. Some products may need both, and each must be assessed against its own requirements.
FORWARD-LOOKING INNOVATION
Some product ideas require more than a label adjustment. We assess whether the practical route is reformulation, an alternative classification, or a request to change the permitted lists.
New supplemental ingredient
Assess the information needed to support a proposed addition.
Different conditions of use
Assess a proposed change to an existing ingredient’s permitted category, amount, or other conditions.
New or modified food category
Review whether a category request is appropriate and what supporting information would be needed.
Health Canada provides a pre-market submission process for these types of list amendments. The submission must address the proposed change and supporting evidence; submitting a request is not permission to sell the product.
We can help define the request, map evidence gaps, and coordinate specialist input before you commit to a full development or submission program.
2027–2028 PORTFOLIO PLANNING
For brands developing a 2027–2028 portfolio, we help compare concepts before formula and packaging decisions become expensive to change. Each variant is assessed against its own ingredients, serving instructions, positioning, and intended market.
Concept comparison : Compare formula and positioning options against the applicable pathway.
Variant control : Identify what changes between flavours, sizes, concentrations, and formats.
Manufacturing handoff : Define the specifications and documentation needed from suppliers and co-manufacturers.
Content consistency : Coordinate approved product information across packaging and online listings.
Change assessment : Establish review triggers for supplier, formula, process, serving, claims, and regulatory-list changes.
This is a planning service, not a forecast that particular ingredients will be approved in 2027 or 2028.
Build a repeatable review process as the range develops.
WHERE TO START
An existing product needs review
Assess the formula, category, artwork, and supporting records to identify gaps and prioritize corrective work.
A new product is being developed
Evaluate ingredient eligibility, serving size, technical feasibility, and claims before the formula is finalized.
A product is entering Canada or changing category
Assess the Canadian pathway rather than assuming an overseas label or NHP formulation can transfer unchanged.
WHAT YOU RECEIVE
Depending on the agreed scope, your project may include:
Classification and category assessment.
Ingredient-permission and conditions-of-use matrix.
Serving-size and caution-threshold assessment.
Reformulation or evidence-gap recommendations.
Claims and bilingual label-review record.
Supplier and co-manufacturer documentation checklist.
Market-entry action plan and change-control priorities.
WHY KOMPETE
Kompete is a registered Trading Partner with Health Canada’s NNHPD under company code 79873. The supplemented foods framework sits on the boundary between the food and natural health product regimes, and products move across that line depending on how they are formulated and described. We work on both sides of it.
Share your formula or ingredient shortlist, intended format, serving size, proposed claims, and target market. We will help identify the pathway, the constraints, and the next development decisions.