Food Label Inspection in Japan

Label bank_Professional Food Labeling in Japan

Expansion of Labeling Requirements for Processed Foods: Origin of Ingredients (9)

~The Q&A section of "the new COOL system for ingredients" was revised~

On September 1, 2017, the Food Labeling Standard was amended and "the new COOL (Country of origin labeling) system for ingredients" started. At the same time, the Q&A section of the Food Labeling Standard was also amended for the third time, and a new page for "the new COOL system for ingredients" has been added.
When they started to accept public comments on March 27, 2017, "the Guidelines concerning the new COOL system for ingredients (supplementary material)” was also released in Q&A format, but some contents have since then been revised according to the addition of "the new COOL system for ingredients" page in the third amendment of the Food Labeling Standard's Q&A section. Therefore, we would like to explain the changes in details here.

Revised contents shown on the table of contents


We compared the table of contents of "the Guidelines concerning the new COOL system for ingredients (supplementary material)” which was released first with the question items from the table of contents of "the Guidelines concerning the new COOL system for ingredients" added for the third amendment of the Food Labeling Standard's Q&A section.

The Guidelines concerning the new COOL system for ingredients (supplementary material) issued on March 27, 2017
http://search.e-gov.go.jp/servlet/PcmFileDownload?seqNo=0000156620

Food Labeling Standard Q&A Appendix New COOL System for Ingredients issued on September 1, 2017
http://www.caa.go.jp/foods/pdf/foods_index_18_170901_0014.pdf

There are 34 added question items, so we will list them as follows.

Added question items


I Subject of labeling
  • (3) Is alcohol also subject to COOL?
    If so, what are the ingredients subject to it?
  • (4) Are the ingredients of so called "Kanmuri hyoji"* also subject to COOL?
    * "Kanmuri hyoji (crown labeling)" generally means using a name of a certain ingredient as a name or a part of a name of the related product.
  • (5) Is water also subject to COOL?
  • (7) Based on the rule of paragraph 1-3 of the name of ingredients in the table of article 3, paragraph 1 of the Food Labeling Standard, which ingredient"s country of origin should be labeled when the compound ingredients (ingredients composed of more than two ingredients) are separately labeled since the ingredients were just mixed (or underwent any other process that left their properties unchanged).
  • (8) According to the rule of paragraph 1-3 of the name of ingredients in the table of article 3, paragraph 1 of the Food Labeling Standard, which country of origin should be considered when a compound which is present in different compound ingredients (as defined before) of the same product is labeled as just one ingredient in the "ingredients lis" of said product?
  • (9) Based on the rule of paragraph 2-1 of the name of ingredients in the table of article 3, paragraph 1 of the Food Labeling Standard, which ingredients require to have their country of origin displayed when the same kind of ingredients are summarized as one (such as "vegetables (○○, △△)")
  • (10) Based on the rule of paragraph 2-1 of the name of ingredients in the table of article 3, paragraph 1 of the Food Labeling Standard, when the same kind of ingredients are summarized as one and all the (for instance) vegetables are produced in Japan, how should the COOL be?
  • (11) Based on the rule of paragraph 2-2 of the name of ingredients in the table of article 3, in the case several processed foods are packaged separately and they compose one product, and the ingredients of those processed foods are noted separately, which ingredients are subject to COOL?
  • (12) Based on the rule of paragraph 3 of the name of ingredients in the table of article 3, paragraph 1 of the Food Labeling Standard which ingredient"s country of origin should be considered when some ingredients are noted as one category such as "vegetable oil" or "starch"?
  • (13) Based on the rule of paragraph 3 of the name of ingredients in the table of article 3, paragraph 1 of the Food Labeling Standard, when some ingredients are noted as one category such as "fish meat", how should we set the COOL out?
  • (14) When there are more than one ingredient being the most predominant by weight, which ingredient is subject to COOL?
II Method of labeling
  • (15) Where should we note the country of origin for ingredients?
  • (17) When ingredients from several different countries are mixed, how should we note them?
  • (18) When allergen labeling or genetic modification labeling is also used in the ingredients list, is there an order of priority among COOL, allergen labeling and genetic modification labeling?
  • (19) About COOL: Is it possible to note an origin by other than a name of a country?
  • (20) About COOL: Is it possible to note a country name by its abbreviation? For instance, is it also fine to note 米国 (United States of America) as USA or US?
  • (21) About COOL: Is it possible to label an origin using a symbol that represents a country?
  • (22) Regarding the most predominant ingredient by weight, we are making claims about a specific country of origin and its ratio of its use on the label, but is it also necessary to note the country of origin in the ingredients list?
  • (23) When a country of origin for an ingredient is noted in the ingredients list (mandatory labeling item), is it necessary also to note the ratio of its use following the rule of article 7 of the Food Labeling Standard?
  • (24) When we would like to (on a voluntary basis) note a country of origin for the 5th most predominant ingredient by weight beside the most predominant ingredient subject to COOL, but is it fine not to note countries of origin for the 2nd, 3rd and 4th predominant ingredients?
  • (25) When there is just one kind of ingredients and the name of ingredients are omitted, how should we note?
III "Or Labeling" (*The former name of this item was "Listing of Possible Suppliers")
  • (28) Can "Or Labeling" be used for labeling by prefecture of origin?
  • (30) When ingredients from several countries are added to a tank to make a product, an ingredient from one of the countries will never be zero mathematically but how should we note it?
IV "All Inclusive Labeling"
  • (33) Regarding All Inclusive Labeling, are labels of classification such as "made in EU" and "made in South America" (i.e. more precise than "import") allowed?
V "All Inclusive Labeling" + "Or Labeling"

No question item was added (only organization of contents of the answers was changed).

VI Purchasing record, etc.
  • (40) When "Or Labeling" or "All Inclusive Labeling" is used, by what unit can a list of past purchasing record by country of origin for a certain period of time, or a future purchasing plan by country of origin for a certain period of time be registered?
VII "Processing country labeling for semi-processed ingredients"
  • (41) Please tell us how to label when an ingredient subject to COOL is a semi-processed ingredient.
  • (42) Please tell us how to decide a processing country for a semi-processed ingredients.
  • (44) As for semi-processed ingredients which went through several production processes, which country's process should be noted?
  • (45) When a semi-processed ingredient subject to COOL is a compound ingredient and the "Processing country labeling of semi-processed ingredients" is not used but instead the country of origin for the perishable raw ingredient is noted, which ingredient (among the ingredients of the compound ingredient) needs to have its country of origin noted?
  • (46) Regarding a semi-processed ingredient which was processed in a company's own factory in Japan, which country’s process should be noted?
VIII Professional use

No question item was added (only organization of contents of the answers was changed).

IX Others
  • (56) About processed foods listed in the appended table 15-1 to 5 (so called "22 food categories + 4 types"), can "Or Labeling", " All Inclusive Labeling" or "Processing country labeling of semi-processed ingredients" be used?
  • (57) As for processed foods included among the so called 22 food categories (processed foods listed in the appended table 15-1), but for which there is no perishable food whose proportion is more than 50% of the total ingredients, how should we note the COOL?
  • (61) How should we deal with a sudden change of ingredients supply caused by a natural disaster or bad harvest/penuries?
  • (63) Will products which were being processed in a production or processing facility when the new COOL system started and will be completed after the transition period be subject to it?

If you have seen the new Q&A released on September 1, but do not know where to get/search for the new information, you may want to check the items listed above.

References:
Guidelines concerning the new COOL system for ingredients (supplementary material)
http://search.e-gov.go.jp/servlet/PcmFileDownload?seqNo=0000156620
Food Labeling Standard Q&A Appendix New COOL System for Ingredients
http://www.caa.go.jp/foods/pdf/foods_index_18_170901_0014.pdf

Nobember 2017