On June 13, 2025, the Consumer Affairs Agency (CAA) announced the launch of a public comment period on the Cabinet Office Ordinance (Draft) to partially amend the Food Labelling Standards (Japanese).

For Foods with Functional Claims (FFC)*, the use of wording that highlight ingredients other than functional ingredients (with some exceptions) is prohibited.

The proposed amendments (Articles 9 and 23) are planned to revise this rule to permit certain indications such as those stating the absence or non-addition of specific ingredients. (e.g. “no XX added“ or “does not contain XX”). However, claims that emphasize the presence of ingredients other than the notified functional ingredients (excluding nutrients listed in Column 1 of the Appended table 9) will remain prohibited.

* The FFC system is a notification-based system in which business operators submit information to the Commissioner of the CAA, including scientific evidence supporting the product’s safety and claimed functionality.

Prohibited Labelling Items under review

Before the amendment	Except in cases where labelling is permitted under Article 7, such as claims on nutrient supplementation or claims on the appropriate intake of nutrients/calories, wording for claims on ingredients other than the functional ingredients notified to the Commissioner of the CAA (including nutrients listed in Column 1 of Appended table 9)
After the amendment	Wording for claims on the presence of ingredients other than the functional ingredients notified to the Commissioner of the CAA (excluding nutrients listed in Column 1 of Appended table 9)

With the amendment, it is expected that FFC will also be allowed to label claims on ingredients with no established criteria for appropriate intake, in the same way as general foods. Note: The public comment period closed on July 14.

On June 25, the CAA released a document titled Review of labelling rules for individual food items originating from the former Food Sanitation Act (related to Appended table 19 and 20 of the Food Labelling Standards) (Japanese) as a material for the 1st Fiscal 2025 Food Labelling Discussion Meeting (Japanese).

Labelling requirements stipulated in Appended table 19 and 20 are mainly based on Specifications and Standards for Foods, Food Additives, etc., which are derived from the former Food Sanitation Act. The labelling requirements are scheduled to be reviewed, together with the rules for individual food items derived from the former JAS Act, by the Subcommittee for the Review of Labelling Rules for Individual Food Items.

Examples from Appended Table 19 (excerpt)

Food	Labelling Item	Labelling method
Meat products	pH and water activity	Indicate the value with symbols such as “pH” for hydrogen ion exponent Indicate the value with symbols representing water activity
Frozen foods	Whether or not the product was heated just before freezing	Indicate whether the product was heated immediately before freezing (e.g. “Heated before freezing”)

The food items subject to review include a wide range of products such as meat products, milk, dairy products, foods made primarily from milk or dairy products, frozen foods, packaged foods sterilized by heat under pressure, and canned foods. For details, please refer to the materials. It should be noted that fresh foods are excluded from the scope of the review.

After consideration of the proposed amendments, the revised rules are expected to take effect concurrently with the rules for individual food items derived from the former JAS Act. The implementation schedule, including the Japanese version of the Front-of-Pack Nutrition Labelling (FOPNL) guidelines, is outlined in the material Future Proceedings (Japanese), so it is recommended to check it as well.

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