How to be prepared for a new labeling system in Japan

As of May 30th 2014, surveys and discussions by the Japanese government are progressing on food labeling system in Japan, which include "Food Labeling Standards (processed foods and perishables)", "Nutrition Labeling" and "Function Claim".

The former two are about the revision of current food labeling regulations, while the latter is the newly proposed argument. Both of them will affect the workflow of the food labeling in the future. Here is the summary of discussions.

Influence on use and management of product specifications

How much influence will the expected changes have on product specifications?

"Product specification" is a document indicating percentage of ingredients, purpose of additives, allergen information, genetically modified food, etc. It is indispensable in the business of food labeling for the confirmation of ingredients or standards of additive use. As to "food labeling standards (for processed food and perishables)", in particular, we have to keep in mind that detailed issues including how to label allergy information, as well as standardization of terms and consolidations of each regulation, are also being discussed.

There is a possibility that the use and management of the product specification, which is very important on food labeling, need to be changed. Therefore, it is necessary to understand the following points in advance, for smooth business operations in the future.
(1)Need to change declaration manner
(2)Need to change the format of product specifications
(3)Need to make a second request of a product specification.

Expected changes in declaration manner

"Change of declaration manner" means that some information in the product specification is modified. In order to avoid errors in food labels, it is important to expect the possibility, at the stage of preparing a product specification, that some modifications might be required under the new system.

For example, the following points should be taken into consideration.
1. Separate declaration of compound ingredients.
2. (1) Exclusion of specified processed foods which don’t include specified ingredients or substitute declarations.
(2)Exclusion of substitute declarations for "egg white" and "egg yolk"

When you choose "separate declaration of compound ingredients", you might have to change even declaration manner of ingredient order in a product specification. "Exclusion of specified processed food which doesn’t include substitute declaration" will require thorough declaration of allergen information in a product specification. (Even if "mayonnaise" is declared on an ingredient list, "egg" is also required to be declared on the allergen list. Otherwise it might be considered as an error.)
Meanwhile, since "standardization of terms (e.g. "fat" "meat") is proceeding, we recommend that you check whether the terms related to your products are on the discussion.

Expected change of the format of product specifications

"Change of the format" means that items to be declared in a product specification are modified. For example, "sesame" and "cashew nuts" were added to the allergens last year. In this case, a change of the format, such as additional rows and columns to the existing list of "allergen", is required" The increase of nutrition facts to be labeled will also need this type of change.

Additional nutrients recommended on the nutrition facts panel: "saturated fatty acid" and "dietary fiber"

In this case also, additional rows and columns in a product specification will be needed. As far as seeing current discussions, a format which has space for declaration of "sugar, trans-fatty acid and cholesterol" might be required. So we recommend that you have enough space for declaration of nutritional information. There is another discussion which might require setting new information items, not just changing the format.

- Making new regulations on additive-free claims
- Disclosure of information about the results of product analysis conducted for the purpose of ensuring safety (functional foods).
- Disclosure of information about the experimental proof by appropriate research review and by clinical trials, using final products (functional foods).

Expected second request of a product specification

Finally let’s see the case where a second request of a product specification from a supplier might be expected because of the modification of the recipe itself or other reasons.

Declaration of the address of a factory and the full name of a manufacturer is being discussed as the general rule. (Under the current labeling standards, ID code can represent them, but it will be considered as an exception under new standards.)

According to the revision, the following are being discussed:
- In principle, the use of ID code shall be allowed when the same products are made and sold at two or more than two manufacturing sites".
- A New ID code database shall be built so that consumers can search for the information concerned".

The revision involves the possibility that some manufacturing sites might be changed. So it will be necessary to specify the products which have only one manufacturing site, among the products which have both "manufacturer’s name and ID code".

These issues are still under discussion, and many of them will need a lot of time to deal with. We recommend that you should confirm first the arguments concerning the new system from the viewpoints of "format of product specification", "management flow" or "quality control policy" etc., which are unique to each company.

June 2014