Your Quick-Start Guide to Canada's 2025 Fresh Produce Labelling Changes: Do This First

If you're in the fresh produce business, you've probably noticed a wave of regulatory updates hitting the Canadian market. The good news? Canada's fresh produce labelling regulations underwent a significant simplification on October 8, 2025, with the primary goal of reducing regulatory burden while keeping food safety standards intact.

The not-so-good news? Many businesses are still operating under old assumptions, which means they're either over-labelling (wasting money) or under-labelling (risking non-compliance). Neither scenario is where you want to be when CFIA comes knocking.

So, where do you start? I'm going to walk you through exactly what changed, what stayed the same, and: most importantly: the one thing you need to do first before anything else.

Do This First: Run a Labelling Compliance Audit

Before you touch a single label, before you call your designer, before you panic-order new packaging: stop and run a labelling compliance audit.

Think of it as a gap analysis for your current labels. You're essentially asking: Which of my existing labels won't meet the new standards? And equally important: Which labels am I over-complicating when I don't need to?

Here's why this matters: The October 2025 changes didn't just add requirements: they also removed several. That means you might be spending money on label elements you no longer need. A proper audit will identify both compliance gaps and cost-saving opportunities.

Your 5-Step Labelling Compliance Audit

Step 1: Inventory your current SKUs

Pull together every fresh produce product you sell in Canada. Yes, all of them. Include consumer prepackaged items, non-consumer prepackaged items, and anything that might fall into a grey area.

Step 2: Categorize by packaging type

This is critical because the new exemptions are heavily tied to how your product is packaged. Specifically, you need to identify:

• Products in transparent containers with 6 or fewer units
• Products packaged with a confining band
• Items in clear protective wrappers or bags (these are now classified as "unpackaged")

Step 3: Check each label against current requirements

For each product, verify that your labels include:

• Common name (still mandatory, 1.6 mm minimum type height)
• Country of origin (still mandatory)
• Grade (required for consumer sales, but now optional for products going to manufacturing/processing)
• Net quantity (check if your product qualifies for an exemption)

Step 4: Flag the gaps and the overkill

Create two lists: one for labels that need updates to meet compliance, and one for labels where you can simplify and save costs.

Step 5: Prioritize by risk and volume

Focus first on your highest-volume products and anything with the biggest compliance gaps. That's where your risk: and your opportunity: is highest.

What Actually Changed in October 2025?

Let me break down the key updates so you know exactly what you're auditing for.

Net Quantity Declarations: Now Optional for Some Products

This is the biggest change, and the one most likely to save you money. Net quantity declarations are no longer required for:

Packaging Type	Exemption Details
Transparent containers	6 or fewer units where contents are clearly visible
Confining band packaging	No quantity limit
Clear protective wrappers/bags	Now classified as "unpackaged" (think wrapped greenhouse cucumbers)

If your products fall into these categories, you can remove the net quantity declaration from your labels. That's one less thing to update every time package weights shift slightly.

Type Height Standards: Simplified to 1.6 mm

All mandatory labelling information: country of origin, grade (where applicable), and net quantity (where still required): must now use a minimum type height of 1.6 mm. This is actually a reduction from previous requirements, which means more flexibility in your label design.

This applies to both consumer prepackaged and non-consumer prepackaged fresh fruits and vegetables.

Grading Requirements: Gone for Manufacturing/Processing

Here's a big one for businesses in the supply chain: if your produce is destined for manufacturing, processing, or preserving, you no longer need to include mandatory grading information.

However: and this is important: if you're selling directly to consumers, grade labels remain required where applicable. Make sure your audit distinguishes between these two channels.

Size Designations: Now Optional

Size designation statements like "38mm and up" are now completely optional. If you choose to include them for marketing purposes, just ensure you're using the 1.6 mm minimum type height.

This is a great opportunity to streamline labels for products where size isn't a major selling point.

Don't Forget: What Stayed the Same

Not everything changed. These requirements are still firmly in place:

Common name labelling remains mandatory. Every fresh fruit and vegetable needs its common name displayed at 1.6 mm minimum height for consumer prepackaged products. No exceptions here.

Country of origin declarations are still required. This hasn't changed, and CFIA continues to enforce it consistently. Make sure your labels clearly state where your produce comes from.

Traceability requirements are still in effect. While the October 2025 changes focused on labelling simplification, your traceability obligations under the Safe Food for Canadians Regulations (SFCR) remain unchanged. If you haven't already, I'd strongly recommend reading my guide on how to start your CFIA digital readiness assessment to make sure your records are audit-ready.

Front-of-Pack (FOP) Labelling: A Quick Note

If any of your products fall into the "processed food" category: think pre-cut fruit with added ingredients, or produce with dips and dressings: you'll also need to consider the Front-of-Pack labelling requirements.

The "High In" symbol compliance deadline was January 1, 2026, meaning enforcement is now active. Whole fresh fruits and vegetables are typically exempt, but anything with added sugars, sodium, or saturated fat may require the FOP symbol.

If you're unsure whether your products are affected, check out my post on common mistakes with Canada's new supplemented foods regulations.

Common Mistakes I'm Seeing Right Now

After working with dozens of produce businesses over the past few months, here are the most frequent missteps I'm encountering:

1. Assuming all products need net quantity declarations

Many businesses are still printing net quantity on products that now qualify for exemptions. Run your audit and check your packaging types: you might be able to simplify.

2. Overlooking the manufacturing/processing exemption for grades

If part of your business involves supplying produce to processors, you may no longer need grade labels for those products. Make sure your audit separates B2C from B2B products.

3. Using outdated type height standards

Some labels still use the old, larger type height requirements. While this won't make you non-compliant, it does limit your design flexibility. Consider whether a refresh makes sense.

4. Forgetting about traceability

Labelling is just one piece of the puzzle. CFIA inspectors are increasingly focused on whether you can trace your products through the supply chain. Your labels might be perfect, but if your records aren't in order, you're still at risk.

Your Next Steps

Here's what I want you to do this week:

1. Run your labelling compliance audit using the 5-step process above
2. Identify your highest-risk products and prioritize those for label updates
3. Review your traceability records to ensure they align with your labelling claims
4. Consider a professional gap analysis if you're working with a large SKU count or multiple distribution channels

The October 2025 changes were designed to make your life easier: but only if you know how to take advantage of them. A proper audit is the foundation for everything else.

Need a Strategic Partner?

If you're looking at hundreds of SKUs and feeling overwhelmed, I get it. That's exactly where I come in. I help fresh produce businesses navigate CFIA compliance without the guesswork: from labelling audits to full regulatory strategy.

Let's connect and figure out the smartest path forward for your business. Visit nerissaallen.com/about to learn more about how we can work together.