Author Archives: Hiroyuki Kawai

About Hiroyuki Kawai

Label bank Co., Ltd. CEO (Founder) Born in Japan. Working on solving various issues related to food labeling operations. Also regularly gives lectures for various organizations in Japan. Co-author of 'Latest edition: Guide book Food Labeling Law and related business practical points - from scratch (Japanese version only)' (DAI-ICHI HOKI CO., LTD/2019).

New Mandatory Warning Label Requirements in Texas and Louisiana, USA

On June 22, 2025, in the state of Texas, USA, Senate Bill 25, which requires warning labels for certain food additives, was passed.

Food products containing ingredients such as artificial color, titanium dioxide, and partially hydrogenated oil will therefore be required to label a warning stating:

“WARNING: This product contains an ingredient that is not recommended for human consumption by the appropriate authority in Australia, Canada, the European Union, or the United Kingdom.”

The new Texas Act targets 44 ingredients, including artificial colors such as Red 3 (CAS 16423‑68‑0) and other color additives approved by the Food and Drug Administration (FDA). It is expected to significantly impact a broad range of food products. The Act will take effect in September 2025 and will apply to products developed on or after January 1, 2027.

Meanwhile on June 27, 2025, in the state of Louisiana, USA, Senate Bill 14, which similarly requires foods to add warning labels for certain food additives was also passed.

Food products containing targeted ingredients will be required to bear a warning label with a QR code linking to a website that states:

“NOTICE: This product contains [insert ingredient name here]. For more information about this ingredient, including FDA approvals, click HERE.”

The list of 44 targeted ingredients largely overlaps with those in the Texas Act. A notable difference, however, is the inclusion of artificial sweeteners such as aspartame, sucralose, and acesulfame potassium. The Act is scheduled to take effect on January 1, 2028.

When exporting food products to the United States, it is essential to pay attention not only to federal labeling regulations (21 CFR) but also to state-level regulations.

For an already existing example, under California’s Proposition 65, products containing designated chemicals are required to carry warning labels stating such as,

“This product can expose you to chemicals including [name of one or more chemicals], which is [are] known to the State of California to cause cancer, and [name of one or more chemicals], which is [are] known to the State of California to cause birth defects or other reproductive harm. For more information go to www.P65Warnings.ca.gov.”

The law specifies a list of chemicals and threshold levels, including arsenic, lead, mercury, acrylamide, and sulfur dioxide. Although it is a state law, Proposition 65 is widely recognized in practice as a critical regulatory requirement for exporting food products to the U.S.

While these state Acts/laws are labeling standards requiring warnings on food products containing certain ingredients, these laws effectively serve as standards that must be taken into account during the ingredient and additive formulation stage for food businesses.

As such, food businesses are expected to be required to review the list of targeted ingredients outlined in the new regulations in Texas and Louisiana, and assess which ingredients are used in their products and whether any of the listed ingredients are present.

In addition, similar bills requiring warning labels on foods containing certain ingredients are currently under discussion in several other U.S. states. Therefore, it is important for food businesses not only to monitor these developments but also to stay informed about future changes to federal regulations.

It is also advisable to check such new rules that include federal preemption clauses in the cases where:

– a federal law or regulation prohibits the use of the ingredient, imposes conditions on the use of the ingredient such as warning labels, or determines an ingredient or class safe for human consumption (Texas)

– the federal government issues an action that is ‘at least equivalent or more restrictive’ than the requirements in the state law (Louisiana)

As the scope expands beyond packaged foods to include food service establishments and school meals, even more regulatory standards come into play. Therefore, when exporting food products, careful attention should be paid to state-level regulations and other applicable standards.

In particular, confirming in advance whether any ingredients or additives may require special attention, especially during the planning stage of their use, can help avoid compliance issues later down the line.

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Proposed amendments to prohibited claims for FFC, and Review of labelling rules for individual food items originating from former Food Sanitation Act (Japan)

On June 13, 2025, the Consumer Affairs Agency (CAA) announced the launch of a public comment period on the Cabinet Office Ordinance (Draft) to partially amend the Food Labelling Standards (Japanese).

For Foods with Functional Claims (FFC)*, the use of wording that highlight ingredients other than functional ingredients (with some exceptions) is prohibited.

The proposed amendments (Articles 9 and 23) are planned to revise this rule to permit certain indications such as those stating the absence or non-addition of specific ingredients. (e.g. “no XX added“ or “does not contain XX”). However, claims that emphasize the presence of ingredients other than the notified functional ingredients (excluding nutrients listed in Column 1 of the Appended table 9) will remain prohibited.

* The FFC system is a notification-based system in which business operators submit information to the Commissioner of the CAA, including scientific evidence supporting the product’s safety and claimed functionality.

Prohibited Labelling Items under review

Before the amendmentExcept in cases where labelling is permitted under Article 7, such as claims on nutrient supplementation or claims on the appropriate intake of nutrients/calories, wording for claims on ingredients other than the functional ingredients notified to the Commissioner of the CAA (including nutrients listed in Column 1 of Appended table 9)
After the amendmentWording for claims on the presence of ingredients other than the functional ingredients notified to the Commissioner of the CAA (excluding nutrients listed in Column 1 of Appended table 9)

With the amendment, it is expected that FFC will also be allowed to label claims on ingredients with no established criteria for appropriate intake, in the same way as general foods. Note: The public comment period closed on July 14.

On June 25, the CAA released a document titled Review of labelling rules for individual food items originating from the former Food Sanitation Act (related to Appended table 19 and 20 of the Food Labelling Standards) (Japanese) as a material for the 1st Fiscal 2025 Food Labelling Discussion Meeting (Japanese).

Labelling requirements stipulated in Appended table 19 and 20 are mainly based on Specifications and Standards for Foods, Food Additives, etc., which are derived from the former Food Sanitation Act. The labelling requirements are scheduled to be reviewed, together with the rules for individual food items derived from the former JAS Act, by the Subcommittee for the Review of Labelling Rules for Individual Food Items.

Examples from Appended Table 19 (excerpt)

FoodLabelling ItemLabelling method
Meat productspH and water activityIndicate the value with symbols such as “pH” for hydrogen ion exponent
Indicate the value with symbols representing water activity
Frozen foodsWhether or not the product was heated just before freezingIndicate whether the product was heated immediately before freezing (e.g. “Heated before freezing”)

The food items subject to review include a wide range of products such as meat products, milk, dairy products, foods made primarily from milk or dairy products, frozen foods, packaged foods sterilized by heat under pressure, and canned foods. For details, please refer to the materials. It should be noted that fresh foods are excluded from the scope of the review.

After consideration of the proposed amendments, the revised rules are expected to take effect concurrently with the rules for individual food items derived from the former JAS Act. The implementation schedule, including the Japanese version of the Front-of-Pack Nutrition Labelling (FOPNL) guidelines, is outlined in the material Future Proceedings (Japanese), so it is recommended to check it as well.

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Trends in Amendments to Food Labelling Regulations in Various Countries

In 2025, major amendments to food labelling standards were implemented in Singapore and China. I would like to take a broader look at the latest trends in regulatory changes across various countries around the world.

The U.S.

On April 7, 2025, the U.S. Alcohol and Tobacco Tax and Trade Bureau (TTB) announced an extension of the public comment period for its proposed amendments to labelling standards for alcoholic beverages.

The proposed amendments involve the mandatory labelling of alcohol information (alcohol content per serving, calorie, and nutrient content) and allergen information on alcohol beverages.

On April 18, the U.S. Food Safety and Inspection Service (FSIS) announced it will update allergen related programs and documents in response to the Food and Drug Administration’s (FDA) recently updated Guidance for Industry (Questions and Answers Regarding Food Allergen Labelling (Edition 5) January 2025). The updates include removing coconut from the list of “tree nuts” that must follow food allergen labelling requirements.

Additionally, FDA announced it would extend the comment period for the proposed rule on a front-of-package (FOP) nutrition labelling scheme.

South Korea

On April 21, 2025, the Ministry of Food and Drug Safety (MFDS) announced a partial amendment to the Food Labelling Standards.

The main points are as follows:

-If export products, initially labelled in a foreign language, cannot be exported for various reasons but comply with Korea’s domestic food standards, Korean labelling using stickers or other methods might be permitted only in specific cases, such as when they are not intended for direct consumer sales in Korea).

– Expansion of mandatory nutrition labelling Additionally, public comments were sought for the proposed amendment to the Enforcement Rule of the Act on Labelling and Advertising of Food, etc. from January to February 2025. The primary focus of this amendment proposal is on digital labelling (ingredient names, product report numbers).

Thailand

On March 7, 2025, the Thai Food and Drug Administration (Thai FDA) called for public comments on the Draft Regulation on Nutrition Labelling.

The draft includes amendments to certain nutrition labelling requirements and standards for labelling energy, sugar, fat, and sodium in the GDA (Guideline Daily Amount) format. The proposed amendments primarily aim to ease the strict requirements regarding the “colors” to be used for GDA labellings (such as text color and background color).

On May 6, 2025, the Thai FDA also issued two notifications (Ministry of Public Health Notification No. 456 and No. 457) that abolished seven individual labelling standards including for brown rice flour and jelly, and prohibited the manufacture, import, and distribution of certain foods such as konjac mini cup jelly and similar products.

Australia

On April 7, 2025, Food Standards Australia New Zealand (FSANZ) announced the approval of the following three amendments to the Australia New Zealand Food Standards Code. (1. Cultured Quail as a Novel Food 2. Carbohydrate and sugar claims on alcoholic beverages 3. Energy labelling on alcoholic beverages)

In Singapore, the new requirements for gluten-free labelling were introduced to Food Regulations (see our past article). Other changes have also been made, including amendments to the rules on the labelling of ingredient names (Regulation 5, Paragraph 4).

Regarding China’s GB7718-2025 and GB28050-2025 (see our past article), many amendments have been introduced, such as the mandatory labelling of allergens, the addition of ingredients to the mandatory nutrients content labelling, and the prohibition of the use of certain terms such as “不添加(En: not added)”, “不使用(En: not used)”and their synonyms.

As a conclusion, we would like to remind you that it is advisable to stay informed about the regulatory changes in these countries, as well as the amendment trends in Japan’s Food Labelling Standards (see our past articles here and here).

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(China) General Principles for the Labelling of Prepackaged Foods Revised

On March 27, 2025, China’s National Health Commission (NHC) and the State Administration for Market Regulation (SAMR) jointly released the General Principles for the Labelling of Prepackaged Foods (GB 7718-2025)*. On the same day, the General Rules for Nutrition Labelling of Prepackaged Foods (GB 28050-2025)* were released.

Both regulations will come into effect on March 16, 2027. Given the comprehensive nature of these Chinese regulations and the substantial revisions they entail, I would like to provide a summary here.

*Chinese versions of GB 7718-2025 and GB 28050-2025 can be found at the Ministry of Agriculture, Forestry and Fisheries page.

Main revisions

<GB 7718-2025>

  • The required date labelling was changed from “date of manufacture and shelf life period” to “date of manufacture and shelf-life expiration date (the end of the shelf life period)”, which must be clearly stated in the order of year, month, and day.
    The shelf-life expiration period that exempts the indication of the date of manufacture was changed from one year to six months.
  • Allergen information was changed from recommended to mandatory labelling.
    Allergens shall be labelled in the list of ingredients, or warning information close to the list of ingredients. When listed in the ingredient list, the relevant ingredient names must be highlighted in bold or underlined.
  • The requirements for labelling common names alongside the functional class names of food additives were revised.
    For packages with a maximum surface area of 60 cm² or less, the INS Number can be used instead of common names for food additives.
  • Labelling requirements for digital labels were added.
    Information required to be displayed on pre-packaged foods can be presented through digital labels, and packaging label information can be simplified in accordance with relevant laws and regulations.
  • When emphasizing the presence, high content, absence, or low content of one or more ingredients or components, quantitative indication is required.
    Quantitative indication must include specific numbers or percentages, using symbols or terms that express minimum values (such as “≥” or “not less than”) or maximum values (such as “≤” or “not higher than”).
  • Where wordings such as “无 (En: free)” and “不含 (En: does not contain)” are used, the content of the corresponding ingredients or components shall be “0”.
    It is not allowed to use words such as “不添加(En: not added)”, “不使用(En: not used)”, and their synonyms (e.g.零添加(En: zero added/zero〇〇), 没用(En: unused/〇〇less), 未用(En: not in use)).

<GB 28050-2025>

  • Expansion of the mandatory nutrients content labelling to include sugars and saturated fat (acid)
  • Requirements on adding a caution/warning message “children and adolescents should avoid excessive intake of salt, oil, and sugar”.
  • Addition of ingredients for the Nutrition Facts label and revision of Nutrient Reference Values (NRVs) for nutrients

In addition:

  1. Revisions were made to include new labelling requirements for items such as bacterial strains.
  2. Labelling requirements, such as font size, date labelling methods, and manufacturer information, were removed from GB 7718-2025. These labelling provisions were transferred to the newly revised Food Labelling Supervision and Management Measures, which was also updated in March.
  3. Food Labelling Supervision and Management Measures (The effective date: March 16, 2027) also introduce changes such as a ban on labels that indicate a product is “for minors”.

In light of the significant changes, food exporters to China are advised to carefully compare the updated version with the previous one and conduct a thorough review of the revisions.

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Important Notice: Food Labelling Standards amended (Japan)

The Cabinet Office Ordinance to partially amend Food Labelling Standards (Japanese) was promulgated and came into effect on March 28, 2025.
N.b. No changes have been made to the proposed amendment or the transitional measures since the draft was released for public comment in January.

We have mentioned it previously on LinkedIn, but due to the importance and potential impact on products labeling in the next few years, please find the outline of the amendment as follows:

  1. Deletion of labelling exemption regulations for food additives for nutritional fortification purposes
    (Amendments to: Article 3, Paragraph 1; Appended Table 4 and 24)
  2. Amendment of the standard values for nutritional labelling
    (Amendments to: Appended Tables 9, 10, and 12)
  3. Review of labelling rules for individual food items
    (Amendments to: Appended Tables 3, 4, 5, 19, 20, and 22) *The provisions concerning prepared frozen foods will take effect from April 1, 2026.

Meanwhile, the notification (the Regarding Food Labelling Standards and the Food Labelling Standards Q&A) and the Guidelines for setting food expiry date labelling (Japanese) (which has been reclassified as an appendix to the Food Labelling Standards Q&A) were also amended on the same day, whose main points are as below (from A to C).

A. From the 38th amendment of the Regarding Food Labelling Standards (Japanese)

When labelling based on the standard values for nutritional labelling after the amendment (April 1, 2025), it is desirable to indicate “栄養素等表示基準値(2025)” (En: the standard values for nutritional labelling (2025)) to show clearly that the values are based on the new reference values to distinguish them from the previous standards.

Other amendments have also been made to the measurement methods for dietary fiber and the vitamin B group.

B. From the 20th amendment of the Food Labelling Standards Q&A (Japanese)

(Process-75-2) Regarding the labelling of foods that use additives for nutritional fortification, it’s important not only to indicate the use of additives but also to display the amount of the relevant nutrient. Even if labelling the nutrient name is not required, it is recommended to include both the nutrient name and its amount, as this information helps consumers make informed and rational food choices. (omitted).

(Process-64)1 For spices and spice extracts, as per the provisions of the section on ingredient names in the table in Article 3, Paragraph 1 of the Food Labelling Standards, and excluding those already classified as Existing Additives (additives with a long history of consumption in Japan)(the 1996 Ministry of Health and Welfare Notification No. 120), a collective label such as “spices” or “mixed spices” is permissible only when their combined weight does not exceed 2%. of the total ingredient weight.
When the combined weight exceeds 2%, each spice must be listed by its common name in descending order of weight. Or, the most common names of the spices can be listed in parentheses after labelling as “香辛料(En: spices)”, Inside the parentheses, spices are listed by descending order of weight. However, within the parentheses spices with lower weight percentages can be combined, starting with the smallest, until their cumulative weight reaches 2% of the total ingredient weight. Once this 2% threshold is met, these combined spices can be grouped and listed as “その他の香辛料”(En: other spices) within the same parentheses. (omitted)

The Q&A regarding spices has been amended due to the need for operational changes following the review of the labelling rules for individual items.

C. Additionally, the following amendments have been made:

  • “Non-caffeine” and “non-alcoholic” do not fall under the nutritional labelling specified in Article 3, Paragraph 3 of the Food Labelling Standards
  • Regarding the labelling of ingredient names when using intermediate processed ingredients (pre-processed ingredients used to make final food products), the final product manufacturer is required to label the ingredients used with the most common names based on their own judgment.

In line with the amendment of the Guidelines for setting food expiration date labelling (such as setting safety factors based on food characteristics), the related Q&As have also been updated such as the one to help prevent the waste of edible food. As examples of labelling formats, “賞味期限 ２５－９(En: Best Before 25-9)” and “賞味期限 ２５ ／ ９(En: Best Before 25 / 9)” have also been added (note: a half-width space is required before and after the full-width “／”).

The above is not to be a comprehensive summary of the amendments content.
For an overview of each amendment and the transitional measures, please refer to the proposed amendment to the Food Labelling Standards in our past article Draft Amendments to the Food Labelling Standards and the Classification of Cashew Nuts and Pistachios as Allergens (Japan) (March 5, 2025).

Do notice that we have started to and will (in the future) reflect those amendments in all our labeling reviews and preparations from April 2025. If you have specific concerns or questions about potential impact on your products, feel free to reach out to us.

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Trends in plant-based food labelling standards in various countries

In January 2025, the U.S. Food and Drug Administration’s (FDA) released Labeling of Plant-Based Alternatives to Animal-Derived Foods: Draft Guidance for Industry. I’d like to provide an overview of the latest trends in plant-based food labelling regulations across various countries, viewed from Japan.

The U.S.

As mentioned above, the guidance on alternatives for animal-derived foods was released in January of this year. The scope of this guidance includes plant-based alternatives to eggs, seafood, poultry, meat, and dairy products (excluding plant-based milk alternatives). For guidance on labelling plant-based milk alternatives and voluntary nutrient statements, please refer to Draft Guidance for Industry released in February 2023.

The guidance primarily aims to prevent misleading labels regarding product names. The main points of the guidance are as follows,

– Plant-based alternative foods, which do not have established definitions or identity standards, are classified as “non-standardized foods”

– Labels for these non-standardized foods should clearly indicate the specific plant source(s) (e.g., soy, lentil, walnut, etc.)

– Simply labelling them as “meat-free” or “dairy-free” is not recommended The guidance on plant-based milk alternatives includes nutritional guidance, such as labelling to highlight differences in nutritional values between plant-based milk alternatives and milk (referring to Appendix 1) and recommending indication of lower amounts of certain nutrients than found in milk. (Other examples of cautionary labelling for the nutritional content of milk alternatives can also be found in the labelling standards of Australia and New Zealand (2018))

Canada

In October 2024, Proposed guidance: How to label and represent plant-based alternatives to egg products was released. In addition to font size and words, there are provisions to prevent misleading impressions from images (e.g., Image of a farm). Claims such as “30% less fat than chicken’s eggs” must meet the specific requirements for nutrient content claims. For claims such as “egg free”, allergen labelling must also be considered.

France, Czech Republic

In January 2025, the Council of State of France annulled the decrees prohibiting the use of terms such as “steak” on plant-based products. The decrees were initially established in June 2022 and February 2024, but were subsequently opposed by the Court of Justice of the European Union in October 2024, leading to the repeal. Following this announcement, indicating terms such as “soy steak” and “vegetable sausage” are now permitted again. In January 2025, the Ministry of Agriculture of the Czech Republic announced it would not implement any changes to the requirements concerning meat, fishery products, eggs, and their products (regarding the regulation of “meat” labelling for plant-based products, 2024). (Note: EU has established requirements regarding the labelling of milk products (whey, cream, butter, etc.))

Thailand

In July 2024, the Thai Food and Drug Administration (FDA) announced that it is actively preparing to enter the plant-based protein market. Thai FDA solicited public comments on a draft proposal outlining labelling requirements and other regulations for plant-based protein alternatives in May 2024. The relevant standards are expected to be published after further review.

In Japan, the Q&A on Labelling Plant-Based (Plant-Derived) Foods was released in 2021, requiring indications such as “made from soy” in addition to the product name to prevent any confusion. Additionally, in 2022, Textured soy protein products under the Japanese Agricultural Standards (JAS) were established, stipulating requirements on labelling such as “肉を使用していません(En: This product does not contain meat)”.

Labelling for plant-based foods has been a topic of significant interest, along with FOP (Front-of-Pack) labelling, HFSS (High in Fat, Sugar, or Salt) regulations, and PAL (Preventive Allergen Labelling). We would like to take up any major revisions or updates to these regulations in this Newsletter in the future.

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Draft Amendments to the Food Labelling Standards and the Classification of Cashew Nuts and Pistachios as Allergens (Japan)

The draft amendments to the Food Labelling Standards (in Japanese), scheduled to be implemented in April 2025, have been published. The public comments for the amendments have been collected up to January 28.

As for allergen labelling, the 7th Advisors’ Meeting on Food Allergen (21 January, 2025) (in Japanese) proposed that cashew nuts be included in the mandatory allergen labelling list, and pistachios be added to the recommended allergen labelling list.

The outline of the proposed amendment to the Food Labelling Standards is as follows.

(1) Deletion of labelling exemption regulations for food additives for nutritional fortification purposes

(2) Amendment of the standard values for nutritional labelling

<1> Amendment of the standard values for nutritional labelling

<2> Amendment of the tolerance range for dietary fiber and addition of guideline for the amount that can be labelled as “zero”

<3> Amendment of the method of measurement and calculation of Vitamin B group.

(3) Review of labelling rules for individual food items

With the amendment of (1) (mentioned above), the labelling of food additives used for nutritional fortification will be required on all processed foods, including those previously exempt from labelling.

The amendment to (2)<1> updates the standard values of nutrients based on the Dietary Reference Intakes for Japanese (2025 Edition) including the addition of salt equivalent. Accordingly, the criteria for nutrient content claims (such as “contains”, “high in”, and “fortified with”) will also be amended. (Notably, the standard values for Vitamin B12 and Vitamin D have significantly increased.)

As for (3), the following points have been reviewed for the amendments.

-Standards of identity
-Labelling rules for individual food items (Legal name, Ingredients list, Additives, Net weight)
-Regulations for legal names
-Additional labelling items
-Labelling format
-Prohibited labelling items

The following are the food categories for which individual labelling rules have been abolished or amended.
-Partial abolition and amendment
　12 items such as miso, retort pouch foods, etc.
-Partial abolition
　1 item: margarines
-Complete abolition
　7 items such as prepared frozen foods, instant noodles, etc.
22 items including soy sauce and ham are scheduled for review this year.

The future schedule (the implementation schedule and transitional period) about Food Labeling Standards is as follows:

  Implementation schedule Transitional period
(1) Article 3, Paragraph 1, Appended table 4, 24 April 1, 2025 5 years
(2) ＜1＞Appended table 10, 12 April 1, 2025 3 years
＜2＞＜3＞Appended table 9 April 1, 2025 –
(3) Appended table 3, 4, 5, 19, 20, 22 April 1, 2025 5 years
Among the above, the amendment of “prepared frozen foods” April 1, 2026 5 years

The draft amendment to the Food Labelling Standards, incorporating feedback from the public comments, is expected to be published shortly. Additionally, the draft amendment for allergen labelling, as previously mentioned, is anticipated to take effect sometime in fiscal year 2025. For those of you who can read Japanese, we advise to look through the survey results in the meeting materials, including the background information on the rapidly increasing number of allergy cases related to nuts. We will keep everyone informed of any progress on this topic here in this newsletter!

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Summary of the status of legal changes on food labelling in Japan (2)~ Amendment of the Standard Values for Nutritional Labelling and Progress Report on Reviewing Labelling Rules for Individual Food Items (Categories)~

This article continues the previous article, Summary of the status of legal changes on food labelling in Japan (1).

The Food Labelling Advisory Committee (held on 13 December 2024) (Japanese) reviewed the draft amendment to the standard values for nutritional labelling. At the meeting, the progress of reviewing the labelling rules for each individual food item (from the 1st to the 7th meeting) by the subcommittee was also reported.

Amendments of the standard values for nutrients labelling

The standard values for nutritional labelling will be revised based on the Dietary Reference Intakes for Japanese (2025 Edition) published by the Ministry of Health, Labour and Welfare (11 October 2024). Some standard values for nutrient labelling, such as those for calcium and vitamin D, will be increased. For further details of the amendment, please refer to the Draft Amendment to Nutrition Labelling (Japanese). With the revision of standard values for nutrient labelling, the standards for nutrient content claims (such as “contains,” “high in,” and “fortified with”) are also expected to be updated. Therefore, business operators who use these claims on their products should ensure they comply with the new standards.

Review of labelling rules for individual food items

The review has been made to align with the “horizontal” standards that apply to all foodstuffs. Some opinions and requests have been presented at the discussions so far, such as: “There were food items for which individual rules were already abolished (7 out of 22 items already discussed by the subcommittee)”, “Definitions and names under the labelling rules for each individual food item should remain on the label“, “It is preferable to maintain the individual labelling rules according to the characteristics of the food item“, etc. For details, refer to The Sub-Committee for the review of labelling rules for individual products (Japanese). The remaining 22 items with current individual mandatory labeling will continue to be reviewed by the subcommittee and will be reported to the Advisory Meeting in the next fiscal year (March 2026).

Regarding the items to be revised and future steps

The anticipated amendments to the Food Labelling Standards are outlined in the Advisory Meeting materials titled Regarding the Amendments of Food Labelling Standards (Japanese). This document includes the specific Articles and Appended Tables that are subject to revision. Here is an excerpt from the material.

  1. Mandatory labelling of additives for nutritional fortification purposes
    Article 3, Paragraph 1
    Appended Table 4 – Labelling rules for individual food item
    (Legal name, Ingredients list, Additives, Net weight)
    Appended Table 24 – Individual labelling items for general fresh foods
  2. Amendment of the standard values for nutritional labelling
    Appended Table 9 – Units for labelling nutritional components and energy, measurement methods, tolerance ranges, and contents that can be labelled as “zero”
    Appended Table 10 – Standard values for nutritional labelling
    Appended Table 12 – Standard values for claims on nutrient supplementation
  3. Review of labelling rules for individual food items
    Appended Table 3 – Standards of identity
    Appended Table 4 – Labelling rules for individual food item
    (Legal name, Ingredients list, Additives, Net weight)
    Appended Table 5 – Rules for legal names
    Appended Table 19 – Additional labelling items
    Appended Table 20 – Labelling form
    Appended Table 22 – Prohibited labelling items

A public consultation on the draft amendments to the Food Labelling Standards is expected to take place within this fiscal year (until March 2025). Although the exact timeline for the amendments remains uncertain*, it is believed that changes to allergen labelling, including adding cashew nuts to the mandatory list, are being considered. As such, it would be a good time to begin preparing for these anticipated changes.

* The amendments are now scheduled to enter into force on 1 April 2025. The public consultation on the amendments closed on 28 January 2025.

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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.

Summary of the status of legal changes on food labelling in Japan (1)

Looking back the year 2024, there have been various amendments to the food labelling system this year, and we would like to reiterate the domestic situation.

Status of amendments in 2024

The main amendment announced this year was the addition of “macadamia nuts” to the list of Voluntary allergen labelling items (and the deletion of “matsutake mushroom”).  There is no transitional period for these measures, but there currently is one for “walnuts”, which was added to the mandatory allergen list in March 2023 and will end on 31 March 2025.  The addition of cashew nuts to the mandatory allergen list is also under consideration at the moment. This is due to the fact that in the “2024 Report of the Research and Study Project on Food Labelling Related to Food Allergy (Japanese)”, the number of shock cases involving cashew nuts increased significantly, making it the fifth most common causative food.

March 2023“Walnuts” added to the list of mandatory allergen labelling (Japanese)
March 2023End of the period for transitional measures for revision of ‘non-GM labelling criteria (Japanese)(revised in April 2019)
March 2024End of the period for transitional measures for “the guideline of additive labeling for use of ‘non-use (Japanese)’” (published in March 2022)
March 2024Addition of “macadamia nuts” and deletion of “matsutake mushrooms” to the list of the allergens for recommended labeling (Japanese) (no period for transitional measures)
March 2025Period for transitional measures for mandatory allergen labelling of “walnuts” ends
2025- (under review)Addition of “cashew nuts” to the list of mandatory allergen labelling

Other major changes include the transfer of the food sanitation standards administration (e.g. designation of food additives and formulation of standards), previously under the jurisdiction of the Ministry of Health, Labour and Welfare, to the Consumer Affairs Agency (Japanese) from April 2024.

Themes under consideration and future amendments

Several discussions on food labelling systems have been held between last year and this year. “The Sub-Committee for the review of labelling rules for individual products (Japanese)” is studying the labelling rules (labelling items, labelling methods, prohibited labelling items, etc.) for individual products, such as bacon, ham, carbonated drinks and fruit drinks, with the aim of making the rules more comprehensive.  The public comments on these draft amendments are expected to take place by March 2025.  In addition to reviewing the setting of expiry date labels, “The review discussion on guidelines for setting food expiry date labels” (Japanese) is also considering the ‘handling of food that has reached its expiry date and can still be eaten’.  The draft amendments are also expected to be published by March 2025.

In addition, “The discussion on Front-of-package Nutrition Labelling in Japan” (Japanese) is considering the direction of voluntary labelling with reference to front-of-package nutrition labelling systems in other countries.  “The Sub-Committee to Study the Use of Digital Tools for Food Labelling” (Japanese) is also scheduled to study specific methods of utilizing digital tools with reference to initiatives in other countries. In January 2023, “The 3rd Food Labelling Advisory Committee (Japanese)” also discussed “the labelling of additives used for nutritional fortification purposes (Japanese)”.. It is expected that a draft amendment will be drawn up after conducting a fact-finding survey. (Japanese)

The above is a brief summary of the upcoming amendments to the food labelling system, which are likely to have a significant impact in practice, particularly with regard to “cashew nuts”, “labelling rules for individual items” and “labelling of additives used for nutritional fortification purposes”. We hope that you will take the opportunity to review each of the amendments once again.

Additional information: 19 December 2024

The 2024 Food Labelling Advisory Committee (held on 13 December) (Japanese) presented a proposal to revise the standard values for nutrient labelling (the standard values for nutritional claims are also scheduled to be revised), and public comments will be invited in the future.

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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.

Current food waste issues triggered by expiry date labeling, Proposed legislation to uniform food expiry date labelling in California/USA, and General Situation around the world (including Japan)

On 28 September 2024, the State of California, USA, announced that a bill to uniform food expiry date labelling had been signed. Until now, the state has allowed for the use of “Sell by”, “Best by/before”, ‘Expired by’ as well as other recommended labelling methods such as “Best if Used By” and “Use By”, when displaying expiry dates, but from 1 July 2026, uniform labelings such as “Best if Used By”, “Best by/before”, “Expired by” will become mandatory. Such uniform labelling is said to help ensure a sustainable future by reducing the likelihood of confusion over quality and safety, whereas the various expiry date labels have been confusing for consumers and have led to unnecessary food waste.

In the US, there are no federal regulations on food expiry date labelling, except for infant formula, and consequently a legislation was proposed in May 2023 for the Food Date Labeling Act, which also aims to uniform on “Best If Used By”, “USE By” and so on to prevent consumer confusion and help solve the problem of food waste.

The relationship between expiration date labels and food waste has been an issue in many countries, with the EU estimating that up to 10% of food waste may be related to a lack of understanding of expiration date labels, and a revision of the Regulation on the provision of food information to consumers (FIC Regulation (EU) 1169/2011) is planned. Improvements are being considered in terms of terminology, format and visual presentation to avoid consumer misunderstanding the “use by” and “best before” labelling methods.

In April 2024, the Food Standards Agency of Australia and New Zealand (FSANZ) released its “2023 CONSUMER INSIGHTS,” and the following information is a good illustration of the current situation of food waste that is past its expiration date.

“Most people correctly understood best before and use-by dates, but up to a third expressed an incorrect understanding.”

“Among people with a correct understanding of date marking, up to a third reported behavior inconsistent with their understanding.”

In Japan, a ‘Study Group to Review Guidelines for Setting Food Expiry Dates’ has been convened since May 2024, and in addition to reviewing the setting of expiry date labels, it is also considering the “handling of food that has reached its best before date and can still be eaten”. The revised guidelines are due to be published in March 2025.

The above is a brief summary of the current situation in each country regarding expiration date labeling, which may be a trigger for food waste. In practice, especially when exporting food products to Japan or another country, it is necessary to review local labeling methods about expiry date labeling. By deepening our understanding that time limit labeling is related to the problem of food waste as a background, we believe that it will be easier to respond and prepare for future labeling creation.

Supplement

The expiration date labeling, which is often printed at the time of manufacture, is a labeling item that is prone to error when importing or exporting due to differences in labeling methods between countries. (In particular, the order in which expiration dates are printed is confusing, as some countries use “day-month-year” or “month-day-year,” while Japan uses “year-month-date”). In the design stage of labeling, it is recommended that the space for the expiration date not be left blank, but that the difference be easily recognized in advance by writing “YYYYY.MM.DD”, “DD.MM.YYYYY”, “MM.DD.YYYYY”, and so on.

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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.