The trend of the food labelling system and main changes
In 2014, there were many movements on the food labelling system. As some revisions have been done in response to the Public Comments, we would like to sum up the revised points and organize information.
Major changes from the current situation
Major changes from the current situation, which come along with the foundation of food labelling standards, are as follows:
1) Fundamental parts
< General information >
- Clarification of the definition of: Processed foods (production, processing) and perishables (arrangement, selection)
- Separate declaration of (or clear division between) ingredients and additives
- Manufacturer's ID code can be used in case identical products are manufactured in two or more manufacturing facilities.
- The items "that can't be omitted even if possible labelling area is 30 cm2 or smaller" are increased. (L-Phenylalanine compound, etc.)
< Allergens >
- The name of specified processed foods (e.g.mayonnaise ), as well as the ingredient name that includes the name of specified processed food (e.g. mustard mayonnaise) can no longer be mentioned on food product labels without declaration (either individual or collective) of the allergen present in respective ingredient. Currently, "eggs" can be exempted from declaration if there is a declaration of "mayonnaise", but it won't be permitted under the new rule.
- Nutrional labelling is to be mandatory for every food relating business operator (Professional use and small-scale enterprises are excluded).
- Three divisions are to be placed: Mandatory, Recommended, and Voluntary Saturated fatty acid and dietary fiber are to be classified as "recommended".
- Amount of sodium is to be labelled by the salt-equivalent amount, however, both can be labelled (other than foods added sodium salt).
- Nutrient comparative claim is subject to Codex guideline (CAC/GL 23-1997）in principle.
- Addition of the rule regarding "Additive-free claims"
- Additional labelling standard regarding "stearidonic acid" derived (soybeans)" (GM food)
- Additional labelling standard regarding heating of cheese, fermentation temperature of fermented milk drinks (Cabinet Office Ordinance regarding milk, etc.)
2) Labelling standards of nutritional values and food with nutrient function claims (FNFC)
- Revision of labelling standards of nutritional values
- Addition of "n-3 fatty acid", "vitamin K", "Potassium" to the target ingredients of FNFC
- Perishables other than eggs are to be applied to standards of FNFC.
- "Foods with function claims" are to be specified within the food labelling standards.
- Documents with scientific evidence are to be submitted in advance to the Consumer Affairs Agency, which will disclose them to the public before distribution.
- Required scientific evidence and possible function claims are to be notified in the guideline hereafter.
Impact on the food labelling workflow.
Transitional period was also revised in response to the Public comments. It was prolonged to five years as for processed foods and additives, and to one year and a half as for perishables. Those who are involved in food label creating works have to prepare for, and deal with new system during the period above mentioned. Here are the summary of the expected impacts on the workflow:
1) At the stage of collecting ingredient specifications.
First of all, it seems that the careful attention will be needed to the changes regarding allergies. For example, it will lead to the unexpected error of food labelling if there is no declaration of "eggs" in the allergen list, while there is a description of "mayonnaise" in the ingredient list in the specification.
Careful attention should be required also when you refer to the backside labelling of processed foods used as ingredients, if there contained "specified processed foods", such as mayonnaise. Along with the change of Manufacturer's ID code system, it can be expected that the changes of manufacturing sites themselves and ingredient contents will be increasing. As the result, revision of workflow will become important in this stage, such as management of revised version.
2) At the stage of label creating
Along with the changes of allergen labelling, keeping the place for ingredient labelling will be needed. Furthermore, revised labels will be required for almost all foods, due to the added rule which require the labelling of clear division between ingredients and additives.
3) At the stage of product specification management
Some changes require the introduction of additional managing items. Labelling of salt-equivalent amount, additional labelling of recommended nutritional information (saturate fatty acid and dietary fiber), etc., will be applicable. Re-calculation of nutrients could be needed, depending on the contents of the revision of labelling standards of nutritional values.
4) Sustainable quality assurance
In addition to keeping the documents offering grounds for labelling of nutritional values, storage of documents with scientific evidence will become important when labelling function claims or similar claims (e.g. Good for beauty and health, etc.) In order to avoid misleading representations, it is necessary to decide on the flow of operations with regard to the quality assurance tasks, such as selection of documents for scientific evidence and regular inspections, in consultation with product developers.
Detailed guidelines and Q&As regarding new system will be presented this year. Arranging current workflow, it will be important to discuss how to deal with the new system. Although there are a lot of complicated matters, we hope that this will be a good opportunity for those who are involved in food-related business to offer customers better and more convincing food labelling. Thank you very much in advance for continued cooperation.