This article continues the previous article, Summary of the status of legal changes on food labelling in Japan (1).

The Food Labelling Advisory Committee (held on 13 December 2024) (Japanese) reviewed the draft amendment to the standard values for nutritional labelling. At the meeting, the progress of reviewing the labelling rules for each individual food item (from the 1st to the 7th meeting) by the subcommittee was also reported.

Amendments of the standard values for nutrients labelling

The standard values for nutritional labelling will be revised based on the Dietary Reference Intakes for Japanese (2025 Edition) published by the Ministry of Health, Labour and Welfare (11 October 2024). Some standard values for nutrient labelling, such as those for calcium and vitamin D, will be increased. For further details of the amendment, please refer to the Draft Amendment to Nutrition Labelling (Japanese). With the revision of standard values for nutrient labelling, the standards for nutrient content claims (such as “contains,” “high in,” and “fortified with”) are also expected to be updated. Therefore, business operators who use these claims on their products should ensure they comply with the new standards.

Review of labelling rules for individual food items

The review has been made to align with the “horizontal” standards that apply to all foodstuffs. Some opinions and requests have been presented at the discussions so far, such as: “There were food items for which individual rules were already abolished (7 out of 22 items already discussed by the subcommittee)”, “Definitions and names under the labelling rules for each individual food item should remain on the label“, “It is preferable to maintain the individual labelling rules according to the characteristics of the food item“, etc. For details, refer to The Sub-Committee for the review of labelling rules for individual products (Japanese). The remaining 22 items with current individual mandatory labeling will continue to be reviewed by the subcommittee and will be reported to the Advisory Meeting in the next fiscal year (March 2026).

Regarding the items to be revised and future steps

The anticipated amendments to the Food Labelling Standards are outlined in the Advisory Meeting materials titled Regarding the Amendments of Food Labelling Standards (Japanese). This document includes the specific Articles and Appended Tables that are subject to revision. Here is an excerpt from the material.

1. Mandatory labelling of additives for nutritional fortification purposes
   Article 3, Paragraph 1
   Appended Table 4 – Labelling rules for individual food item
   (Legal name, Ingredients list, Additives, Net weight)
   Appended Table 24 – Individual labelling items for general fresh foods
   
2. Amendment of the standard values for nutritional labelling
   Appended Table 9 – Units for labelling nutritional components and energy, measurement methods, tolerance ranges, and contents that can be labelled as “zero”
   Appended Table 10 – Standard values for nutritional labelling
   Appended Table 12 – Standard values for claims on nutrient supplementation
   
3. Review of labelling rules for individual food items
   Appended Table 3 – Standards of identity
   Appended Table 4 – Labelling rules for individual food item
   (Legal name, Ingredients list, Additives, Net weight)
   Appended Table 5 – Rules for legal names
   Appended Table 19 – Additional labelling items
   Appended Table 20 – Labelling form
   Appended Table 22 – Prohibited labelling items

A public consultation on the draft amendments to the Food Labelling Standards is expected to take place within this fiscal year (until March 2025). Although the exact timeline for the amendments remains uncertain*, it is believed that changes to allergen labelling, including adding cashew nuts to the mandatory list, are being considered. As such, it would be a good time to begin preparing for these anticipated changes.

* The amendments are now scheduled to enter into force on 1 April 2025. The public consultation on the amendments closed on 28 January 2025.

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