Monthly Archives: August 2022

The move from recommended to mandatory allergen labeling for “walnuts” (Part 2) (Japan) ~Report on the national fact-finding survey of health damage caused by immediate-type food allergy in 2021~

At the 67th Consumer Commission Food Labeling Section Meeting held on June 6, 2022, the prospect of the mandatory allergen labeling of “walnuts” was announced. I would also like to take up the “Report on the national fact-finding survey of health damage caused by immediate-type food allergy in 2021”, which was the background of the announcement.

Main Points

  • According to the survey (2020), nuts have become one of the three major foods causing allergies, surpassing wheat
  • Among nuts, allergens caused by walnuts have increased significantly, followed by cashew nuts
  • The revision bill to make walnuts subject to mandatory labeling is expected to be consulted by the end of this fiscal year

Background to date

It was at the 56th Consumer Commission Food Labeling Section Meeting held on July 5, 2019, that the Consumer Affairs Agency (CAA) announced its policy of “designating walnuts as products subject to mandatory labeling.” The background is that the number of cases caused by almonds and walnuts increased compared with the previous two surveys in the report compiling the results of the survey at that time (“Report on the national fact-finding survey of health damage caused by immediate-type food allergy in 2018”).

Subsequently, almonds were added to the list of items for recommended allergen labeling in September 2019. As for walnuts, the issues to be considered were organized as follows, -need to confirm whether or not the number of cases is not just temporary
-when designating an item as subject to mandatory labeling, test methods need to be developed and validated from the perspective of ensuring the implementation.

In addition, the “Advisors’ Meeting on Food Allergen” which started in February 2021, proceeded with preparations and discussions, including surveys.

Based on the results of the survey, a concrete target (aiming for consultation by the end of this fiscal year) was set regarding the timing of the transition of walnuts to a mandatory labeling item.

About this survey

The following is an excerpt from the 67th Food Labeling Section Meeting material, “Regarding labeling of foods containing allergens”, which provides an overview of the survey.

Method of the surveys

  • The subjects of the survey were “Patients who had any reaction within 60 minutes of food ingestion and visited a medical institution” except the cases in which symptoms were induced by food oral load testing or oral immunotherapy (OIT).
  • The survey period was from January to December 2020, and postcards were mailed every three months. Reports were received by postcard or by email when requested.

Subject of the survey

6,080 cases were analyzed after excluding 414 cases with unidentified causative substances, 83 cases with causative substances other than food (70 cases of Anisakis, 13 cases of mite), and 100 cases with unclear age, gender, treatment/outcome, first-time cases of allergy/ erroneous food intake, and OIT out of a total of 6,677 cases.

Causative food

Chicken eggs 2,028 cases (33.4%), cow milk 1,131 cases (18.6%), and nuts 819 cases (13.5%). Until the previous survey, the top three causative foods were chicken eggs, cow milk, and wheat, but in this survey, the proportion of nuts increased to third place (from 8.2% in the previous survey to fourth place). Among the nuts, walnuts were the largest number (463 cases), followed by cashew nuts (174 cases) and macadamia nuts (45 cases).

Chart 2: Proportion of causative foods
Type n % of total
Walnuts 463 7.6%
Cashew nuts 174 2.9%
Macadamia nuts 45 0.7%
Almonds 34 0.6%
Pistachios 22 0.4%
Pecan nuts 19 0.3%
Hazelnuts 17 0.3%
Coconuts 8 0.1%
Cacao 1 0.0%
Chestnuts 1 0.0%
Pine nuts 1 0.0%
Mixed nuts/category unknown 34 0.6%
Total 819

Table1: Breakdown of tree nuts

Shock symptoms

Until the previous survey, the top three causative foods causing shock symptoms were chicken eggs, cow milk, and wheat, but in this survey, the proportion of nuts increased to third place (from 12.8% in the previous survey, the fourth place). As the breakdown of the nuts, walnuts were the most common at 58 examples, ranking higher than peanuts (46 cases) alone. Cashew nuts followed with 30 cases.

Chart 3: Causative foods causing shock symptoms
Typen% of total
Walnuts 58 8.8%
Cashew nuts 30 4.5%
Almonds 7 1.1%
Pistachios 6 0.9%
Macadamia nuts 5 0.8%
Pecan nuts 3 0.5%
Mixed nuts/category unknown 6 0.9%
Total 115

Table3: Breakdown of tree nuts causing shock symptoms

Discussion and Conclusion

Similarly, “Regarding labeling of foods containing allergens” from the 67th Food Labeling Section Meeting material provides the summary of the discussion and conclusions as follows.

Chart 4: Change in the proportion of cases of top causative foods

Looking at the increasing trend of nuts since 2005, while chicken eggs, cow milk, and wheat, which are high-ranking items, have remained almost unchanged, nuts have increased since 2014.

Chart 5: Change in the proportion of cases of tree nuts
(Only tree nuts with more than 0.5% extracted in the 2020 survey)

Looking at the breakdown of nuts, the increase of cases by walnuts is remarkable.

  1. The number of survey cases this time was 6,080, keeping an increasing trend from the previous survey (4,851 cases).
  2. Until the previous survey(2017), the top three causative foods were chicken eggs, cow milk, and wheat, but in this survey, the proportion of nuts increased to third place surpassing wheat.
  3. Among nuts, allergens caused by walnuts have increased significantly, followed by cashew nuts.
  4. In terms of causative foods for first-time cases of allergy reaction onset, chicken eggs, cow milk, and wheat were the most common in the 0-year-old group, while tree nuts were among the top three in the infant and school-age groups.
  5. The increase in tree nuts as causative foods for immediate-type food allergy is not a temporary phenomenon.

Based on the above, as the conclusion of “-need to confirm whether or not the number of cases is just not temporary” for walnuts, walnuts will be added to the list of specified ingredients for mandatory labeling because they are considered to be “significantly increasing and not a temporary phenomenon”.

Future schedules

CAA plans to consult with the Consumer Commission on the revision of Food Labeling Standards, by the end of this fiscal year at the latest. In addition, with regard to “Development and validation of test methods”, which had been previously considered as an issue to be considered, development is currently underway with aiming of its completion in the next fiscal year. Therefore, it can be assumed that Food Labeling Standards will be revised by the end of March 2023, and walnuts will be changed to items subject to mandatory allergen labeling.

In the meantime, I would like to recommend those who are involved in food labeling read this report of investigation results. In addition to walnuts, the increase in cashews can also be reconfirmed, as well as the proportion of first-time cases of allergy and erroneous food intake, and the proportion of cases of food labeling errors among erroneous food intake. We hope that it will be utilized for future confirmation work.

References

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Labeling of place of origin for seafood products (especially shellfish) (Japan)

Food Labeling Standards Q&A was revised on June 15, 2022, and “The guidelines for the legal product names of seafood” was revised. The revision was made in response to changes in the situation surrounding names of seafood, such as the expansion of the import and distribution of new fish species and the change of names due to the development of taxonomic research. Among seafoods, the revision was made for fish in 2020, but this time it is for crustaceans.

In addition, the March 30, 2022 revision included a new Q&A and accompanying revisions to the labeling of place of origin of seafood products (especially shellfish), which we will take up here. This article will focus on shellfish (mainly short-neck clams), and we hope that it will provide you with an opportunity to learn about the regulations for seafood products, which differ from those for agricultural products and livestock products in terms of place of origin.

Background of the revision

Food Labeling Standards Q&A (Fresh – 27) summarizes the current labeling method and concept of places of origin labeling for seafood products (especially shellfish), as well as the history of the revision leading to it. We will mainly explain the background.

1 The place of origin of fresh foods is, in principle, the place where agricultural, livestock and seafood products are produced (including harvested and caught). However, for farmed seafood products, the basic concept of place of origin labeling is that if the product was raised in multiple locations, the location with the longest growing period must be labeled as the place of origin.
2-3 (omitted)
4 This concept has been taken over since JAS Act prior to the revision by Food Labeling Act. However, in April 2005, inappropriate cases such as mislabeling of the place of origin of short-neck clams among shellfish, in particular, were confirmed. In the case where the period of growth before harvesting in a foreign country is clearly longer than the period of growth in Japan, even if imported short-neck clams are stocked in Japan for two or three months, it has been kept informed that they must be properly labeled according to the basic concept of origin labeling, the country of origin must be indicated as the country where the product was harvested before import.
5 In addition, in March 2010, the government published the “Q&A on Food Labeling,” which is the predecessor of Food Labeling Standards Q&A, stating that in the case of importing young short-neck clams or transplanting ones from other area in Japan to propagate and then harvesting the adult short-neck clams, the place of origin with the longest stocking period for the clams must be indicated and it is necessary to be able to prove that the clams have been stocked at that location for a long period of time.
6 However, it is difficult to accurately grasp the growth period of imported short-neck clams by their external appearance. Furthermore, a number of cases were identified in which the origin was labeled as the domestic place (Japan) of origin, based on the provided untruthful certifications stating that the domestic growing period (in Japan) was longer than the overseas growing period.
7 Therefore, in March 2022, in order to promote proper understanding of the concept of origin labeling, the following regulations were introduced
① The term “stocking” is defined as the short-term storage of aquatic animals and plants in a certain location for shipment adjustment and other purposes, and the period of “stocking” is not included in the overall growing period of shellfish.
② The country of origin of imported short-neck clams is an exporting country of the clams regardless of presence or absence of their stocking periods. As an exception, if imported young short-neck clams are raised (farmed) for more than one and a half years (*) based on a demarcated fishing right and the documentation related to cultivation, etc. is preserved, the domestic raised site (in Japan) can be indicated as the place of origin.
(*)This period is set based on the assumption that it takes approximately three years to harvest them. This is because it is difficult to confirm the growth period of imported short-neck clams.
③ When introducing young short-neck clams from other areas of Japan, indication is needed that it is necessary to preserve supporting documents of such young short-neck clams in order to distinguish them from imported adult short-neck clams to be released. Food Labeling Standards Q&A, was revised for the above three points.

Documents with evidence

(Fresh – 27) As mentioned in 7②, documents with evidence (documents that can explain the basis for labeling at the request of administrative bodies, etc.) that must be preserved when young short-neck clams are raised for more than one year and a half based on a demarcated fishing right and labeled as originating from a domestic raised site (in Japan), is described in (Fresh – 34) 3.

3 As for documents importers and domestic (Japanese) manufacturers preserve
① As documents with evidence for imported short-neck clams
(a) Documents related to customs clearance of imported short-neck clams (notice of import permission, CERTIFICATE OF ORIGIN and other documents related to customs clearance)
(b) In the case of subdividing imported young short-neck clams into small packages, a document to match the short-neck clams actually introduced into the fishing ground with the certificate of customs clearance (number management shall be controlled on a lot basis, and even after subdividing, it is necessary to take measures such as assigning numbers to the clams after subdividing).
In addition to the above
② As documents with evidence for domestic (Japan) raising :
(a) Documents that can confirm the use of fishing grounds in the area licensed for demarcated fishing rights (e.g., fishing ground map, farming zone map, farming zone numbers, area, etc.)
(b) Detailed statement of carrying in/out of young short-neck clams (documents submitted to customs : records of carrying in/out of each farming zone)
(c) Records of the date and quantity of short-neck clams introduced into the fishing ground for each farming zone
(d) Records of the harvesting date and quantity of short-neck clams from the fishing ground for each farming zone
(e) Certificate of registration of the demarcated fishery right (If the fishery cooperative has obtained a license of the demarcated fishery right, it is necessary to confirm separately whether the person who raises the fish can exercise the demarcated fishery right.)And so on.

In addition, please refer to (Fresh -35) for documents with evidence of young short-neck clams in (Fresh-27) 7 (3).

This revision related to “The guidelines for the legal product names of seafood” and the concept of place of origin of seafood products would be helpful not only for those who handle fresh seafoods, but anyone who uses seafoods as ingredients in their products.

References

Newsletter Signup

We issue monthly e-newsletters, which provide you with the latest updates on food labeling/regulations in Japan.
If you want to make sure to not miss any issue, please click below.

Related Service

Research Services on Ingredients & Food Labeling -For the Japanese Market-
We verify the conformity of ingredients and additives with the standards for use in Japan based on specifications such as formulation lists. We also verify the conformity of the proposed labeling of ingredient names, nutrients, etc. with the labeling standards based on specifications such as formulation lists.