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Keywords to be noted in the future: "The disclosure of information" and "The management of evidential data"

Going through all the proposals provided for the consolidation of laws for food labeling as well as for New Functional Labeling System, we have been noticing a certain trend. We would like to discuss the trend in this newsletter.

Notification of manufacturer’s ID code and evidential data of function claims

The review of manufacturer’s ID code system in the proposal of new labeling standards includes some thought-provoking passages, in the light of the trend in the future: “to impose a duty to respond to inquiries from consumers”, “to build the database of new manufacturer’s ID code for the Consumer Affairs Agency, which allows consumers to access the relevant information”, just to name a few.

The final proposal for New Functional Labeling System also mentions as follows: “Notification of product information including evidential data as to the safety and health effects of products”, “Before product sales, the Consumer Affairs Agency publishes the information associated with products for which the notification has been made”.

A point to note is that those passages suggest keywords associated with transparency such as the “disclosure of information”. Although it remains to be seen how things will develop in the future, given the result of public comment, it is necessary to keep in mind that the Consumer Affairs Agency has put forward such a final proposal, and you follow the trend.

The timing of information disclosure

The disclosure of information is nothing new; there are many companies supplying information of their products through their websites or customer relations offices. There are two types of timing, in terms of publishing information: prior disclosure and post- disclosure. Prior disclosure includes information about the origin of ingredients, nutrition and allergens, for example provided on the website. Post-disclosure includes batch numbers, which will be required in case of trouble.

A point to be aware of is that prior disclosure would require regular updates on the information provided to ensure the consistency of information between actual products and the disclosed information (thus the maintenance of information is important), while post disclosure would require more of a swift response than the consistency of information.

The management and validity of evidence-based value data

In order to publish accurate information, a proper information management system must be developed, which provide evidential data that support the validity of the given information. For example, on September 27, 2013, the following clause was added to Nutrition Labeling Standards in Japan: “Store the evidential data associated with the values declared.”

The Nutrition Labeling Standards in Japan require nutrient values only obtained by analysis-which must fall within the specified tolerance limits-to be declared on Nutrition Facts label but it now allows values obtained by reasonable methods such as by calculation.

While the overall flexibility concerning food labeling has been increased, it is required to provide reasonable grounds, as outlined in the proposal on New Functional Labeling System. In brief, the new regulation is to lift the ban on claiming the effect that a substance has on certain parts of the body, on condition that you have factual evidence to support the function claims made on labels. We would like to talk about the disclosure of evidential data as a theme in this newsletter.

Increasing importance in data management

We have been discussing “The disclosure of information” and “The management of evidential data” as keywords to be noted. This is because we think it is important to develop a data and operational management system that connect those two keywords. Unless they are properly applied to actual business activities, it would be difficult to make the most of the information disclosed and evidential data stored. Effectively managing the information you own could be a big advantage for your business.

It is becoming a common practice for companies to handle a large amount of information including personal information; companies are enhancing information management, responding to demands from society, in which the information on food labels is included. Making products valued by customers, responding flexibly to changes in society, would be important.

September 2014