Food Label Inspection in Japan

Label bank_Professional Food Labeling in Japan

Discussions on the labeling system for genetically modified food 5

~"Non-GM" labeling requirements and mentions showing that foods were treated under proper identity preserved handling~

Once more, we would like to feature the labeling system for genetically modified foods in our monthly publication. The 10th "discussion on the labeling system for genetically modified food" was held on March 14, 2018. Then the preliminary draft of the report on the discussion on the labeling system for genetically modified food as well as "examples of voluntary mentions for ingredients treated under proper identity preserved handling when it is actually performed" were discussed.

Therefore, we will summarize the changes on the "requirements allowing 'non-GM' labeling", and provide specific examples of "labeling which shows that foods were treated under proper identity preserved handling."

Outline of the current system and points to be changed


  • Alternative labeling expressions for "GM not segregated" will be discussed and examples will be shown in Q&A.
  • The requirements for non-GM labeling will be lowered from its current state (i.e. "unintentional GM presence of soybeans and corn equal or lower than 5%") to "undetectable. When it is 5% or less, the voluntary labeling to show that foods were treated under proper identity preserved handling will be allowed.

Requirements to allow "non-GM" labeling


In the current system, if the requirement stated in the lower left column (that is 5% or less of unintentional GM presence (soybeans and corn)) applies , the voluntary labeling of "non-GM" is allowed.

On the other hand, in the new system, if the requirement stated in the lower right column (as for soybeans and corn, unintentional GM presence is "equal or less than α%") applies , the voluntary labeling of "non-GM" will be allowed.

Reference: “Examples of voluntary labeling for ingredients that are actually treated under proper identity preserved handling” (Consumer Affairs Agency(CAA))

However, when the requirement stated in the right middle column applies (percentage of unintentional GM presence is "between 5% and α% (0%)"), it is now allowed to label it as "treated under identity preserved handling."

That said and in both systems, when the percentage of unintentional GM presence is over 5%, it is considered that foods were not treated under identity preserved handling and it shall be labeled as "GM not segregated."Even though there are actually few products with labeling like this, we can the notice in the Q&A to be released soon that it has been changed to an alternative labeling: "GM not segregated.

Examples of labeling to show foods are treated under proper identity preserved handling


Examples of voluntary labeling for ingredients that are actually treated under proper identity preserved handling are written, so we quote them as follows.

[Expected examples]
*Examples of labeling in case when the (unintentional GM) presence (of soybeans, corn) is 5% or less

(1) In case of voluntary labeling outside of the mandatory frame

  • "Using corn treated under identity preserved handling to prevent GM ingredient presence."
  • "Using soybeans treated under identity preserved handling, but GM ingredients might remain."
  • "To ensure that the unintentional presence of GM soybeans is as low as possible, ingredients are properly managed in each process of producing, distributing and processing."
  • The purchase of ingredients and production process of this product are managed in a way to prevent the presence of GM soybeans as efficiently as possible.
  • By treating soybeans under identity preserved handling, the GM presence in this product is reduced as much as possible.

(2) When labeled collectively in the ingredients lists

  • Ingredients treated under identity preserved handling to prevent GM presence
  • Identity preserved handling to prevent GM presence
  • Managed to prevent GM presence

Future of the "non-GM" labeling


It is safe to say that the handling of non-GM labeling is the single most important change in the new system. Although the report is mainly about "maintaining the current system", the present "non-GM" (but potentially "up to 5% unintentional presence") labeling system could mislead consumers. Therefore, the condition will be changed to "undetectable (0%)."

In case it's actually undetectable (0%), it will be allowed to be labeled as "non-GM", yet concerns that there will only be very few products that might still be labeled as non-GM have been raised, and it is expected that many products labeling will be changed to "to show that identity preserved handling is properly done."

Also since the system will likely be promoted, it is possible that inquiries related to the "identity preserved handling" system will increase. What this means for people in charge of products labeling, is that it will be important to read through the report on the discussion (preliminary draft) and once again review the GM labeling system/identity preserved handling before establishing a system that will help to deal properly with future inquiries from all quarters.

Reference: Discussions on the labeling system for genetically modified food (CAA)

May 2018