SUPPLEMENTED FOODS — CANADA
Canada’s Supplemented Foods framework came into force in July 2022 with a transition period for products holding a valid Temporary Marketing Authorization Letter. That period ended on 31 December 2025. CFIA is now enforcing. Products still selling under old TMAL conditions, or carrying labels built for the previous framework, are exposed today rather than at some future date.
WHAT CHANGED
Under the old system each product needed its own Temporary Marketing Authorization. Under the new one there is no pre-market assessment, but there is a fixed set of rules: a List of Permitted Supplemental Ingredients, a List of Permitted Supplemented Food Categories, a Supplemented Food Facts table, and where thresholds are exceeded, a Supplemented Food Caution Identifier on the front of the pack. The burden moved from getting permission to demonstrating that you already comply.
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.
WHAT WE DO
The order matters. A label review on a formula that cannot comply produces a compliant-looking pack for a product that cannot be sold.
Formula screen against the List of Permitted Supplemental Ingredients, at your actual levels.
Category determination and confirmation that the product fits a permitted category.
Threshold assessment, including whether a caution identifier is triggered.
Reformulation options where an ingredient or level does not clear, preserving the product as closely as possible.
Supplemented Food Facts table construction and verification.
Full label and artwork review, including cautionary statements, bilingual requirements and prominence.
Claims review against what the category and framework allow.
Written position on where the product stands and what has to change.
WHO THIS IS FOR
Enforcement is active. The exposure is current and the fastest path matters more than the cheapest one.
There is no transition period available. A new supplemented food must comply from the day it is sold, which means the framework has to shape the formula, not audit it afterwards.
Intended purpose, ingredients, levels and claims together determine whether a product is a supplemented food, a natural health product, or neither. That determination is the first piece of work.
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.
Send the formula at your actual levels, the current label and the intended category, and we will tell you whether the product clears the framework as it stands and what has to change if it does not.