On January 1, 2017, the Healthy Menu Choices Act came into force in Ontario. The Act mandates that food service chains with 20 or more locations in Ontario post caloric content for most food and drink items. We published articles on the Act in November 2016, April 2016, October 2015 and May 2015, discussing the contents, requirements and exemptions under the Act and its accompanying regulations. As we recently noted, the Ontario Ministry of Health and Long Term Care amended and finalized the regulations for the legislation.
The Act applies to regulated food service premises (RFSPs) with 20 or more locations. RFSPs are defined as any food premise where meals or meal portions are prepared for immediate consumption or sold or served in a form that will permit immediate consumption on the premises or elsewhere. The Act is vague on the potential liability of franchisors for non-compliance by their franchisees. So franchisors with more than 20 locations in Ontario should take note.
If you are a food service franchisor in Ontario and you have questions about the Act or the accompanying regulations, please contact Larry Weinberg, Frank Robinson, Rebecca Valo or Noah Leszcz at Cassels Brock.