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New labeling regulations in Japan (Final proposal): Public comment is invited

On June 25, 2014, the Food Labeling Consolidation Review Committee of the Consumer Affairs Agency has put forward the final proposal on the creation of new food labeling law, including mandatory nutrition labeling, and the Agency will invite public comment by the end of July.

Major modifications:

The following are the major changes to Japan’s food labeling regulations:

<< Consolidation of standards >>

  • Consolidation of laws for food labeling
  • Change in labeling rules for ingredients listing, etc.
  • Providing a clear definition of "processed foods" and "fresh foods"

<< Nutrition facts >>

  • Mandatory nutrition labeling for processed foods
  • Change in the rule of nutrition claim

<< Others >>

  • Change in allergen labeling rule
  • Change in Manufacturer’s ID code rule
  • Change in labeling format rule (usable space for labeling)

Expected impact on the labeling process

With the consolidation of existing food labeling laws, the listing order of ingredients for bread, cooking vegetable oil, salad dressing/non-oil salad dressing, and flavor seasonings is expected to be changed -which currently list all ingredients in descending order by weight.
They will be required, however, to list food ingredients other than food additives first in descending order by weight, followed by the list of food additives in the same order, as with other foods.

Given that a separate declaration of compound ingredients is to be permitted, those businesses introducing self-imposed rules on labeling of compound ingredients will be required to consider a response on the change.

As for nutrition facts, "salt equivalent" information may have to be listed instead of "sodium" on the label. The final proposal also specify the changes in terms of nutrition claims:
the requirement of absolute difference when relative claims are made on the label, and claims that are newly required to make up relative difference.

Furthermore, a new regulation on “Free” claims such as "sugar free" and "sodium salt free" has been proposed, and an additional process would be required to determine whether the claim made complies with those requirements.

The immediate impact on food labeling process may be allergen labeling. When it comes to specified processed foods (e.g. mayonnaise) as well as the ingredient name that includes the name of specified processed food (e.g. mustard mayonnaise) , the mention of "mayonnaise", for example, only on the label will be no longer valid, and the mention of "egg" will become mandatory along with the "mayonnaise".

The declaration of allergens in brackets immediately after each ingredient name will become a general rule of allergen labeling, while the use of additional allergen statements in brackets (e.g., "Contains: milk, egg, peanuts, etc.") at the end of the ingredients list may be permitted in exceptional circumstances.

As for the additional allergen statements at the end of ingredients list, for example, even if "wheat" is listed in a product’s ingredient list, "wheat" will have to be identified again in the list of allergens in brackets at the end of the ingredients list.

July 2014