In Japan there are two types of mandatory labeling standards.

1. the cross-sectional labeling standards, which mean “horizontal” standards that are common to all foodstuffs
2. the standards for each individual item, which mean “vertical” standards that are applicable to specific food items

On May 29, 2024, the 1st Subcommittee on Reviewing Labeling Rules for Each Individual Item* (Japanese) (hereinafter referred to as “the Subcommittee”) was held. Subsequently, the 2nd Subcommittee (Japanese) was held on June 18. This time, we would like to summarize the review of labeling rules for individual items that has currently been being discussed based on the published material (Japanese).

*The Subcommittee was set at the Fiscal 2023 Food Labeling Discussion Meeting (see our past article and details below)

Background of the discussion

Following the Fiscal 2023 Food Labeling Discussion Meeting, there have been ongoing efforts to develop a rational and easy-to-understand food labeling system that aligns with international standards. The labeling rules for each individual item, which was taken up as a major topic at the Fiscal 2023 Food Labeling Discussion Meeting, have not been fully reviewed since 1999 when the cross-sectional labeling standards were formulated. Given that some of these standards for individual items may have already fulfilled their intended purposes, the Subcommittee planned to hold hearings with relevant industry groups for each item and assess whether these rules are still necessary and if any revisions are needed.

Items to consider

The necessity and rationale behind each labeling item are planned to be reviewed. Here are some specific examples for the items to be considered ,sorted by their category in the Food Labeling Standards (Japanese). (see the details in the Subcommittee material 3 (Japanese))

Appended Table 3 Standards of identity	Is it in line with the current situation and the times? Whether the current standards of identity can impede the development of new products?
Appended Table 4 Labeling rules for individual item (Legal name, Ingredients list, Additives, Net weight)	Whether the stipulated names match the actual market/consumer needs situation? Difference between the labeling rules for individual items and the cross-sectional labeling standards for an ingredient list Labeling of additives with nutritional fortification purposes Labeling unit for net weight, etc.
Appended Table 5 Rules for Legal names	To be considered together with the forementioned Standards of identity
Appended Table 19 Additional labeling items	To reconfirm if these additional labeling items are still necessary in light of the evolving social circumstances
Appended Table 20 Labeling style	Labeling location/ style To be considered together with the forementioned Additional labeling items
Appended Table 22 Prohibited labeling items	If prohibited labeling items for individual items are removed, labels will be judged based on the cross-sectional rules for prohibited labeling for each product and the Act on Unjustifiable Premiums and Misleading Representations, so the reasonableness of such judgments should be examined.

Future schedule

The revision process of the Food Labeling Standards will involve creating revision proposals for multiple food items collectively, while considering opinions from hearings and other sources. The process then will be proceeded through established procedures, including conducting public comments and consulting the Consumer Commission, before finalizing the revisions.

Multiple hearings will be held as the discussion progresses. Following these procedures, a certain conclusion will be expected to be reached for all the items within two years, that is: from FY2024 to FY2025. However, if more time turns out to be needed for further consideration, the review process will continue beyond this timeframe. In such cases the additional time of the review will be notified. We recommend keeping an eye on the time schedule for the review (Japanese) for any updates or changes to this schedule – we will also inform of progress as much as possible in this newsletter.

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