The Canadian Food Inspection Agency (CFIA) recently published a guidance that clarifies the definition of and regulatory requirements for simulated meat and poultry products.

Simulated meat products and poultry products are defined Canada’s Food and Drug Regulations (FDR) as foods that do not contain meat, poultry, or fish products, and that have the appearance of meat products or poultry products. Simulated meat and poultry are made mostly of plant-based ingredients and may contain other animal products (such as milk and eggs).

The appearance of simulated meat and poultry products includes the sensory characteristics of the imitated food (e.g., visual appearance, texture, flavor, and odor), and/or how the food is being advertised and represented (e.g., the food is labeled, advertised, or marketed as a food similar or comparable to a meat or poultry product).

Simulated meat and poultry products and their labels must meet specific provisions under FDR, which require that they:

• Be identified by a common name that includes the word "simulated"
• Be identified by the words "contains no meat" or "contains no poultry" (as applicable)
• Meet specific requirements for composition and fortification.

Foods that do not meet the definition of a simulated meat or poultry product include foods that contain no meat, poultry, or fish and that do not have the appearance of meat or poultry. Such foods:

• Are generally made of mostly plant-based ingredients
• May contain other animal products (such as milk and eggs)
• Are not labeled and/or advertised with words or images that present or imply that they resemble or are comparable to meat or poultry products.

While these foods may have some visual characteristics that are similar to meat or poultry products, they are not subject to the simulated meat and poultry requirements or prohibitions provided that they do not resemble them (i.e., they do not have the appearance of meat or poultry products). In addition, such foods must not be likely to be mistaken for meat or poultry products. To determine this likelihood, the overall impression of the product is assessed. All information on food labels or in advertisements, such as the common name, claims and statements, images (pictures, vignettes, and logos), and the appearance of the product (e.g., whether components have been added to the product to simulate bleeding, marbling of fat, or visual appearance of meat cuts or parts), will contribute to the overall impression created about the product.

The guidance contains a table that lists the regulatory requirements for simulated meat and simulated poultry products, and other foods that do not meet the definition of a simulated meat or poultry product.