Food Label Inspection in Japan

Label bank_Professional Food Labeling in Japan

Discussions on the labeling system for genetically modified food 4

~Currently discussed major points of amendment and summary of the current system~

The 8th and 9th “discussions on the labeling system for genetically modified food” (Consumer Affairs Agency) were held respectively on January 31, 2018 and February 16, 2018. The preliminary draft of the “report on the discussion on the labeling system for genetically modified food (preliminary draft)” was studied during the 9th session.

While we assumed that there would be no important changes before the discussion, there actually was a modification of the standard for “non-GM” labeling. Thus, following last month’s newsletter content it will again be our main topic this time. Beside, we will also provide a quick summary of the outline of the current system.

Major points of amendment


According to the preliminary draft of the “report on the discussion on the labeling system for genetically modified food”, we summarized the current state of the discussions as follows:

  • Scope of the mandatory labeling

    1. Discussions on food items subject to mandatory labeling
    ⇒ (Conclusion) Maintain the current system (8 crops 33 items)

    2. Discussions on the scope of ingredients subject to mandatory labeling
    ⇒ (Conclusion) Maintain the current system (limit to main ingredients (the ones which are the three most predominant by weight and whose proportion is more than 5%))

  • Labeling method

    1. Method of labeling for non-segregated GM
    ⇒ (Conclusion) Labeling expressions that are easier to understand than “non-segregated GM” will be exemplified in the Q&A

    2. Method of labeling for "non-GM"
    ⇒ (Conclusion) The percentage (of unintentional GM presence in potato and corn) will be lowered from the current“5% or less” to “0% (below detection limit).”(However, regarding foods that might no longer be labeled as “non-GM” after lowering the standard, the use of a voluntary labeling showing that these foods were treated under a proper identity preserved handling system shall not be precluded)

Following these amendments, it seems likely that most of the products currently labeled as “non-GM” will instead be labeled as “treated under a proper identity preserved handling system”.

About the current system


It is necessary to have a good understanding of the current labeling system for genetically modified food to perceive the nuances of the abovementioned changes. Therefore, we would like to summarize the present regulations here. First of all, food items subject to mandatory labeling are listed on the two appended tables below.

The 17th appended table for the food labeling standards (8 crops in the left column and 33 food groups in the right column

Targeted agricultural products Processed foods
Soybeans (including green soybeans and bean sprouts) ① Tofu (soybean curd) and aburaage (fried soybean curd)
② Kori-dofu (frozen bean curd), okara (soybeans pulp) and yuba (dried bean curd)
③ Natto (fermented soybeans)
④ Soy milks
⑤ Miso (fermented soybean paste)
⑥ Boiled soybeans
⑦ Canned and bottled soybeans
⑧ Soybean flour
⑨ Roasted soybeans
⑩ Food made mainly from ingredients listed in items ① to ⑨
⑪ Food made mainly from soybeans for cooking
⑫ Food made mainly from soybean flour
⑬ Food made mainly from soybean protein
⑭ Food made mainly from green soybeans
⑮ Food made mainly from soybean sprouts
Corn ① Corn snacks
② Corn starch
③ Popcorn
④ Frozen corn
⑤ Canned and bottled corns
⑥ Food made mainly from corn flour
⑦ Food made mainly from corn grits (excluding corn flakes)
⑧ Food made mainly from corns for cooking
⑨ Food made mainly from ingredients listed in items ① to ⑤
Potato ① Potato snacks
② Dried potatoes
③ Frozen potatoes
④ Potato starch
⑤ Food made mainly from potatoes for cooking
⑥ Food made mainly from ingredients listed in items ① to ④
Rapeseed  
Cottonseed  
Alfalfa Food made mainly from alfalfa
Sugar beet Food made mainly from sugar beets for cooking
Papaya Food made mainly from papayas

Food Labeling Standards: 18th appended table

Characteristic Processed food Targeted agricultural products
High oleic acid

1 Food made mainly from soybeans (except ones which do not have characteristics listed previously in the 17th appended table after being defatted)

2 Food made mainly from an ingredient listed in 1
Soybean
Stearidonic acid production
High lysine

1 Food made mainly from corns (except ones which do not have characteristics listed in the above tables (corn))

2 Food made mainly from an ingredient listed in 1
Corn

Let’s sum up the difference between mandatory and voluntary labeling:
When the GM agricultural product is not a main ingredient (I.e. one of the three most predominant by weight, and its proportion is at least 5%), the labeling is not mandatory. Regarding the amendments in the preliminary draft of the “report on the discussion on the labeling system for genetically modified food (preliminary draft)”, the two points underlined below will be subject to them.

Mandatory and voluntary labeling of GM foods

“Is the composition and nutritional value equal to the current one?”
→ Yes, it is equal
→”The ingredient is GM and segregated ” ... Mandatory labeling
Example of labeling: soybean (GM), etc.
→”GM and not segregated” ... Mandatory labeling
Example of labeling: soybean (GM not segregated), etc.
→”The ingredient is non-GM and segregated” “DNA and protein are not detectable” ... Voluntary labeling
Example of labeling: soybean or soybean (non-GM)

→No, it is not equal
... Mandatory labeling

Example of labeling: soybean (high oleic acid GM) etc.

As you can see, in the current system, “non-GM” labeling is allowed if the product was treated under proper identity preserved handling and even when there is certain “unintentional GM presence” (5% or less for soybeans and corns). (But after the amendment, this percentage is planned to be lowered from “5% or less” to “0% (below detectable limit)”.

Future schedule


Based on this preliminary draft of the “report on the discussion on the labeling system for genetically modified food”, the discussions around GMO labeling were planned to be finalized by the end of this fiscal year (end of March, 2018) . We are convinced that this will provide an opportunity to consider the preparation for necessary changes to come in the labeling review workflow, in accordance with the expected points of amendment.

Reference: “Report on the discussion on the labeling system for genetically modified food (preliminary draft)”

March 2018