 
  
Notice of Modification to the List of 
Permitted Preservatives  to Enable the 
Use of Modified Vinegar  in Various 
Meat and Poultry Products  
 
Notice of Modification  – Lists of Permitted Food 
Additives  
Reference Number: NOM/ADM-0176  
November 08 , 2021  
 Notice of Modification to the List of Permitted Preservatives  to Enable th e Use of Modified Vinegar in Various Meat and Poultr y 
Products – Reference Number: NOM/ADM -0176| 2 
 Summary  
Food additives are regulated in Canada under Marketing Authorizations  (MAs) issued by the Minister of 
Health and the Food and Drug Regulations  (Regulations) .  Approved food additives and their permitted 
conditions of use are set out in the Lists of Pe rmitted Food Additives  that are incorporated by reference in 
the MAs and published on the Canada.ca website.  A petitioner can request that Health Canada approve a 
new additive or a new condition of use for an already approved food additive by filing a foo d additive 
submission with the Department's Food Directorate.  Health Canada uses this premarket approval process to 
determine whether the scientific data support the safety of food additives when used under specified 
conditions in foods sold in Canada.  
The food industry has  for some time  been interested in using modified vinegar to control microbial growth in 
certain foods.  Modified vinegar can contain one or more of potassium acetate , potassium  diacetate , sodium 
acetate and sodium diacetate . These subs tances, when used on their own, are permitted for use as 
preservatives in various meat and poultry products1.  
The results of the Food Directorate’s evaluation of available scie ntific data support the safety of modified 
vinegar for use in the same meat and  poultry products where these individual preservatives are already 
permitted.  As a result, the Department published Health Canada’s Proposal to Enable the Use of Modified 
Vinegar as a Preservative in Certain Meat and Poultry Products and Preparations . The proposal was published 
on December 22, 2 020, and was open to the p ublic for comment for 75 days.   The comments Health Canada 
received are summarized in the section “Notification – Summary of Comments and Health Canada’s 
Responses” .   
One commen t was a request to authorize modified vinegar in pumping pickle, cover pickle and dry cure . This 
request was consistent wi th earlier information received by the Department to the effect that modified 
vinegar can be indirectly added to raw meat products as part of a brine or marinade .  
There is a standard  for pumping pickle, cover pickle and dry cure employed in the curing of preserved meat 
or preserved meat by -product set out in B.14.009 of the Regulations . Including pumping pickle, cover pickle 
and dry cure in the new entry M.3 w ould  allow modified vineg ar to be a  component  in these standardized 
ingredients  and indirectly added to preserved  meat and preserved meat by -product . The same conditions of 
use would  apply whether modified vinegar is added directly to foods, or indirectly  through pumping pickle, 
cover pickle or  dry cure . Since in both cases the maximum  level of use of potassium or sodium diacetate 
applies to the final  foods, the outcomes of the safety assessment remain unchanged .  
Therefore, H ealth Canada has agreed to also permit the  use of modified vinegar in pumping pickle, cover 
pickle and dry cur e employed in the curing of preserved meat or preserved meat by -product.  
The other information that was submitted to Health Canada as a result of this Notice of Proposal  did not 
further change the Department’s decision about modified vinegar .  Since the conclusions of the evaluation 
remain as described in the publication, with the exception of permitting the use of  modified vinegar in 
pumping pickle, cover pickle and dry cur e employed in the curing of preserved meat or preserved meat by -
product , Health Canada has enable d the uses of modified vinegar  by adding the entries shown in the table 
below to Part 2 of the List of Permitted Preservatives . 
 
                                                             
1 Part 2 of the List of Permitted Preservatives : potassium acetate (item no. P.01), sodium acetate (item no. S.01), 
potassium diacetate (item no. P.2.01) and sodium diacetate (item no. S.2.1).  Notice of Modification to the List of Permitted Preservatives  to Enable th e Use of Modified Vinegar in Various Meat and Poultr y 
Products – Reference Number: NOM/ADM -0176| 3 
 Modification to  Part 2 of  the List of Permitted Preservatives2 
Item 
No. Column 1  
Additive  Column 2  
Permitted in or Upon  Column 3  
Maximum Level of Use and 
Other Conditions  
M.3 Modified vinegar (a liquid 
or spray -dried mixture 
containing acetic acid and 
one or more of potassium 
acetate, potassium 
diacetate, sodium acetate 
or sodium dia cetate, 
prepared by adding 
potassium bicarbonate or 
sodium bicarbonate,  
potassium carbonate or 
sodium carbonate, or 
potassium hydroxide 
or sodium hydroxide to 
vinegar)  
 (1)  
Brawn; Headcheese; Meat 
by-product loaf; Meat loaf; 
Potted meat; Potted meat 
by-product; Prepared meat; 
Prepared meat by -product; 
Prepared poultry meat; 
Prepared poultry meat by -
product; Preserved meat; 
Preserved meat by -product; 
Preserved poultry meat; 
Preserved poultry meat by -
product;  Sausage  (1) 
Good Manufacturing Practice  
(the total amount of potassium 
diacetate or sodium diacetate 
added to the food, from all 
sources, not to exceed 0.25% of 
final product weight ). 
(2) 
Pumping pickle, cover pickle 
or dry cure employed in the 
curing of preserved meat or 
preserved meat by -produc t (2)  
Good Manufacturing Practice 
(the total amount of potassium 
diacetate or sodium diacetate 
added to the cured preserved 
meat or the cured preserved 
meat by -product, from all 
sources, not to exceed 0.25% of 
final product weight).  
 
(3)  
Unstandardized preparations 
of 
(a) meat and meat by -
product (Division 14); and  
(b) poultry meat and poultry 
meat by -product (Division 22)  
 (3) 
Good Manufacturing Practice  
(the total amount of potassium 
diacetate or sodium diacetate 
added to the food, from all 
sources, not to exceed 0.25% of 
final product weight ). 
 
Consequential Modification  
In additio n, the conditions of use for potassium diacetate (item P.2.01) and sodium diacetate (item no. S.2.1) 
were  modified so that the total amount of  potassium diacetate or sodium diacetate added to a food , if used 
                                                             
2 The modification presented in this document differ s slightly from the propos ed modification  published on 
December 22, 2020 as part of Health Canada’s Proposal to Enable t he Use of Modified Vinegar as a Preservative in 
Certain Meat and Poultry Products and Preparations  (NOP/ADP -0036 ). It was updated to reflect the comments 
received by Health Canada during the consultation period.  Notice of Modification to the List of Permitted Preservatives  to Enable th e Use of Modified Vinegar in Various Meat and Poultr y 
Products – Reference Number: NOM/ADM -0176| 4 
 in combination with modified vinegar that contains either of these additives,  does not exceed 0.25% of final 
product weight.  
Rationale  
Health Canada’s Food Directorat e completed a premarket safety and efficacy assessment of modified vinegar 
for use as an antimicrobial  preservative in various meat and poultry products .  The Department concluded 
that information related to allergenicity , chemistry, microbiology, nutrition,  and toxicology suppor ts the 
safety of modified vinegar  for use as shown in the table above , and technical information indicates this food 
additive  can have a bacteriostatic effect against certain bacteria .  Therefore, the Department has enabled the 
use of modified vinegar  as a preservative by adding to Part 2 of the List of Permitted Preservatives  the new 
item numbe r and its corresp onding entries shown in the above table .  However, there are multiple factors 
that can influence the microbial safety of a food , and food manufacturers and processors should identify 
optimal conditions for any controls, including preservatives such as modi fied vinegar, that are used to 
achieve a microbiologically safe food .  
Other Relevant Information  
Food additives and other ingredients generally must be declared in the list of ingredients on the label of pre -
packaged foods sold in Canada. For modified vin egars  manufactured with potassium bicarbonate, potassium 
carbonate or  potassium hydroxide , the name “modified vinegar” does not indicate the presence of 
potassium .  For this reason , Health Canada strongly encourag es industry to voluntarily declare the tota l 
amount of potassium  in a food  manufactured with one of these modified vinegars , as well as the percentage 
of the “daily value” for potassium, in the Nutrition Facts table .  This is  to alert individuals following a low 
potass ium diet to the presence of potassium  in food s made with  one of these modified vinegar s.  
This potassium  declaration will become mandatory for most  prepackaged foods as a result of  amendments to 
the Regulations  published in Canada Gazette  Part II on December 2, 2016 .3 For foods that are not 
prepackaged when offered for sale, such as food s prepared  in a grocery store for sale from a specialty 
counter , Health Canada strongly encourages the seller  to make the nutrition  information about the food, 
including its potassium content , availabl e to consumers . 
Food additives such as modified vinegar are required to meet food -grade specifications set out in Part B of 
the Regulations  or, if there are no ne in Part B,  the specifications set out in the  most recent  edition of the  
Food Chemicals Codex  (FCC) or the Combined Compendium of Food Additive Specifications .  The  FCC is a 
compendium of standards for purity and identity for food ingredients, including food additives, published by 
the United States Pharmacopeial Convention.  The Combined Compendiu m of Food Additive Specifications , 
which contains specifications prepared by the Joint FAO/WHO Expert Committee on Food Additives (JECFA), 
is published by the Food and Agriculture Organization of the United Nations . 
There are no specifications for modified  vinegar  in any of these sources .  However, i ndustry informed Health 
Canada that t he bases used in the manufacture of modified vinegar meet FCC or JECFA specifications , and 
that modified vinegar is manufactured under strict quality control standards and go od manufacturing 
practices , and is considered to be of food grade quality.   
                                                             
3 Regulations Amending the Food and Drug Regulations (Nutrition Labelling, Other Labelling Provisions and Food 
Colours) , Canada Gazette Part II, Vol. 150, No. 25, SOR/DORS/2016 -305. Notice of Modification to the List of Permitted Preservatives  to Enable th e Use of Modified Vinegar in Various Meat and Poultr y 
Products – Reference Number: NOM/ADM -0176| 5 
 Notification – Summary of Comments  and Health Canada’s 
Responses   
Health Canada received comments from nine stakeholders , all from industry,4 following  the publication of  
Health Canada’s Proposal to E nable th e Use of Modified Vinegar as a Preservative in Certain Meat and Poultry 
Products and Preparations  (Reference number: NOP/ADP -0036) on December 22 , 2020 .  Health Canada , in 
collaboration with the Canadian Food Inspection  Agency (CFIA),  is replying as summarized in the table 
below.5  
 
Summarized Comments  Summarized Response s 
Requested c larification on the authority  
of Health Canada and the CFIA . Health Canada is the federal authority regulating the safety 
and nutritional value of food in Canada . The CFIA is 
responsible for determining compliance with all food 
labelling requirements.  
Requested c larification on the scope of 
the proposal . Health Canada proposed  to regulate modified vinegar as a 
food additive (preservative) permitted in certain cooked or 
raw (as permitted by their standard) standardized meat and 
poultry products and certain unstandardized meat and 
poultry products as described in NOP -0036 .   
Requested c larification on t he foods not 
covered by the proposal, or request ed 
that Health Canada exten d the  use of 
modified vinegar to other standardized 
meat and poultry products , certain 
standardized foods (e.g. pumping pickle, 
cover pickle and dry cure) and 
unstandardized foods . File a  food additive submission with Health Canada for 
consideration  to be given to  extend ing the use of modified 
vinegar to other foods . 
 
Health Canada committed  to give further consideration to 
the request to allow modified vinegar in pumping pickle, 
cover pickle and dry cure as the  safet y of use of modified 
vinegar has  been assessed for the types of meat product in 
which  these ingredients would be added.  Further to this 
consideration, Health Canada has agreed to permit the  use of 
modified vinegar in pumping pickle, cover pickle and dry cur e 
employed in the curing of preserved meat or preserved meat 
by-product.  
Supported Health Canada’s initiative to 
regulate modified vinegar as a food 
additive . Noted position.  
Agree d with  Health Canada’s 
characterization of modified vinegar, its Noted position.  
                                                             
4 Six industry associations  (from which three associations presented a joint response), two ingredient suppliers and 
one consultant on behalf of a food manufacturer . 
5 The hyperlinks to the “Nature, natural – Method of production claims on food label” guidance, to the “Marketing 
Authorization for Food Additives That May Be Used as Preservatives” and to the “standard of identity” were not 
included in the original communications. They were added to the summarized comments and responses for clarity 
purposes. The CFIA is revising the above referenced guidance.  
 Notice of Modification to the List of Permitted Preservatives  to Enable th e Use of Modified Vinegar in Various Meat and Poultr y 
Products – Reference Number: NOM/ADM -0176| 6 
 Summarized Comments  Summarized Response s 
use, and the choice of the term 
“modified” in the additive common 
name . 
Opposed Health Canada’s initiative to 
regulate modified vinegar as a food 
additive and were of the opinion t hat 
modified vinegar should  not be 
considered as a substance different  
from  “vinegar”.  Noted position.  
Questioned Health Canada’s 
characterization of modified vinegar, its 
use, and the choice of the term 
“modified” in the additive common 
name .  
 Modified vinegar, which can contain one or more of 
potassium acetate , potassium diacetate , sodium acetate , 
sodium diacetate, and unreacted vinegar , is different than 
vinegar  (i.e. water and acetic acid)  as described in Division 19 
of the  Regulations . Since  modified vinegar’s main 
components are, on their own, regulated as food additives in 
Part 2 of the List of Permitted Preservatives , Health Canada 
has proposed to regulate its use as a food additive 
(preservative) permitted in the same foods and with the 
same conditions of use  as potassium acetate , sodium 
acetate, sodium acetate, and sodium diacetate . The term 
“modified vinegar” accurately communicates to consumers 
that it is no longer vinegar but a different, vinegar -derived 
product.   
Proposed other terms to be considered 
as an alternative common name or for 
use as synonyms as the term “modified” 
was considered  inaccurate or 
misleading.  The suggested synonyms (i.e. low acid vinegar, neutralized 
vinegar and buffered vinegar ) are not considered  acceptable 
options for the common name. These terms do not correctly 
describe the product and are likely to create an err oneous 
impression with consumers due to the chemical 
modifications involved, which are more than simply a 
buffering action and a change in pH.  
Opposed the term “low -acid vinegar” as 
it refers to an already -existing product. 
Emphasized that any synonym should 
communicate that “vinegar” has indeed 
been modified.  Noted position.  
Requested clarification on labelling 
requirements .  
 The additive itself (i.e. “modified vinegar”) must be declared 
in the list of ingredients, with no mention of the individual 
substances that go into production of the food additive.  
 
If the standard of identity  for a meat or poultry p roduct  
allows the use of a  preservation  method (e.g., the standards 
that apply to bacon, chopped ham, beef wiener ), there is no 
requirement to label this food as “preserved” . However, 
when the standard of identity for a meat or poultry meat Notice of Modification to the List of Permitted Preservatives  to Enable th e Use of Modified Vinegar in Various Meat and Poultr y 
Products – Reference Number: NOM/ADM -0176| 7 
 Summarized Comments  Summarized Response s 
product does not allow for the use of a preservation method 
(e.g., blood sausage), then the common name must refer to 
the use of  the t reatment or process  (e.g., preserved blood 
sausage) .  
Highlighted differences in food additive -
related requirements between the Food 
Standards of the Food and Drug 
Regulations  (Regulations) and the 
Canadian Standards of Identity (CSID) 
incorporated by reference in the Safe 
Foods for Canadians Regulations  (SFCR) . The SFCR’s CSID  are more detailed on certain aspects than 
the Regulations  food standards and vice -versa . Should  there 
be inconsistency for a food between  the SFCR and the 
Regulations , industry should rely on the requirements set out 
in Heal th Canada’s Lists of Permitted Food Additives , where it 
is specified which food additives are permitted in foods , with 
their associated limits and conditions.  
Suggested expanding the proposed 
listing by adding an entry for powdered 
(dry) modified vinegar . To provide regulatory clarity to industry and further 
transparency to consumers, the proposed List e ntry for 
“Modified vinegar” already  includes a description of what this 
ingredient is and how it is made and specifies it can be used 
in its liquid form or as a spray -dried mixture.  
Requested clarification on the 
permitted maximum level of use .  In Part 2 of the List of Permitted Preservatives , modified 
vinegar is permitted to be added at levels consistent with 
Good Manufacturing Practice (GMP ), as defined in the 
Marketing Authorization for Food Additives That May Be 
Used as Preservatives , but there is a requirement that if the 
modified vinegar contains potassium diacetate or sodium 
diacetate, the total amount of potassium diacetate or sodium 
diacetate added to the food, from modified vinegar singly or 
in combination with potassium diacetate (item P.2.01 of Part 
2 of this List ) or sodium diacetate (item S.2.1 of Pa rt 2 of this 
List), must not exceed 0.25% of the final product weight.  
Suggested to include modified vinegar 
in Column 3 (“Maximum level of use 
and other conditions”) in Part 1 of the 
List of Permitted Preservatives  under 
item A.1 (acetic acid), and in Part 2 of 
this List under items P.01 (potassium 
acetate) and S.01 (sodium acetate), as 
these substances are also components 
of modified vinegar.  The entry for a cetic acid in Part 1 of the List of Permitted 
Preservatives  is for a different purpose of use (curing) than 
modified vinegar (antibacterial) . Potassium acetate and 
sodium  acetate , which are listed in Part 2 of the list, are 
permitted for use as antibacterial preservatives at levels 
consistent with GMP. Since they do not have nume rical 
maximum levels of use, it is not necessary to specify a distinct 
condition of use in thei r respective List entry for when they 
are used in combination with modified vinegar.  
Requested clarification on compliance 
requirements.  Industry must be able to demonstrate that the use of any 
food additive complies with the regulations using s uppliers’ 
specifications, internal calculations, lab oratory  expertise or 
another reliable method . 
Expressed concern that, based on CFIA’s 
guidance Nature, natural - Method of 
production claims on food labels , foods 
containing modified vinegar would not The CFIA is revising  its guidance on “Natural” claims  to 
incorporate an outcome based approach to the use of this 
claim . The update to the guidance will be posted on the CFIA 
website in Fall 2021 . Notice of Modification to the List of Permitted Preservatives  to Enable th e Use of Modified Vinegar in Various Meat and Poultr y 
Products – Reference Number: NOM/ADM -0176| 8 
 Summarized Comments  Summarized Response s 
be allowed to carry a “Natural” claim on 
their label .  
Suggested to allow two transition 
periods, one year apart. The first would 
be to allow suppliers to bring their 
labels into compliance. The second to 
allow manufacturers to modify their 
products , if necessary, and bring their 
labels into compliance.  Regulated parties  should conta ct the CFIA  to discuss  the 
compliance date for labelling related to modified vinegar 
following  the date Health Canada publishes the  Notice of 
Modification  for modified vinegar . 
Implementation and Enforcement  
The above modification came into force November 0 8, 2021, the day it was published in  Part 2 of the List of 
Permitted Preservatives .  
The Canadian Food Inspection Agency is responsible for the enfo rcement of the Food and Drugs Act and its 
associated regulations with respect to foods.   
Contact Information  
Health Canada's Food Directorate is committed to reviewing new scientific information on the safety in use of 
any permitted  food additive, includi ng modified vinegar .  Anyone wishing to submit an inquiry or new 
scienti fic information on the use of this additive may do so in writing, by regular mail or electronically.  If you 
wish to contact the Food Directorate electronically, please use the w ords " modified vinegar  (NOM -0176 )" in 
the subject line of your e -mail.  
Bureau of Chemical Safety, Food Directorate  
251 Sir Frederick Banting Driveway  
Tunney’s Pasture, PL: 2202C  
Ottawa, Ontario K1A 0K9  
E-mail: hc.bcs -bipc.sc@canada.ca  