Author Archives: Chinami Nakanishi

About Chinami Nakanishi

Label bank Co., Ltd. Regulatory Review and Development Born in Japan. Specializing in nutrition, she is engaged in research work on ingredients and additives imported to Japan from overseas, and provides consulting services on food standards, additives, and food labeling.

Study on the Use of Digital Tools for Food Labeling

On October 1, 2024, the “First Subcommittee Meeting to Study the Use of Digital Tools for Food Labeling” (hereinafter referred to as the “Subcommittee Meeting”) was held. During this first gathering, the current status of the use of digital tools in Japan and abroad, as well as current issues related to them were discussed. In this issue, we would like to summarize the contents of the first subcommittee meeting based on the materials published for it.

Background of the Study

In the “Consumer Basic Plan Schedule”(note), it is stated that a rational and easy-to-understand food labeling system should be discussed based on consistency with international standards.

(Note)
An annual plan of actions and timelines based on the Consumer Basic Plan, an action plan to improve the lives of consumers set by the Consumer Affairs Agency

At the 2023 Food Labeling Roundtable Meeting, the general direction that food labeling should take in the future was presented, and “the use of digital tools for food labeling” was mentioned as one of the directions.

Mandatory labeling items for food products in Japan are difficult to read, they are numerous, and if it is increased beyond the current items, consumers with diverse needs may find it even more difficult to read the labels and may not fully refer to them. In parallel, it should be noted that discussions are currently underway in the Food Labeling Subcommittee of the Codex Alimentarius Commission (International governmental organization for international food standards) on the formulation of international rules for the development of “Guidelines for the Provision of Food Information Using Technological Innovation”. In light of these developments, a subcommittee will be established at the 2024 Food Labeling Roundtable to discuss the direction of the use of digital tools for food labeling.

Current Considerations in Codex Alimentarius

The Sub-Committee discussed how to use technology as an alternative to the conventional mandatory labeling items on packages and the content of information to be provided in such cases, and prepared the “Draft Guidelines for the Use of Technology to Provide Food Information in Food Labeling” (For details, please refer to Subcommittee Document 3 (in Japanese).)

Overseas Initiatives

Other countries are also moving forward with the use of digital tools to provide food labeling information. For example, in Indonesia, it has been confirmed that QR codes are mandatory to be displayed on containers and packaging, and that the product information database is managed by a national agency. In South Korea, the EU, and the U.S., regulations that allow QR codes to be used for some labeling items have also been confirmed.

Other examples of digital tool use overseas include cases in which industry associations, NPOs, and private companies, in addition to the national government, are in charge of operation, as well as efforts to promote the use of digital tools, such as support functions for people who have difficulty operating digital tools and smartphone education for the elderly, etc. (For details, please refer to Subcommittee Document 5 (in Japanese).)

Domestic Initiatives

Based on the results of the Consumer Affairs Agency’s survey project conducted in FY2020 and FY2021, the technical issues that should be considered in the future were listed. Some of the specific issues are summarized below. (For more details, please refer to the Subcommittee Document 4 (in Japanese))

  • Format of food labeling data (unification of various standards for food labeling data, etc.)
  • Assurance of freshness and accuracy of food labeling data
  • Distribution method of food labeling data
  • Establishment of a mechanism for openness of food labeling data (a mechanism to promote the release and distribution of food labeling data).
  • Methods to uniquely identify processed foods
  • Present a step-by-step roadmap for data distribution

The use of digital tools in the provision of food labeling information is expected to increase in importance from the perspective of diverse consumer needs for food labeling, ease of understanding and visibility, etc., but there are still many technical issues to be cleared.

Future Schedule

The second and third subcommittee meetings are scheduled to report on the 48th Codex Alimentarius Commission Food Labeling Subcommittee meeting held from October 27, conduct interviews with related businesses, and discuss the direction of resolving technical issues. After that, based on the directionality discussed, the committee will continue to discuss the desirable form of digital tools and other issues.


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2nd Discussion on Initiatives for Easy-to-understand Nutrition Facts held (Japan)

The 2nd Discussion on the initiatives for easy-to-understand Nutrition Facts labeling (hereafter referred as to the Discussion)  was held on January 31, 2024. I would like to summarize the content of the second round of the Discussion based on the published materials.

What is the Front-of-Pack Nutrition Labelling (FOPNL)?

The published material 2 – titled the results of an interview survey of consumers- includes the situations of similar FOPNL systems in other countries, with some labeling examples.

Let’s take a look at the examples of voluntary labeling in France and Italy.

  • France-  A color-coded graded indicator, from dark green associated with the letter “A” for products with higher nutritional quality, to dark orange associated with the letter “E” for products with lower nutritional quality.
  • Italy-  Contents of energy, fats, saturated fats, sugars, and salt in a food are indicated based on the Guideline Daily Amounts (GDA)/ Reference Intake (RI). This system presents the amount of energy, fats, saturated fats, sugars and salt per portion in relation to daily reference intakes.

The 2nd Discussion

The second Discussion compiled some materials such as the voluntary efforts of food-related businesses in Japan, the results of an interview survey of consumers, and so on.

The material 1 titled the voluntary efforts of food-related businesses in Japan includes the backgrounds of the introduction of Front-of-pack Nutrition Facts labeling, and challenges that businesses might face in the event of the introduction.

The material 2 titled the results of an interview survey of consumers summarized
 the reasons why the current nutrition facts labeling is difficult for consumers to understand and some improvement proposals for easy-to-understand labeling. (e.g. Simplify the information to an appropriate level, Empower consumers to make their own informed choices, Use a unified logo/mark) Noticeably, the following is the included opinion about effective strategies for consumers to utilize Nutrition Facts labeling in daily dietary life by one of the committee members.

“The initiatives (for a food classification with a unified evaluation method and single nutrient-focused approaches which are taken in other countries) may not lead to creating a food environment that encourages informed choices by consumers as individual activities and health conditions have become more diverse.”

Future schedule

The 3rd Discussion will be held on March 12, 2024. Based on the content of the 2nd Discussion, I assume that measures to facilitate the use of nutrition facts labeling by consumers and to ensure the viability of food-related businesses will be discussed in the future.

Revision draft of Japan’s Specifications and Standards for Food Additives

On February 9, 2023, the Ministry of Health, Labour and Welfare (MHLW) published the 10th edition of Japan’s Specifications and Standards for Food Additives (draft). Under the provisions of Article 21 of the Food Sanitation Act, the specifications and standards and the standards for use of food additives shall be included in Japan’s Specifications and Standards for Food Additives. Since the first edition was published in 1960, it has been revised periodically until the Supplement 2 to the 9th edition of Japan’s Specifications and Standards for Food Additives published in July 2022. This time, I would like to summarize the main points of the revision draft of the 10th edition of Japan’s Specifications and Standards for Food Additives.

Background and Policy on the 10th Edition of Japan’s Specifications and Standards for Food Additives

Since June 2008 the Discussion meetings have been held for 12 times, during which

  • Requests for comments on the results of the discussions were made
  • The collected comments for the requests were discussed
  • Considering the above comments, the 10th edition of Japan’s Specifications and Standards for Food Additive (draft) was created.

This revision draft has been created reflecting the actual conditions of sales (and so on) by increasing the opportunities to solicit comments and to consider the issues.

Main points of the revision draft

The main revisions from the current 9th edition of Japan’s Specifications and Standards for Food Additives, Supplement 2 are from (1) to (9) as follows (draft).

(1) The specifications and standards (45 stipulated items) for 45 Existing food additives (Widely used as food over a long period of time in Japan) shall be newly established.

“Agrobacterium succinoglycan”, “Aspergillus terreus glycoprotein”, “Calcinated sea urchin shell calcium”, “Urushi Wax”, “Elemi resin”, “Sodium chloride-decreased brine”, “Rumput roman extract”, “Licorice oil extract”, “Enzymatically hydrolyzed guar gum”, “Quercetin”, “Glucosamine”, “Smoke flavourings”, “Gentian root extract”, “Spice extracts”, “Enzymatically modified lecithin”, “Rice bran wax”, “Cane wax”, “Artemisia sphaerocephala seed gum”, “Shellac wax”, “Jelutong”, “Sandalwood red” “Jamaica quassia extract”, “Vegetable carbon black”, “Essential oil-removed fennel extract”, “Horseradish extract”, “Calcinated coral calcium”, “Crude potassium chloride”, “Chicle”, “Tea extract”,  “Capsicum water-soluble extract”, “Trehalose”, “Coffee bean extract (paste and liquid)”, “Tricalcium phosphate”, “Hyaluronic acid”, “Phytin (extract)”,  “Branched cyclodextrin
 “, “Heptane”, “Gallic acid”, “Myrrh”, “Mevalonic acid”, “Japan wax”, “Mannentake extract”, “Rosin”, “Rosemary extract (water-soluble) ”, “Rosemary extract  (non-water-soluble) ”

(2) Regarding the specifications and standards of 2 Designated additives (approved by the Minister of MHLW) and 5 Existing additives, and 2 additive preparations, respective sub-specifications constituting the specifications and standards shall be specified as individual specifications.
*Please refer to “Regarding the establishment of the 10th edition of Japan’s Specifications and Standards for Food Additives” (pg1&2) for those additive names in the Reference below. (The same shall apply hereinafter)

(3) For the specifications and standards of 106 Designated additives (129 items), 58 Existing additives (85 items), and 2 additive preparations (3 items)
the followings shall be implemented;
-Improvement of test operability and accuracy
-Unification of names and structural formulas based on IUPAC nomenclature
-Unification of descriptions of terms, examples calculation formulas (and so on)
-Change of reagents used, etc.

(4) Elemental analysis and other test methods shall be newly defined as general test methods in “B. GENERAL TESTS”. For some existing general test methods, the used technology shall be updated, the apparatus/test solutions used shall be changed, the descriptions shall be maintained. Methoxy Determination shall be deleted.

(5) In the “C. REAGENTS, SOLUTIONS, AND OTHER REFERENCE MATERIALS” section, reagents in accordance with the provisions of the newly established General Tests and the specifications and standards shall be added, the old names of reagents shall be deleted, the items for each reagent shall be added/revised/deleted.

(6) The section on infrared reference spectra shall be deleted from “C. REAGENTS, SOLUTIONS, AND OTHER REFERENCE MATERIALS” and stipulated in each article of “D. MONOGRAPHS”.

(7) With regard to the sections “A. GENERAL NOTICES”, “B. GENERAL TESTS”, and “C. REAGENTS, SOLUTIONS, AND OTHER REFERENCE MATERIALS”
the followings shall be implemented;
-Improvement of test operability and accuracy
-Substitution of hazardous reagents for other reagents
-Unification of description methods of names and structural formulas, descriptions of terms/examples, (and so on) based on IUPAC nomenclature

(8) In the sections “E. STANDARDS FOR MANUFACTUREING” and “F. STANDARDS FOR USE”, “sand” and “insoluble mineral substance” shall be deleted and their specific substance names such as Pearlite, Granite porphyry shall be listed as shown in the table below.

the 9th edition of Japan’s Specifications and Standards for Food Additivesthe 10th edition of Japan’s Specifications and Standards for Food Additives (draft)
STANDARDS FOR MANUFACTUREINGTalc, Sand, Diatomaceous earth, Silicon dioxide or Magnesium carbonate, or similar insoluble mineral substances…..Talc, Diatomaceous earth, Silicon dioxide, Magnesium carbonate, Pearlite, Granite porphyry, Activated white clay, Cristobalite, Zeolite, or Vermiculite….
STANDARDS FOR USE…Acid clay, Kaolin, Bentonite, Talc, Sand, Diatomaceous earth and Perlite and similar insoluble mineral substances…..Acid clay, Kaolin, Bentonite, Talc, Diatomaceous earth, Perlite, Granite porphyry, Activated acid clay, Cristobalite, Zeolite and Vermiculite….

(9) Designated additives that have been newly designated or whose the standards for use have been revised since the creation of the Supplement 2 to the 9th edition of Japan’s Specifications and Standards for Food Additives shall be listed in “D. MONOGRAPHS” and the “F. STANDARDS FOR USE”.

Future schedules

Public comments on this issue are expected to be solicited, so keep an eye on the future move on the revision.

References


Newsletter Signup

We issue monthly e-newsletters, which provide you with the latest updates on food labeling/regulations in Japan.
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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.