More than six months have passed since Japan ‘s Food Labeling Standards were revised on March 28, 2024, adding macadamia nuts to the list of recommended allergen labeling items (while also removing matsutake mushrooms). Since the number of 28 items (8 mandatory and 20 recommended) remains the same, it is difficult to see the changes as far as containers and packaging are concerned, but we believe that the situation is gradually being addressed. In this issue, we would like to extend our scope to outside Japan and look at some of the revised information on allergen labelling that was announced worldwide this year.
In February 2024, the Australian Department of Agriculture, Fisheries and Forestry (DAFF) and the New Zealand Ministry of Primary Industries (MPI) announced that new allergen labeling requirements ( DAFF Notice and MPI Notice ) had come into effect. Changes include labeling allergens in bold, labeling “contains 00,” and more. The transitional period is until February 25, 2026.
In July 2024, the Food and Drug Administration (FDA) of the Thai Ministry of Public Health promulgated and implemented the “Labeling of Prepackaged Foods (No. 450)” (original in Thai). The English version has also been published. Shellfish, mollusks and their products were added to the list of items subject to allergen labeling. The transitional measures period is until July 19, 2026.
In August 2024, the Saudi Food and Drug Administration (SFDA) published a draft standard for Labeling of Food Allergens on Prepackaged Food. In addition to a list of items subject to allergen labeling, the draft also shows how to label items by bolding, underlining, and highlighting in color, as well as by using illustrations with accompanying text.
In September 2024, the UK Food Standards Agency (FSA) released an update on its work on Precautionary Allergen Labelling (PAL). We previously covered developments in PAL in the U.K. (in our issue of November 2023); this latest update makes public further proposals for the use of allergen thresholds (standardization by ‘Eliciting Dose’ (Note) ).
(Note: This is a unit known as the one to indicate the amount of allergen that causes a reaction with objective symptoms (abbr. ED). Please go to the link above: “update on its work on Precautionary Allergen Labelling (PAL)” for the details.)
Also, by the end of 2024, the U.S. FDA is expected to release a draft guidance for the industry titled “ Questions and Answers Regarding Food Allergens, Including the Food Allergen Labeling Requirements of the Federal Food, Drug, and Cosmetic Act: Guidance for Industry.”
The above is simply a general overview of examples of recent changes from various countries around the world. It should be noted that the Thailand case is a comprehensive revision of the labeling standards. Other examples of comprehensive amendments to labeling standards include Malaysia’s Food (Amendment) (No. 4) Regulations 2020 (January 2024) and Turkey’s Food Codex Regulations Amendment on Consumer Information and Food Labeling (April 2024).
On a further note, the Codex Alimentarius Commission is currently discussing allergen labeling, and in August 2024, will begin soliciting opinions on “General Standard for the Labelling of Pre-packaged Foods Provisions relevant to allergen labelling” and “Guidelines on the use of precautionary allergen labelling”. In particular, reference doses (mg/kg) standardized based on induced doses will be set for each item (e.g., almond 1.0, peanut 2.0, hazelnut 3.0, wheat 5.0, buckwheat 10, crustacean 200) for preventive allergen labeling (PAL), and the proposed revisions clarify the threshold values, which is a trend that we believe will require close attention. The allergen labeling system is expected to change in the future in line with changes in consumer behavior and technological advances. If you are considering exporting food products to foreign countries and are interested in future trends, it would be a good idea to check the proposed amendment.
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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.
Label bank Co., Ltd. CEO (Founder)
Born in Japan. Working on solving various issues related to food labeling operations. Also regularly gives lectures for various organizations in Japan.
Co-author of ‘Latest edition: Guide book Food Labeling Law and related business practical points – from scratch (Japanese version only)’ (DAI-ICHI HOKI CO., LTD/2019).
