Author Archives: Hiroyuki Tanimoto

About Hiroyuki Tanimoto

Label bank Co., Ltd. Regulatory inspections and Consulting Research staff Born in Japan. Has a long experience in the food manufacturing industry. He is engaged in research work on both domestic and imported food ingredients and additives as well as provides consulting services on food standards, additives compliance, and food labeling.

Amendment to Guidelines for setting date labelling on foods (Japan)

In March 2025, the Consumer Affairs Agency (CAA) amended the Guidelines for setting date labelling on foods (Japanese).

This update stems from the Policy package toward achieving food loss reduction targets (December 2023) (Japanese), which called for a review of the previous guidelines (February 2005) (Japanese) to examine current practices for determining date labelling and applying safety factors*, with the aim of reducing food loss.

*A safety factor is a numerical coefficient, typically less than 1, applied to the scientifically determined shelf life or quality retention period of a food product to set a more conservative date label.

(1) Setting of “Use-by” or “Best-before” dates

The fact-finding survey revealed cases where the distinction between “use-by” and “best-before” dates was made solely based on a five-day rule*, without considering their definitions (Japanese).

According to the definitions (stated below) “use-by” or “best-before” labelling should be applied based on the product’s characteristics.

  • A “use-by” date should be set primarily based on the results of safety-related tests and inspections, such as microbiological testing
  • A “best-before“ date should be set primarily based on the results of quality-related tests and inspections, such as physicochemical analyses and sensory evaluations

* When date labeling was introduced in 1995, it was notified that expiration dates should be distinguished between “used-by” dates and “best-before” dates, depending on whether the expiration date is within 5 days or beyond 5 days from the date of manufacture. However, this distinction of “5 days” was removed in 2008.

(2) Establishing objective items (indicators) and criteria according to food characteristics

According to the guidelines, those responsible for labelling should have the deepest understanding of their food products’ safety and quality. They must also independently establish objective items (indicators) and criteria for setting date labels, using scientific and rational methods that consider each food item’s specific characteristics and storage conditions.

The fact-finding survey showed that some date labels were set unnecessarily short because general hygiene indicators, such as total viable count, coliform group count, and Escherichia coli count, were used for evaluation without considering the food’s specific characteristics.

Instead, appropriate items (indicators) for each food item such as psychrophilic or anaerobic bacteria need to be chosen based on the hazard factors identified through HACCP.

(3) Setting an “appropriate safety factor” based on food characteristics

When determining date labelling, the former guidelines stated that a safety factor of less than 1 should be applied to shorten the period derived from the objective indicators depending on the characteristics of the food.

Additionally, the former Food Labelling Standards Q&A (Processing-22) stated that the safety factor should be set at 0.8 or higher as a guideline for products with minimal variation in quality.

However, the fact-finding survey found out that about 40% of products had safety factors set below 0.8. Even in cases where food safety was already well ensured, the safety factor was applied regardless of the product’s characteristics.

The new guidelines, while still recommending a safety factor of less than 1, advise moving it closer to 1 depending on the food’s characteristics, and state that for products such as retort-pouch foods and canned products, a safety factor no longer needs to be considered.
(the new Food Labelling Standards Q&A) (Japanese)

(4) Others

The guidelines encourage those responsible for labelling to make every effort to provide information on how long the product is likely to remain safe to eat when stored under the specified conditions upon request from consumers or others.

These guidelines are a recommended reading, as they provide useful information for setting date labels and contributing to food loss reduction efforts.

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Outline of the Cabinet Office Ordinance (Draft) to partially amend Food Labeling Standards in accordance with the revision of the system for FFC (Japan)

Note: The current system of foods with functional claims (FFC) is summarized in a leaflet in English.

The Consumer Affairs Agency (CAA) recently solicited opinions on the Cabinet Office Ordinance (Draft) (Japanese) to partially amend the Food Labeling Standards (Japanese) in accordance with the revision of the system for FFC. (from June 27 to July 26, 2024)

The point of the proposed amendment is to revise the definition of FFC (Article 2) and clarify its requirements. The draft also proposed to add the Appended Table 26 and 27 to the Standards, which would stipulate notification items for FFC and matters to be complied with after the notification.
Foods that do not meet these requirements are to be considered violations of Article 9 of the Food Labeling Standards under the Food Labeling Act.

Here is the summary of the new proposed requirements for FFC.

  • The CAA will be able to prohibit the labeling of foods with no adequate scientific backing; in other words, those not recognized by the Commissioner of the CAA as appropriate for functional claims based on sufficient scientific knowledge.
  • As matters to be complied with after notification, the following four items have been added.
    1. Report any new scientific findings related to functionality and safety to the Commissioner of the CAA
    2. Maintain quality control (compliance with Good Manufacturing Practice (GMP) for tablets, capsules, and other foods made from natural extracts)
    3. Report information on any health hazards (limited to those diagnosed by a physician. Report it promptly even if the causal relationship with the food in question is unclear)
    4. Report the results of self-checks of these above-stated compliance items to the Commissioner of the CAA annually
    Public comments for the GMP standards (draft) (Japanese) were also solicited until Augst 16 and the content is briefly explained in the other article.
  • The notification items are based on what was stipulated in the Guidelines for submitting a notification of foods with function claims (Japanese) and further clarifies this stipulated content in accordance with the Cabinet Office Ordinance. The GMP standards for “tablets, capsules, and other foods made from natural extracts” have been newly established.
  • The method of labeling the notification information on the package has also been reviewed to prevent misidentification as a pharmaceutical product, to differentiate it from Foods for Specified Health Uses, and to provide information on safety and functionality to consumers.

The main points of the revision of the labeling method on packages (Article 3, Appended Table 22) are as follows.

  • The labeling for FFC shall be indicated in a frame at the top of the main surface.
  • The notification number shall be indicated in a position close to the label of FFC.
  • The [Reference Material 4]  (Japanese) (the 74th meeting of the Food Labeling Subcommittee) gives easy-to-understand examples of the labeling on functional claims (Functionality of foods containing functional ingredients and the ingredients themselves, supported by scientific evidence) such as,
    -It will no longer be allowed to indicate part of the functionality
    -For functional ingredients of which the notification is based on a research review, indicate “it has been reported that XX (effects on health)”

The following is a proposed revised labeling example of food products for which notification was made based on the research review of functional ingredients in [Reference Material 4] (The example is for fresh foods, but the revised parts can be applied to other foods, too. Changes are in red).

Lastly, the enforcement date is summarized in [Reference Material 3] titled Review of the FFC System and the enforcement date (Japanese) (Some of the revision draft will be enforced on September 1, 2024).  The content of the draft may be slightly revised based on public feedback. Businesses that have notified FFC or plan to do so should pay close attention to future developments.

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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.