nals were supportive of treating beer the same as any other prepackaged food, including other standardized alcoholic beverages, and removing the labelling exemptions. These comments referred specifically to allergen and/or gluten labelling, with a few referring specifically to sulphite labelling. Comments from brewing companies and industry associations were generally supportive of removing the exemption from allergen and sulphite labelling but expressed opposition to gluten-source labelling on the basis of concerns about costs to the industry when those with celiac disease may already be expected to avoid beer. Further, brewers also indicated that the new costs come at a time when they are working to manage other new and unexpected costs, specifically increased excise duty rates that also adjust automatically by the rate of inflation each year (these changes came into force on March 23, 2017).

HC Response: Health Canada considered various scenarios in which the gluten-source labelling exemption was maintained and noted that under these scenarios, there would be inco