Author Archives: Akihito Kameyama

About Akihito Kameyama

Label bank Co., Ltd. Regulatory inspections and Consulting Research staff Born in Japan. With many years of experience in the additives (formulation) business, his work focuses on additives verification, as well as ensuring the consistency between the technical information in English and Japanese. He also acts as a seminar lecturer on topics related to the standards of use of ingredients.

[Lecture/Seminar]
  • "Regulatory Requirements of Food Ingredients/Additives Used in Japan" (ChemLinked: REACH24H Consulting Group/Webinar) Oct. 2020

Key points to keep in mind when Making Environmental Claims on Food Labeling in the United Kingdom

In July 2024, the UK’s Advertising Standards Authority (Below we refer to it as the ASA) published “Environmental claims in food advertising,” which provides advice on making environmental claims on meat, dairy, and plant-based food labeling. The following is a brief overview of the advice.

A recent consumer survey conducted by ASA on environmental claims aimed at meat, dairy, and plant-based foods showed that the use of certain “green” or “natural” terms or visual images in an advertising context can create a series of associations and evoke strong speculation about environmental/animal welfare or health benefits of a brand or product. In response to the findings, ASA announced that care should be taken to ensure that such storytelling do not go so far as to foster a misleading disconnect between a particular depiction and reality.

Specifically, it stated that when environmental claims are made using photographs, they should be taken or filmed in the real-world environments which they are depicting, and where this is not feasible, particular care should be taken to avoid exaggerating the nature (visual or linguistic) of real-world agricultural and livestock practices and conditions in a way that goes beyond legitimate storytelling of the products. For example, if your product does not actually relate to “free range” livestock, you need to be careful not to imply this as if it were the case. Finally, the ASA concluded that, as with all advertising, evidence must be held for all environmental claims, whether direct or implied, written or visual.

What about Japan and other countries?

In relation to such environmental claims, the Ministry of the Environment of Japan has established a guideline: “Environmental Labeling Guidelines” (Japanese). The Guidelines states that appropriate environmental labeling must meet the following requirements: the information must be accurate and based on evidence, it must not mislead consumers, the content of the environmental claim must be verifiable, and it must not be ambiguous or abstract.

In addition, the Federal Trade Commission (FTC)’s Environmental Claims: Summary of the Green Guides and the European Commission (EC)’s Products – labelling rules and requirements have also established guidelines and regulations for environmental claims.

Meanwhile in Asia, the Korea Fair Trade Commission (KFTC) has amended its Guidelines for Review of Environment-Related Labeling and Advertising in South Korea. This has strengthened regulations against so-called “greenwashing,” which is the practice of giving the appearance of being environmentally conscious when in fact it is not, and appears to be a trend against environmental claims. As interest in environmental issues continues to grow, the trend to actively incorporate this environmental claim is likely to accelerate. We hope that you will find this information useful when you are planning to make such labeling in accordance with the relevant regulations of each of our target countries.


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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.

Recent Trends in Food Labeling Standards in U.S.A., Australia, and Canada

The following is a summary of the trends in the food labeling standards of the United States, Australia, and Canada.

U.S.A.

Update

On May 16, 2023, the Food and Drug Administration (FDA) released a draft Compliance Policy Guide regarding major food allergen labeling and cross-contact.

Overview

The draft specifies FDA’s enforcement policy for managing cross-contact with the ingredients of other products with different allergens manufactured in the same production area or on the same production line/equipment.

We believe that the draft highlights the U.S. policy to prevent potential cross-contact, rather than the so-called precautionary allergen labeling (PAL), which is a voluntary “may contain” labeling that indicates the possibility of cross-contact. For more detailed background on why the FDA has taken this policy, please visit the FDA website here.

Australia

Update

The new allergen labeling standard was revised on February 25, 2021, and is currently in a transition period that will end on February 25, 2024.

Overview

The Food Standards Code requires allergens to be labeled using certain required names.

Please refer to the FSANZ website for details. Under the new standards, tree nuts, molluscs, and cereals, which were previously indicated using such category names, must now all be listed separately using the individual name of each allergen.

Canada

Update

The following are the labeling standards set by the Canadian Food Inspection Agency (CFIA) in their transition periods (as of June 2023).

– Amendments to the Food and Drug Regulations related to nutrition labeling, list of ingredients and food colours, which came into force on December 14, 2016→Transition deadline: December 14, 2023 (Some action will be taken on regulated parties that do not comply with the new labeling requirements. See below for details.)

– The standards on Nutrition Facts labeling enforced from July to November 2022→Transition deadline: December 31, 2025 (the compliance date beginning January 2026).

Overview

– Amendments to the Food and Drug Regulations related to nutrition labeling, list of ingredients and food colours, which went into force on December 14, 2016:
The change is related to the grouping of sugar-based ingredients under the name “sugars” and food colours, and so on. For more information, please see our past article.

– The standards on Nutrition Facts labeling enforced from July to November 2022:
Amendments have been made to the nutrition labeling in the FOP (See here for details), as well as to the nutrition claims/their standards, and the mandatory labeling for sweeteners. (See here for details). And also potassium and sodium values for certain age groups in Table of daily values for nutrition labeling have been amended. (See here for details.)

The deadline for the labeling standards was originally set for December 14, 2022. However, given the challenges imposed by COVID-19, CFIA has extended its deadline to December 14, 2023. Between December 15, 2022, and December 14, 2023, CFIA will verify compliance and take some action unless non-compliant companies have detailed plans showing how they intend to meet the new requirements at the earliest possible time.

These are the recent updates in the three countries, and we hope you will take a look at the details of each of them. Noteworthy, the above-mentioned allergen labeling standards in Australia also include information on precautionary allergen labeling (PAL), but the labeling of cross-contact is not regulated by the Food Standards Code. However, we should closely watch the possibility of revising the standards in Australia as well to include management guidelines that prevent cross-contact rather than labeling.


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.

Names of marine products in Japan and other countries

The labeling of the name and place of origin of marine products has been taken up as a topic in recent years. In Japan, the labeling of such names is required to be made in accordance with the “The guidelines for the legal product names of seafood”. In other countries what kind of rules are used to make such labeling then? Let us take a look at the cases of the EU, the US, Canada, and Australia/New Zealand.

“The guidelines for the legal product names of seafood” (Japan)

In Japan, the standard Japanese names for fish and shellfish are based on the “The guidelines for the legal product names of seafood” (Attachment, Food Labeling Standards Q&A) in principle. However, if there is a more widely used name for particular species, this name may be used in order to avoid confusion among consumers with the use of unfamiliar standard Japanese names, etc. “(Appended Table 1)” of the guidelines has listed examples of alternative common names and corresponding scientific names in addition to the “Standard Japanese names” of fish and shellfish.

Food Labeling Standards Q&A Attachment The guidelines for the legal product names of seafood (Consumer Affairs Agency)

The scientific names listed with the standard Japanese names can be referred to in determining the labeling name of the marine product, as well as in determining a name that is generally understood for species that does not have standard Japanese names, such as exotic species, together with the name in the country of origin, etc.

A pocket guide to the EU’s new fish and aquaculture consumer labels(EU)

In the EU, the Pocket Guide with the above title issued by the European Commission (see the link below*) specifies the labeling method of marine products. The contents are largely divided into “Unprocessed and certain processed fishery and aquaculture products” and “Other processed fishery and aquaculture products”. Both categories are obliged to indicate their names (names stipulated by acts and regulations as well as names customarily used and general names used for distribution). For the former category, it must be accompanied by their scientific names.
[The former is called “Commercial designation” and the latter is called “Name of the food” respectively for their general names”.]

*A pocket guide to the EU’s new fish and aquaculture consumer labels (European Commission)

The rationale for the above pocket guide comes from the following information by the European Commission.

Commercial and scientific name of the species
Each EU country draws up and publishes a list of the commercial designations accepted in its territory, including accepted local or regional names.

Excerpt: Commercial and scientific name of the species (European Commission)

Scientific names can be confirmed from the following page by the European Commission. By entering Commercial designation, a name of a marine product to be sold, you can search for its scientific name corresponding to that name, which is also linked to the name in the language of each EU member country.

Commercial designations of fishery and aquaculture products (European Commission)

The above search results obtained are in English, but you can refer to the list of Commercial designation/scientific names in European languages, including English, by clicking the following link.

Commercial designations of fishery and aquaculture products: Language (European Commission)

The Seafood List (USA)

In the US, The Seafood List by the Food and Drug Administration(FDA) indicates the “Acceptable Market Name” (a name accepted by FDA as not to be mistaken for other types of seafood for labeling), “Common Name” (a name used by ichthyologist and fisheries experts to identify the type of seafood), and the scientific name of each seafood product.

The Seafood List (FDA)

According to the explanation on this site and the following site, basically “Acceptable Market Name” is indicated, but there are some types of marine products that use “Common Name” as their name. The scientific name itself can be labeled only as reference information to confirm that the labeled name is appropriate, and is not required to be labeled as in the EU.

Guidance for Industry: The Seafood List (FDA)

CFIA Fish List (Canada)

The Canadian Food Inspection Agency (CFIA) lists common names for each scientific name in English / French in the CIFA Fish List and recommends that these names be indicated. Names not on this list may be indicated as far as an inspection is conducted to ensure that they do not lead to false or misleading labeling.
Please refer to the following site.

Food Standards Australia New Zealand (FSANZ)

Food Standards Code by Food Standards Australia New Zealand (FSANZ) does not define names for fish.
However, the seafood industry in Australia has worked with Standards Australia, the non-government, not-for-profit standards organisation, to develop an Australian Fish Names Standard which provides guidance on standard fish names to be used.
For New Zealand, the Ministry for Primary Industries (MPI) website provides Maori names and scientific names for each fish species.
According to the FSANZ website, there are a free call of consulting services for Australia and New Zealand respectively in the case (from the FSANZ website)
“Sometimes fish may be incorrectly identified at capture or wholesale, and the mistake carries on through the supply chain to consumers. To ensure you’re getting what you paid for, find a reputable fishmonger/restaurant. If you’re concerned that fish may be mislabelled, then contact the supplier in the first instance. If you are dissatisfied with the explanation or response…”. For more details, please check the link below.

Fish names (FSANZ)

The above is a review of cases in the EU, the US, Canada, and Australia/New Zealand regarding the labeling of names of marine products. I believe that it is a common theme in all countries to label fish and shellfish with correct and easy-to-understand names to avoid misunderstanding when similar or identical names are associated with multiple species. We hope that this information will be of some help to those who handle marine products in their import and export processes.


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.