On January 21, 2025, the 8th Subcommittee on Reviewing Labelling Rules for Each Individual Item* 2025 (Japanese) (hereinafter referred to as “the Subcommittee”) was held. In this article I would like to take up the proposed change in labelling rules application for spices used as ingredients.

The proposed change in the application of cross-sectional labelling rules for spices

Under the current cross-sectional labelling rules*, when spices and spice extracts make up 2% or less of the weight of all the ingredients in a food product, they can be grouped and labelled as “香辛料” (En: spices). If the total weight of the spices exceeds 2%, all individual spice names must be listed.

On the other hand, under the individual rules* for some food items (i.e. apart from the cross-sectional labelling rules), which are scheduled to be partially abolished, it is possible to list spices collectively as “香辛料” regardless of the total weight. Discussions have been progressing with the aim of reducing the inconsistencies and aligning with cross-sectional operations in the future. As more ingredients need to be listed according to the change, flexible adjustments to the rules will be required after the transition.

*In Japan there are two types of mandatory labelling standards.
-the cross-sectional labelling standards, which mean “horizontal” standards that are common to all foodstuffs
-the standards for each individual item, which mean “vertical” standards that are applicable to specific food items

The following change in the application of labelling spices rules was proposed at the Subcommittee, referencing the CODEX General Standard and the EU regulations.

• When spices and spice extracts make up 2% or less of the weight of all the ingredients, they can be grouped and labelled as “香辛料” as it is currently.
• When the total weight of spices and spice extracts exceeds 2%, the spices can be listed collectively under the term “香辛料” followed by parentheses. Inside the parentheses, spices are listed by descending order of weight. However, spices with lower weight percentages can be combined, starting with the smallest, until their cumulative weight reaches 2% of the total ingredient weight. Once this 2% threshold is met, these combined spices can be grouped and listed as “その他の香辛料”(En: other spices) within the same parentheses (see (Proposed change)* shown below).
• It is inappropriate to extract and list specific spice(s) individually in a way that ignores the weight order in order to emphasize them.

[Example case]: When the multiple spices shown below are used and the total from (3) to (8) is 2% or less (added together starting from the one with the lowest weight)

(1) ターメリック(En: Turmeric) (1.0%), (2) コリアンダー(En: Coriander) (0.8%), (3) カルダモン(En: Cardamom) (0.6%), (4) 赤唐辛子(En: Red chili pepper) (0.5%), (5) マスタード(En: Mustard) (0.3%), (6) クローブ(En: Clove) (0.1%), (7) シナモン(En: Cinnamon) (0.07%), (8) ローレル(En: Laurel) (0.03%)

The total of (3) to (8) is 1.6%

(Current labelling)

The following ways are possible.

1

ターメリック、コリアンダー、カルダモン、赤唐辛子、マスタード、クローブ、シナモン、ローレル (En: Turmeric, Coriander, Cardamom, Red chili pepper, Mustard, Clove, Cinnamon, Laurel)

2

香辛料（ターメリック、コリアンダー、カルダモン、赤唐辛子、マスタード、クローブ、シナモン、ローレル） (En: Spices (Turmeric, Coriander, Cardamom, Red chili pepper, Mustard, Clove, Cinnamon, Laurel))

(Proposed change)　* in addition to (Current labelling)

The following ways become possible.

香辛料（ターメリック、コリアンダー、その他香辛料）
(En: Spices (Turmeric, Coriander, other spices))

香辛料（ターメリック、コリアンダー、カルダモン、その他香辛料）
(En: Spices (Turmeric, Coriander, Cardamom, other spices))

香辛料（ターメリック、コリアンダー、カルダモン、赤唐辛子、その他香辛料）
(En: Spices (Turmeric, Coriander, Cardamom, Red chili pepper, other spices))
…, etc.

*Business operators can, at their discretion, extract and list individual spice names in descending order of weight from the grouped “その他香辛料　(En: other spices)”.

Inappropriate example:

香辛料（ターメリック、コリアンダー、マスタード、その他香辛料）
(En: Spices (Turmeric, Coriander, Mustard, other spices))

Spices included in “other spices” must be extracted in descending order of weight, and it is not possible to extract and display only “Mustard,” which is ranked third in weight.

Summary

Currently, the guidelines for listing spices that exceed 2% usage are organized in the Food Labelling Standards Q&A (Processed-64)(Japanese). The Q&A is planned to be revised to show the measures to be taken based on the change.

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