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"Revised proposal of food labeling standards" has been published

On September 23rd, 2014 "outline of public comment on food labeling standards (proposal)" has been disclosed, where summary of opinions and responses to them are provided (4,329 opinions have been sent to Consumer Affairs Agency). On September 24th, revised proposal of food labeling standards, reflecting public comment, has been presented by the Consumer Affairs Agency and discussion was held.

Main revised points from public comment are as follows:

As for small packaged foods

"L-phenylalanine compounds" should be added to the mandatory labeling items - (product name, storage method, use-by or best-before date, person in charge of labeling and allergen), which can't be omitted even though the possible labeling area is under 30 square cm.

This is to ensure the safety of the phenylketonuria patients. Furthermore, the name and address of the manufacturer has become the mandatory labeling items, even for sample products processed in a shop or bagged foods at the charity bazaar in an elementary school, where declaration of a person in charge of labeling can be omitted.

Modification which could have impact on business operation is the additional declaration of L-phenylalanine compounds. Usually it is labeled with the purpose of use, as "sweetener (aspartame, L-phenylalanine compounds)". So in case it is used as an additive, there is no big problem.

However, it would be better to suppose that you might be asked if there is a product with which aspartame itself is treated as a carry-over, because the revised proposal will be paid attention again.

Prolongation of transitional period

According to the revised proposal, transitional period (period of suspension until the perfect shift to the labeling based on the new standards, after the enforcement of food labeling standards) is prolonged. For example, as for processed foods, it became five years from two years. As for additives, five years from one year.

As for perishable foods, one-and-half year of transitional period has been introduced though there was no such period before. This seems to be the measures to lighten the burden which comes along with the implement of the new food labeling standards, which include review of the allergen labeling method, mandatory labeling of nutritional values, necessity of distinction between ingredients and additives. In order to meet the new standards, labels of almost all the products should be revised.

Meanwhile, the proposal of Consumer Affairs Agency gives "Database development for manufacturer's ID code system" as the background of prolongation of transitional period. They will request necessary amount for “Database development for manufacturer's ID code system”in the budget of fiscal 2015. After completing necessary preparation, they plan to enforce the system. Consumer Affairs Agency says that a large number of enterprises will begin to revise labels when the database is completed. From this point of view also, it can be said that the most important point of new labeling standards is "manufacturer’s ID code system".

Other revisions

Other revisions are as follows:

-As for manufacturer's ID code, "Foods for business use are excluded" has been added. This is the only amendment reflecting public comment. As public comment proposal says, it will be prohibited to label only "distributor" without manufacturing site on the products which are manufactured in only one facility. This revision will apply to a lot of products, as mentioned in the paragraph above.

-Exceptional rules for mandatory nutritional value labeling. Definition of "small enterprise" has been amended from "under 10 million of taxable sales amount" to "small enterprises as defined under the Small and Medium-sized Enterprise Basic Act".

As for enterprises with 20 or less than 20 employees, and commerce and service businesses with five or less than five employees, omission of nutritional value labeling will be permitted for the time being.

There are also some minor revisions regarding labeling of sodium and salt-equivalent amount. There is no change about mandatory labeling of salt-equivalent amount, however, it will be permitted to describe salt-equivalent amount in the parenthesis next to sodium, as the current labeling system does. (Note: the parenthesis notation is applicable only to food products with no sodium salts added.)

There is also a revision about "labeling in a relative manner" for nutritional claims. While 25% or more of relative difference has been necessary when labeling the reduction, only sodium has become the exception, that is to say, "salt reduction" can be labeled even if there is not exact figure of relative difference as for sodium.

Impact on consumers and enterprises

Looking through the revised proposal of food labeling standards, for example amendments such as a review of the allergen labeling method and labeling of manufacturing sites, it seems that the revision is advantageous for consumers as a whole. It is also well-balanced revision for enterprises since prolongation of transitional period and consideration for small enterprises are included.

Meanwhile, revision of manufacturer's ID code system might pose some problems and the impact on both consumers and enterprises. Food distributors, dealing with daily foods, have been increasing because they can label themselves as distributors, that is to say, they can develop original products even if they don't have their own manufacturing factories.

Attracting customers is the most difficult issue when starting a new business. It costs a lot to develop new customers. Distributors might face various problems including the lots for private brand products. Manufacturers might have to think over manufacturing in smaller lots or self-solution because they cannot operate business without distributors.

It is important to increase people who produce foods through agriculture, fishery and manufacturing. It is also important to increase those who start new businesses and sell groceries, from the viewpoint of whole society. How will enterprises deal with the revision of manufacturer’s ID code of this time? This is the question which each of us have to think about, because we will be influenced not only as a consumer but also as a citizen who lives everyday life.

October 2014