Author Archives: Ikram Riahi

About Ikram Riahi

Label bank Co., Ltd. Regulatory inspections and Consulting Research staff Born in Tunisia. Specializing in bioengineering, her job mainly involves research work on foreign ingredients and additives, as well as monitoring information on amendments to food standards and labeling standards in various countries.

FOP, GMO, and small packaged food labeling: Latest Updates to the Food Labeling regulations for some countries


The food industry is growing incredibly fast in all aspects due to the variety of products and their resources. As a result, government agencies are working day and night to ensure that consumers are well-informed and guided in their food choices. We would like to share with you some highlights of the Food labeling regulations around the world.

1. Front of Pack labeling in Brazil

The above cannot pass without mentioning the ‘Front of Pack’ labeling, a very encouraging labeling trend that has been adopted under different names in the countries such as Singapore (Nutri-grade), Australia (Health Star Rating), UK (Color-coded GDA) and the European region (Nutri-score). Now, other countries are following this “healthy” trend, such as Brazil, which was enforced last October 2022.

Such legislation aims to inform the consumer clearly and simply about the high content of certain nutrients relevant to health. The “magnifying glass” symbol must be displayed on the front of the packaging, at the top, indicating one or more nutrients, as the case may be when foods contain the following amounts of nutrients:

A high content of:Solid and semi-solid foodsLiquids
Added sugar15 g or more per 100 g7.5 g or more per 100 ml
Saturated fat6 g or more per 100 g3 g or more per 100 ml
Sodium600 mg or more per 100 g300 mg or more per 100 ml

The followings are the “magnifying glass” symbol models that can be used:

a) Models for 1 nutrient b) Models for 2 nutrients
c) Models for 3 nutrients

In addition to the above, other changes have been made to the Nutrition Facts panel and changes have been proposed to the criteria for the use of nutrition claims to avoid inconsistencies with the FOP label.

The transition period for companies to adjust their existing labels is until next October 9th, 2023 for food in general.

2. GMO Labeling updates

Advanced technologies are being incorporated smoothly into our plates, and some consumers are still quite reserved when it comes to their food. However, the science of genetically modified organisms continues to grow faster and wider. Therefore, governments are trying to further simplify the idea of GMO foods and to clarify their advantages while putting more care into drafting the legislation.

A. Malaysia: ‘Guidelines on Labelling of Food and Food Ingredients Obtained Through Modern Biotechnology’ were published.

On Jan 16th, 2023, guidelines on labeling GMO products and ingredients, were published, highlighting the necessity of displaying the origin of food and food ingredients obtained through modern biotechnology on the label as follows: “gene derived from (origin)”.

Please also note, that even if the food and food ingredients are produced from a GMO, but do not contain GMOs, it is mandatory to display the following statement: “produced from genetically modified’’.

The above labeling requirements apply ONLY to foods containing, consisting of, or produced from GMOs in a proportion greater than 3% of the food ingredients ‘considered individually, or foods consisting of a single ingredient, provided that this presence is adventitious or technically unavoidable’. The guidelines also detail labeling requirements, such as where to place the statement for single and multiple-ingredient products, and labeling exemptions.

Example of Labeling


(d) in the case multi-ingredient foods, the information shall appear in the list of ingredients immediately following the ingredients; and

(e) the statement “contains genetically modified ingredient” shall be stated on the principal display panel in close proximity with the name of the food and shall be in not less than 10 point lettering.

Example of Labeling


(c) for the purpose of paragraphs (a) and (b), in the case of single-ingredient foods, the information shall appear on the principal display panel in close proximity with the name of the food and shall be in not less than 10 point lettering;

B. USA: ‘Feed Your Mind’ A smart move from the FDA

GMO foods have been in our markets since the 1990s and continue to increase in quality and variety. The FDA has taken several steps to ensure these products’ safety and provide consumers with as much information as possible.

For example, the FDA has launched a new educational initiative and published a brochure in July 2022 to explain GMOs and reassure consumers about health and allergies. Since the term “GMO” itself is known to consumers as a reference to foods derived from genetic engineering, this initiative introduces the term “bioengineered” instead.

A new national standard that defines bioengineered foods as ‘those that contain detectable genetic material that has been modified through certain lab techniques and cannot be created through conventional breeding or found in nature’, has been enforced on January 2022.
It is now mandatory to disclose food labeling if they are bioengineered.

3. Labelling of processed food served in restaurants with the meals

On January 12th this year, the Taiwan Food and Drug Administration released a draft article requesting public opinion in regards to packaged processed foods served with meals at restaurants.

According to Article 22 of the Food Safety and Sanitation Management Law, food labeling should display all the mandatory labeling items in Chinese.

However, in regards to food labels whose maximum surface area is less than 20 cm2, and following the “Small Packaged Foods Exemption from Partial Labeling” (小包裝食品免一部標示) regulation, one of the following methods can be used:

A. Only labeling of the product name, expiration date, name and address of the manufacturer and the responsible domestic company, country of origin of the product and origin of specific ingredients published by the authorities, and warnings such as allergens declaration.


B. Only labeling of the product name, and expiration date, in addition to a “QR Code” or other electronic methods, containing the rest of the labeling information, along with the statement “scan here to get product label information” or equivalent any other equivalent statement.

For this reason, and to protect the very interest of consumers, pre-packaged food products served with meals at restaurants such as Ketchup and Mayonnaise, shall now be labeled under the above legislation if the maximum surface area of the outer package is less than 20 cm2

Therefore, the previously released letter exempting small-package food products served with meals in restaurants from individual labeling is now suspended.


It is clear how consumers’ interest in receiving enough information about their food products is considered of big importance to governments. There are numerous reasons for this, such as the fast-growing health issues in populations and also the digitalization of information.

In our next article, we will give you a summary of the release from the FDA on The Draft Guidance on the Labeling of Plant-Based Milk Alternatives on February 22nd of this year, which also includes the FDA’s recommendations on the use of voluntary nutrient statements. In addition to the above, we will share with you any important new updates to the Food labelling regulations around the world.


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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.

Updates on food labeling for pre-packaged food products and the current situations of the Nutri-score labeling in the world

Eating habits are a form of culture that has the primary effect on the health profile of each country around the world. While some countries are struggling with constantly increasing rates of obesity and cardiovascular diseases due to excessive consumption of sugar and fat, others considered as healthy, however, are worrying about nutrient deficiency.

For this reason, governments are constantly brainstorming to come up with the clearest ‘map’ for consumers to guide them through their daily choices of food products. By ‘map’ here, we are talking about the nutrition facts and all related claims displayed on food products.

In this article, we will walk you through the latest updates in regards to the nutrition facts labeling and related claims.

1. Updates on Nutrition Facts Labelling (Canada)

Given the challenges raised by the COVID-19 crisis, the Canadian government has extended the transition period from December 14th, 2021 to 2022 instead, for food producers to comply with the new requirements for the nutrition facts and ingredient list.
These amendments are intended for a better understanding for consumers of the contents of the products and are as follows:

Image 1: Comparative image for the new and old Canadian nutrition facts table.

Now compared to the new nutrition facts table for the U.S, attention is given to the serving size and its calories, as it will help consumers make a more realistic choice while comparing to other similar food products. Potassium has also been added for its importance to the Canadians’ diet, while vitamin A and vitamin C were removed as Canadians’ diet is already rich enough.

*There are regulations regarding the standard amount of serving size in Canada

Under Food Labeling Standards in Japan, minerals (e.g., potassium, calcium, iron, etc.) and vitamins (e.g., vitamins A, C, B1, etc.), etc. are listed as nutrient components in Appended Table 9 of Food Labeling Standards, and can be labeled voluntarily. Sugars are also nutrients for voluntary labeling (however, if these nutrients are labeled on the container or packaging, or if a nutrient content claim is made for specified nutrients, it is mandatory labeling). Sodium is converted to “salt equivalent” and displayed.

2. Ingredients list labeling updates (Canada)

The Canadian government has also announced changes to the ingredient list, with particularly significant changes to the labeling of sugars (the definition of sugars is provided separately). Sugars can now be grouped in brackets and in descending order of weight, following the word ‘sugars’, which will help consumers easily spot all sources of sugars present in the food product. The above is only required when the final product contains 0.5 g or more of sugars/serving.

In Japan, however, sugars do not need to be grouped and labeled unless individual labeling methods are stipulated, such as for foods specified in Appended Table 4 of Food Labeling Standards.

On an additional note, if you wish to use claims for sugars on your products marketed in Canada, you need to review the information provided in the summary table, which outlines the terms and phrases that may be used and the conditions required, etc. Please note that claims such as “low carbohydrate”, and “light” are not allowed for use on food products.

The updated content other than sugars is related to colouring.
Font related updates were also listed and summarized in the following image:

Image 2: Ingredient list (Canada)

3. Front of Package labeling (FOPL) in other countries

3.1. Definition

The Front of Package labeling, known as ‘FOPL’, is an informative tool highlighting the contents of sugars, fat (total, trans and saturated) and sodium, etc. in processed food products; therefore, provides guidance to consumers to make the right choice for their diet/needs.

There are various FOPL systems that have been introduced and serving different purposes, in addition to the nutrition facts table:

System How it works Example
GDA*1 systems

*1 GDA:Guideline Daily Amount

A simplified form of the nutrition facts label, showing, for calories and each nutrient, their amount and ratio to the Daily Dietary Reference Intake.

United Kingdom:

GDA systems
Color-coded GDA/RI*2 FOPL systems

*2 RI:Reference Intake

It is a colour-coded GDA and a hybrid display system of GDA and TLL*3

*3 TLL:Traffic Light Labels

United Kingdom:

Color-coded GDA/RI FOPL systems
Displays the overall health index of the food product based on a calculated score. Nutri-score
5 scores available- France
4 scores available-Singapore
Health Star Rating
10 scores available-Australia
Health Star Rating
Using logos/seals developed by nationally or internationally recognized organizations/institutions based on certain criteria to testify for the healthiness of the product Nordic KeyholeNordic Keyhole

(Scheme introduced by Swedish National Food Agency).

It is used in Sweden, Norway, Denmark, Iceland, Lithuania and North Macedonia.

*Please check the latest requirements to use the Nordic Keyhole.

Healthier Choice Symbol (HCS)Healthier Choice Symbol (HCS)
It is used in Singapore.

*Please check the latest requirements to use HCS.

Nutritional warnings systems Using the following expressions “HIGH IN” or “EXCESS” referring to certain nutrients’ contents and specifically, sugars/fats (total, trans and saturated)/sodium, etc. The expressions that can be used vary from country to country and should be checked beforehand. Latin America and Caribbean countries:
Nutritional warnings systems
Already enforced in some countries like Chile Mexico and Brazil, etc. and proposed for mandatory display in Canada.

3.2. Updates and current situation

In Canada, as an additional step to ease and help consumers make healthier choices, FOP (front-of-package) labeling is being proposed by Health Canada to be displayed on specific food products that are high in sodium, sugars and saturated fat, along with other provisions and the expected changes are to be published this year.

This proposal comes aligning with other countries’ initiatives, without being a part of a formal regulatory cooperation plan with other international organizations. Health Canada is expecting compliance with these amendments to be by January 2026.

In the European region, the UK was the first country to implement it and published its guidelines in 2013 to help/encourage food business operators in developing the FOP labeling for their pre-packaged food products.

On UK’s Colour-coded GDA, it is also possible to add descriptive words along with the colours to reinforce the meaning: e.g. red/ “High”, amber/ “Medium” or green/ “Low”. This must be done in a clear and comprehensive way not to mislead consumers. It has already been adopted by the majority of food products in the British market.

Subsequently, the WHO launched calls for FOP labeling implementation as a part of their Food and Nutrition Action Plan 2015-2020. In 2017, France introduced its voluntary display said ‘Nutri-score’ FOP labeling, received lots of encouragement from WHO and EU and then adopted by other European countries.

3.3 The Nutri-Score label and EFSA*’s latest opinion

* EFSA: European Food Safety Authority

The Nutri-Score label was created based on Food Standards Agency (UK) nutrient profiling system (FSAm-NPS) score and is 5 colours and letters coded, from Green (grade A) to Red (grade E), indicating the healthiness degree of the product, in order to improve the consumers’ choice and encourage food operators to opt for healthier formulations.

The score calculations are made per 100g or 100ml and take into account both the nutrients to limit (calories, saturated fat, sugars and salt) and other elements (fiber, protein, nuts, fruits and vegetables, etc.). Later on, the European Commission has proposed the enforcement of such labeling on food products.

However, questions are starting to rise recently in regards to the efficacy of such a system.

According to the EFSA’s latest scientific opinion:

“A diet in line with science-based recommendations for food and nutrient intake is an important determinant of health. Because diets are composed of multiple foods, overall dietary balance may be achieved through complementation of foods with different nutrient profiles so that it is not necessary for individual foods to match the nutrient profile of a nutritionally adequate diet.”

This means that analyzing the nutritional value of a single food product cannot validate the healthiness of a whole diet. This study was previously preceded by the Italian Federalimentare, unsatisfied with the Nutri-score judgemental system, said to be ‘misleading’, by classifying most traditional products (e.g.: olive oil, parmesan, cured meat, etc.) as ‘unhealthy’ based on their fat/salt/sugars contents, etc, rather than their nutritional value and importance for health.

The constantly ongoing changes are mostly related to three main elements of a food label: ingredients list, nutrition facts and nutrition claims, based on scientific studies and consumers’ needs, to enhance the food safety and quality. The main motivators for governments are health and sincerity, to avoid misleading consumers into an unhealthy diet/lifestyle and to push food operators to make more efforts to refine their products.

We highly advise you to keep checking the latest updates every time for each country.


  1. Food labelling changes (Canada)
  2. The guideline for Nutrition Facts labeling based on Food Labeling Act for business operators (Japan)
  3. Carbohydrate and sugars claims (Canada)
  4. GDA label (UK)
  5. Guide to creating a front of pack (FOP) nutrition label for pre-packed products sold through retail outlets (UK)
  6. The Nutri-Score: A Science-Based Front-of-Pack Nutrition Label (France and other countries introducing Nutri-score)
  7. Measures for Nutri-Grade Beverages (Singapore)
  8. How to use Health Star Ratings (Australia)
  9. Front-of-package labelling (Latin America and the Caribbean, etc.)
  10. Experiences in the design and implementation of front-of-pack nutrition warning labels in Latin America and the Caribbean (Latin America and the Caribbean, etc.)
  11. Forward Regulatory Plan 2022-2024: Regulations Amending Certain Regulations Made Under the Food and Drugs Act (Nutrition Symbols, Other Labelling Provisions, Partially Hydrogenated Oils and Vitamin D) (Canada)
  12. Scientific advice related to nutrient profiling for the development of harmonised mandatory front-of-pack nutrition labelling and the setting of nutrient profiles for restricting nutrition and health claims on foods (EFSA)

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.