Healthy eating is important to overall health, but Canadian health agencies disagree on the degree to which lifestyle or society determines healthy eating. The authors review the literature and design a policy analysis framework that captures discursive elements of both arguments. They apply this framework to education policy, analysing the mandated health and physical education (HPE) curriculum policies of Canada's provinces and territories. Findings indicate that, while there are regional differences, Canadian HPE curriculum policies generally position healthy eating simplistically as an individual choice, leaving gaps with respect to societal factors and nuanced individual factors. The authors conclude that Canadian HPE policies should be reviewed in light of the health risks associated with both a narrow, neoliberal emphasis on individual responsibility and an emphasis on food and activity surveillance. They recommend more critical health literacy approaches to help students understand natural body variability and the impact of social determinants on food choice.