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How to deal with the New Food Labeling Standard, and points to note in food labeling. ~ Watch out for labels reflecting a combination of new and old labeling standards ~

Following on from the topic of the last newsletter, we will talk about the New Food Labeling Standard that came into effect on 1 April, 2015. One of the important tasks for people engaged in reviewing food labels is to check for labels reflecting a combination of new and old labeling standards. (P 35 Concerning the New Food Labeling Standard). Note: A combination of new and old labeling standards is to be permitted in terms of "manufacturer's identification (ID) code" for 1 year after the enforcement of the new Standard.

In order to avoid misleading consumers, reflecting a combination of both standards in one label is prohibited; if there is a label where the nutrition facts table complies with the new rules and allergen information complies with the old rules, consumers may be misled into believing that all allergens are declared. (The new Standard requires that all names of allergens appear, if they are to be listed collectively, at the end of the ingredient list.)

Let's see some distinctive changes in a food label:

Sample of a label based on the new Standard

------------------------------------------------------------------------------
Product name   ○○○
Ingredients ○○○、○○○(Some contain ○○)
Additives  ○○○、○○○(Some contain ○○, ○○)
Net weight  ○○○
Best before ○○○
Storage ○○○
Manufacturer  ○○○
------------------------------------------------------------------------------

----------------------------------------
Nutrition facts (per ○○g)
Energy     ○○kcal
Protein  ○○g
Fat     ○○g
Carbohydrates  ○○g
Salt equivalent ○○g
----------------------------------------

There are 3 basic changes that can be distinguished by appearance:

- Food additives are labeled separately from other ingredients. (or separated food additives and other ingredients in the same list with a slash “/” ).
- There is “salt equivalent” in nutrition facts labeling.
- When the name of allergens are labeled collectively at the end of the ingredient list, the mention begins with 「一部に」 (some contain…), not with 「原材料の一部に」(some ingredients contain…).

Not too much hustle if the changes are only for those listed above, but there are other changes that cannot be easily distinguished by appearance. One of the typical examples of such changes is nutrition/health claims.

Examples:

- Changes in reference values for claiming such as "high", "low", "contains", "does not contain", etc.
- Comparative claims such as "reduced" and "increased" must be based not only on a absolute difference but also on a relative difference, and how to calculate the absolute difference has also been changed.
- New rules in “no added” claims, concerning sugars and sodium salt.

Some labels might follow the new Standard with regard to food additives and allergens, but follow the old standards when it comes to claims. It takes time and efforts to verify the consistency of claims made by comparing between indicated values and reference values.

Given that the impact on many food products due to the change in nutritional reference values, it is vital to develop an environment that facilitates the verification of compatibility between product labels and specifications. In order to provide our customers with accurate information in a timely manner, a good grasp of food labels on the market as well as new and old food labeling standards will be required.

May 2015