Allergen Free Claims
"Allergen free" and "Made without allergens" have a different meaning in Japan. There is a useful reference in the 'FAQs on Food Labeling Standards' for claims such as "products made without any specified ingredients (allergens-containing ingredients)"
Would it be considered that "no specific ingredients are present" in a food product if there is a claim on the packaging saying that "made without specified ingredients"?
A claim "made without allergens" does not necessarily mean "does not contain allergens". The claim merely suggests that non-use of any specified ingredients has been confirmed by relevant documents such as manufacturer's data report.
If a "made without" claim is to be provided on the package of food products, necessary measures should be taken to prevent possible allergen cross-contamination.
What should be done if you want to make an "allergen free (no specified ingredients are present)" claim after having taken necessary measures to prevent possible allergen cross-contamination?
You can declare the item as "allergen-removed food", a claim that can be used only with approval of CAA, but it must be tested for specific allergens and proved that the allergen falls below the set detection limit.
For general processed food items, the following requirements must be met to be exempted from allergen declaration:
- The total protein content of specified allergens present in the processed food must be less than a few μg/g.
- The product, in effect, does not require allergen labeling.
( 'FAQs on Food Labeling Standards' - C-3)
To make "allergen free" claims, you need to check ingredient specification and manufacturing process of the product to make sure that necessary measures have been taken to prevent possible allergen cross-contamination, and test the specified ingredients to be labeled on the product. If wheat, eggs and milk are the specified ingredients to be declared on the product package, the respective detection limit must be identified and confirm those allergens present in the product do not exceed each detection limit by the test before shipping. You will be requested to promote internal quality assurance in order to make "allergen free" claims.
Whatever claims are used, it is important not to mislead consumers. Some products use claims such as "made without specified ingredients" or "Our products are run on dedicated lines" instead of using the term "removed".
Having said that, to have a regular check on your products after sale is important.
As indicated above, while consumers are welcoming the increase in the number of allergy-friendly products, there are challenges in the manufacturing sector and strengthening the system to prevent any accidental cross-contamination of food by allergens is one of the important tasks for food manufacturers.
Mandatory (7 items): shrimp/prawn, crab, wheat, buckwheat, egg, milk, peanuts. Recommended (20 items): abalone, squid, salmon roe, orange, cashew nuts, kiwifruit, beef, walnuts, sesame, salmon, mackerel, soybeans, chicken, banana, pork, matsutake mushroom, peach, yam, apple, gelatin.