Food Label Inspection in Japan

Label bank_Professional Food Labeling in Japan

Expansion of Labeling Requirements for Processed Foods: Origin of Ingredients (7)

~Result of public comments released~

On June 8, 2017, a Consumer Commission Food Labeling Section Meeting was held. Since then, they have been discussing the public comments made on the amendment of the new COOL system for ingredients, and which were collected until April 25, 2017, based on the information eventually gathered. The major discussion was that as for the "transition period", a time-frame of approximately 5 years should be appropriate. (At the same section meeting held subsequentely on June 29, a draft for deliberation saying that the transition period shall end on March 31, 2022 was submitted. The draft established prior to the collecting of public comments said the period shall end on March 31, 2020 : it was therefore extended by 2 years.)

Submitted opinions


The total number of opinions submitted to this amendment draft was 8,715. Among them, there were even more than 3,000 opinions just about "seaweed for rice ball". Considering the fact that 4,329 opinions were submitted to the "Food Labeling Standard (amendment of nutritional facts requirement, allergens and additives labeling and the system of Manufacturer's ID Code) in August 2014, there clearly is great interest in this amendment of the new COOL system.

If you look at the overview of the "Main public comments and possible answers about them", most of consenting opinions are similar to each other, but the same cannot be said for the various dissenting opinions. There were also quite a few opinions coming from a misunderstanding about the amendment draft of the new COOL system, which reminds us that this is a complicated system.

Important changes


After receiving the result of these public comments, the Consumer Affairs Agency proposed a draft of changes. It consists of mainly four points, which we will see in details below.

  1. About the "Listing of Possible Suppliers" designation
  2. About how manufacturers usually set the period of past purchasing records
  3. About the transition period
  4. Regarding the dissemination of information and raising awareness among consumers

"As for the 'Listing of Possible Suppliers' designation, 'Or Labeling' shall also be used.'"

"Designation of labeling methods, like 'Listing of Possible Suppliers'), is not based on some law : In this case, it has become common practice to use this designation qfter businesses stqrted to notice the possibility of several supplying countries. "The designqtion 'Or Labeling' shall be used in order to prevent consumers from misunderstanding that a product might be supplied from a country which is not listed because of the word 'possible', and also to make it clear that products are supplied only from the countries connected by 'or'."

Among the submitted opinions, the following concerns were frequently raised:
"According to the labeling rules in the amendment draft, there will be several labeling rules applied on each single product. If it looks like consumers struggle to understand the meaning of all these labelings, the new rules should only be enforced after the information is sufficiently disseminated and acknowledged by the general public."
"We cannot identify the supplying countries of the product we bought with the « Listing of Possible Suppliers »."
It seems that the Commission is considering this revision to prevent these misunderstandings.

"As for how to set past purchasing records, a period of 'one year within three years prior to the year of production' shall also be deemed acceptable."

"When the« Listing of Possible Suppliers » or « all inclusive »labeling methods are used and the purchasing record has lasted for less than a year, it must have been established within 2 years prior to the year of production . However, considering opinions in public comments, as far as the period is longer than a year (i.e during the three years prior to the year of production), no restriction shall be set and thus 'one year within three years prior to the year of production' shall be also acceptable."

Besides, below issues were also brought up among submitted opinions:
"Considering the storage and management of past data as well as the timing of the packaging film revision, the application of the new system could be quite difficult. Thus, we would like you to permit one year which is three years prior to the production."
"As for the « Listing of Possible Suppliers », a period of at least three years prior to the purchasing records (or two years in case of a purchasing plan) should be admitted."
Therefore, the Commission seems to be considering above revision to ensure a smooth application.

"A revision of the transition period will be considered."

"The transition period is currently set to end on March 31, 2020, which is the same as the transition period of the Food Labeling Standard,' but in order to avoid any omission during the transition to the new system, the final decision will be made after thoroughly considering opinions in public comments."

Among the submitted opinions, the following concerns were frequently raised:
"We need another 1 or 2 years from March 31, 2020 for the transition period since there are many products subject to the new COOL system so that research, system adaptation/switch to the new system must be gradually done."
Again, it looks like the Commission is considering revisions to secure the enforcement (of these new rules).

"Together with pro-active information dissemination and actions to raise the awareness of the general public, researches to evaluate the level of understanding of the COOL system will be carried out."

"We shall make easy-to-understand materials about the new food labeling system including a Q&A section for consumers to disseminate information and raise awareness. We shall also actively create opportunities to explain and promote a better understanding of the new system. In addition, we are planning to conduct surveys continuously to find out how much consumers understand the new COOL system."

Finally, the following topics were also raised among the submitted opinions:
"The system will need to be widely spread among consumers. We hope that a survey to check the level of customers' understanding will be carried out in a few years."
"We understand it was necessary to have exceptional rules in order to secure the system enforcement. However, the dissemination of the new standards should not rely solely on business operators, so we hope that the national government will take initiatives to support it."
Consequently, the commission seems to be considering to take such measure.

Transition period was changed to March 31, 2022.


Each board member's opinion about above points was confirmed. However a discussion was held regarding the transition period : it was concluded that "approximately 5 years is appropriate", and it was thefore decided (during the section meeting of June 29) that the transition period should end on "March 31, 2022". The next Food Labeling Section Meeting will be held on July 12. Make sure to stay in touch with the latest update if you are interested in this topic.

References:
Consumer Commission Food Labeling Section Meeting, the minutes of the 40th Food Labeling Section Meeting
http://www.cao.go.jp/consumer/kabusoshiki/syokuhinhyouji/bukai/040/gijiroku/

August 2017