Author Archives: Minami Yoshikawa

About Minami Yoshikawa

Label bank Co., Ltd. Regulatory Review and Development Born in Japan. Specializing in nutrition, she is engaged in research work on ingredients and labeling drafts for food products distributed mainly in Japan, as well as consulting.

Fourth FY2023 Food Labeling Discussion Meeting And Third Discussion on Initiatives of Easy-to-understand Nutrition Facts held (Japan)

The fourth Fiscal 2023 Food Labeling Discussion Meeting

The fourth Fiscal 2023 Food Labeling Discussion Meeting was held on the 7th of March, 2024. The document Draft Summary of Fiscal 2023 Food Labeling Discussion Meeting provides a summary of the discussions held in the first three meetings. Here are the main points of the document.

Summary of the discussions and the general direction that food labeling should aim for in the future

1. Consistency of food labeling systems with other countries

The document concluded that it would be crucial to engage in comprehensive discussions from various viewpoints to ensure clear information for consumers and feasibility for businesses as well as to consider the differences in food labeling between Japan and other countries. It also mentioned that going forward, efforts would aim to align Japan’s food labeling systems with international standards as much as possible, while taking into account Japan’s unique situation. As for additives, the variations in their regulations between Japan and other countries primarily stem from differences in a wide range of their specifications and standards, extending beyond mere labeling systems. Therefore, a comprehensive review including an approach to the Codex Committee and other bodies is considered necessary in light of the transfer of some food sanitation administration from the Ministry of Health, Labour and Welfare (MHLW) to the Consumer Affairs Agency (CAA).

2. About labeling rules for individual items

The rules that were previously established for individual items in the JAS Law have been transferred to the Food Labeling Standards without sufficient discussions during the food labeling integration process. Reviewing these rules towards a more cross-sectional approach is considered needed. Some committee members pointed out that it would be necessary not only to compare the rules for each individual item, but also to consider the background and history of the rules, as well as to review the rules periodically, and to proceed with discussions after listening to the opinions of industry groups. In the future review, the discussions will continue based on the following points
– To distinguish the roles between the JAS, the Fair Competition Codes, and the Food Labeling Standards based on their respective characteristics
-To enhance clarity for customers
-To minimize burdens on businesses

3. Utilization of digital tools for food labeling

The use of digital tools to replace some of the labeling information printed on containers and packaging should be considered in terms of global trend, technological advancement, and readability of food labels. Taking the following factors into account, it is necessary to carefully examine which information should be indicated on packaging and which information can be provided alternatively through digital tools.
-Limited labeling area and readability
-Actual usage of labeled information
The Codex Committee’s discussions on the use of digital tools should also be considered in this process. However, there are concerns about the high-cost burden for businesses and the technical challenges of managing and providing product information. Therefore, discussions will continue while taking these issues into account.

Enforcement date for the revision

Future plans are mentioned in the Time Schedule (Draft) for Future Proceedings of the Food Labeling Discussion Meeting. Although no specific date for the enforcement has been given so far, it is expected to reduce the burden on businesses by setting sufficient transitional periods for each revision and align the end dates of these periods as much as possible. This will make revisions to food labeling regulations more predictable and reduce the need for repeated revisions.

The third Discussion on Initiatives of Easy-to-understand Nutrition Facts

On March 12, 2024, the Third Discussion on initiatives of Easy-to-understand Nutrition Facts was held in Japan. The meeting discussed the basic direction of the Japanese Front-of-Pack Nutrition Labeling (FOPNL) system, and the interim report was compiled.

  • The Japanese version of the FOPNL will be positioned as voluntary labeling and certain rules for it will be established.
  • The amount of nutrients to be labeled must be equivalent to the mandatory labeling (calories, protein, fat, carbohydrates, and salt equivalent).
  • The nutrient contents must be indicated as a percentage to Nutrient Reference Values for the target nutrients.
    (In light of the revision of the Dietary Reference Intakes for Japanese (2025 Edition), the nutrient labeling criteria will be reviewed by FY2024.)
  • The food unit must be based on the amount of one serving of the food and the amount per one serving must be labeled.

Upcoming schedules

The Food Labeling Discussion Group on individual product rules and digital tools will be held in a subcommittee format from next fiscal year. In addition, a separate forum meeting (Initiatives of Easy-to-understand Nutrition Facts) will be established to discuss the FOPNL system because this issue involves specialized nutritional contents. Businesses are encouraged to review the announcement to stay up to date on future developments.

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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.

Labeling Method in Accordance with the Revision of the labeling system for genetically modified foods (Japan)

As of March 31, 2023, the transitional period for the revision of the conditions for the voluntary labeling of “non-GM” will end. This time, we have reviewed the revised labeling method.

Main points of revision

  • The requirements to label “non-GM” will be made stricter from their current state (i.e. unintentional presence of genetically modified soybean/corn shall be equal to or less than 5%*1) to “not detected.”
  • In the case of 5% or less contamination, voluntary labeling indicating “separate production and distribution management (IP handling) is appropriately implemented”*2 is allowed.

Notice:
*1 Unintentional presence of material: Certain contamination of genetically modified agricultural products at a certain level even under proper IP handling.
*2 IP handling: Genetically modified agricultural products and non-genetically modified agricultural products are properly handled so as not to be mixed with each other at each stage of production, distribution and processing from farms to food business operators, and this process is certified by documents and so on.

Specific examples of labeling after the revision

The following are three examples of labeling for genetically modified soybeans.

(1) When non-segregated soybeans are used as ingredients

<Labeling examples>
-Soybean (Not segregated from GM product)

If GM and non-GM agricultural products are not segregated, labeling is mandatory. Words other than “Not segregated from GM product” may be used as long as consumers can understand from the label that the ingredient is “not segregated”. As a means of correctly conveying information to consumers, providing an explanation of the meaning of “not segregated” outside of the mandatory labeling frame will help consumers to understand the term “not segregated” correctly.

(2) When Soybean (with 5 % or less of unintentional contamination with GM products after IP handling was properly implemented) is used

<Labeling examples>
-Soybean
-Soybean (handled to prevent contamination with GM products)
-Soybean (IP handling implemented)
-Soybeans used as ingredients are handled under IP handling to prevent contamination with GM products*
*These are some examples of labeling outside the frame where mandatory labeling items are grouped together.

It is possible to indicate “IP handling is properly implemented” voluntarily.
In that case, it is necessary to clearly indicate that GM agricultural products and non-GM agricultural products are separately handled at each stage of production, distribution, manufacturing, and processing.

(3) When soybean (confirmed as non-GM after IP handling was properly implemented) is used

<Labeling examples>
-Soybean (Non-GM)
-Soybean (Not genetically modified)

“Non-GM” labeling will be allowed only for soybean, corn, and processed foods made from these products as ingredients whose IP handling has been properly implemented and are found to be free of GM agricultural products. It should be noted, however, that if the scientific and social review conducted by the administration confirms that the used ingredient contains genetically modified agricultural products, the labeling will be inappropriate.

At present, the following are considered valid to confirm that no GM products are mixed in agricultural ingredients.

  • Agricultural products verified to be free from contamination with GM products at the place of production are packed in bags or their dedicated containers, transported, and opened for the first time by manufacturers
  • The products are certified to meet all the following conditions
    • Grown in Japan, or in countries that have never practiced commercial cultivation of GM agricultural products
    • Confirmed and proven that the product is not mixed with imported products from countries where GM agricultural products are grown (including the cases where IP handling is properly implemented and also the contamination is controlled to be 5% or less) in the process of production or distribution
  • In the process of production or distribution, each business operator proves that GM products are not contained and the trades by such business operators are conducted using a certificate of IP handling stating that GM agricultural products are not contained

Overview

Please note that “non-GM” labeling is only allowed when GM agricultural products are proven as “not contaminated”. As there is only a short period of time left for transition, I think it is a great opportunity for businesses that handle the applicable labeling to reconfirm their labels.

Reference

Food Labeling Standards Q&A Attached Items regarding genetically modified foods

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.