Food Label Inspection in Japan

Label bank_Professional Food Labeling in Japan

Expansion of Labeling Requirements for Processed Foods: Origin of Ingredients" (3)

~The current status and other countries' origin labeling systems~

The 7th review meeting on "country of origin labeling system for ingredients in processed food products" has been held on Aug. 23, 2016 - meetings have been ongoing since this January. Currently, the labeling of origin of ingredients is mandatory only for certain processed foods (22 categories and 4 types) but discussions are ongoing over the possible expansion of the scope to cover the entire processed foods.

Summary of the previous discussions


Four issues below were covered in the 6th review meeting (July 26):

  • Processed foods under review (e.g. products with an actual labeling area of no more than 30 square centimeter, unpackaged processed foods)
  • Ingredients (e.g. requirements regarding the weight-predominance of ingredients in food products, a specific origin claim in the product name)
  • How to label mandatory information (see the details below)
  • Display media (e.g. information given on the internet)

Given the fact that the origin labeling is practically difficult when it comes to processed foods which contain a number of ingredients, possible solutions to the "how to label" matter have been presented and the feasibility of expanding mandatory origin labeling is being reviewed.

  1. Listing every possible country of origin ("Listing of possible suppliers" labeling) In the case where the product contains an ingredient possibly from country A, B or C
    ⇒Origin of ingredient: Country A, B or C
  2. "Made in Japan", "Made overseas" or "Imported" ("All inclusive" labeling) In the case where the product contains an ingredient possibly from country A, B or C
    ⇒Origin of ingredient: Made overseas
  3. Labeling of country of processing for imported semi-finished products In the case where a product that has undergone primary processing in country A (the origin of ingredients unknown) is used in the product
    ⇒Country of processing: Country A

Things are going as proposed in the March review meeting so far.

Origin labeling systems in Korea and Australia


Other countries' origin labeling systems may also interest those who regularly check the reports of the review meetings. For most food products (including imported foods) it is not very common for the country of origin food labeling to be required, although you may be required, when exporting, such labeling on a product that contains specific food products or ingredients. We have outlined the labeling system in Korea and Australia below, which could be helpful information not only if you are looking into expanding your business or exporting products overseas, but also when you try to imagine a new origin labeling system in Japan.

Korea

Example 1: Pickled Chinese cabbage 70% [Chinese cabbage 98% (Domestic product), Salt 2%], Daikon radish (Domestic product)

Example 2: xx chocolate [Refined sugar, Vegetable oils and fats (Rapeseed oil-Australian, Hydrogenated palm oil- Malaysian), Mixed powdered milk (imported), Cocoa powder, Peanut butter]

Source: Origin of ingredients labeling system for processed foods in Korea (CAA*) http://www.caa.go.jp/policies/policy/food_labeling/other/pdf/160613_shiryou2.pdf

*Consumer Affairs Agency

In Korea, the origin labeling is mandatory for the first three ingredients by weight-predominance (there is a threshold at 98% for the proportion of ingredients), and this is, for example, very different from the Japanese system in terms of numerical standards. Also, the origin labeling is required when using a specific ingredient name in the product name, and "Made overseas" claim may be used in Korea for the product that has variable ingredient sources. If the product contains an ingredient that has undergone primary processing overseas, it is required to claim "Country of primary processing (country of origin)". We think the link above (Reference images are Korean labels) will serve as a reference, if the Japanese origin labeling system is to be revised as proposed in the 7th review meeting.

Australia

Bar chart with a scale under the kangaroo logo, indicating the proportion of Australian ingredients (e.g. 60%)

Chart: Bar chart with a scale under the kangaroo logo, indicating the proportion of Australian ingredients (e.g. 60%)

Source: Country of origin food labeling system in Australia (CAA) http://www.caa.go.jp/policies/policy/food_labeling/other/pdf/160726_shiryou2.pdf

In Australia, the proportion of Australian ingredients is visualized with standard marks. Priority foods are required to bear the standard mark on their labels, while non-priority foods (e.g. seasonings, snack foods) must carry country of origin/processing labeling. This is a system that indicates the proportion of Australian ingredients: "Product of Australia" claim is for a product whose main ingredients are Australian and all of its processing occurred in Australia. Claims like "Made in Australia" can be made on a product if it undergoes substantial transformation after being imported and 50% or more of the cost of production or manufacturing are incurred in Australia.

Purpose of origin of ingredients labeling


There are different views even among people involved in food-related businesses - whereas some support the expansion of mandatory origin labeling, others worry about the feasibility when its scope has been extended. In order for you to prepare a business plan, it is important after all to verify again the purpose of the system.

"The purpose of this Act is to protect producers and consumers by guaranteeing the right of consumers to be informed and inducing fair trade by having the producers indicate the country of origin of agricultural and fishery products or the processed products thereof, etc. in an appropriate and reasonable manner." (Korea)

"The purpose of this Information Standard is to provide clearer, more consistent, more informative and easier to find country of origin labels for food—so that consumers can make more informed choices about the food they buy, in line with their personal preferences." (Australia)

And in Japan, the purpose identified in the 7th review meeting is: "The purpose of origin of ingredients labeling is to provide accurate information to consumers, so that they can make rational decisions when buying food products. The safety of a food product is not guaranteed by such labeling."

Instead of just worrying about the outcome of the review meeting, you might take this opportunity to get the information that could give you an insight into your food label in an increasingly globalized international community.

References:
"Matters to be Noted relating to Health Foods under the Act against Unjustifiable Premiums and Misleading Representations and the Health Promotion Act”
http://www.caa.go.jp/policies/policy/representation/fair_labeling/pdf/160630premiums_8.pdf
Feedback to Public Comments on "Matters to be Noted relating to Health Foods under the Act against Unjustifiable Premiums and Misleading Representations and the Health Promotion Act”
http://www.caa.go.jp/policies/policy/representation/fair_labeling/pdf/160630premiums_7.pdf

September 2016