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"No xxx added" claims in the new Food Labeling Standard

The new Food Labeling Standard came into effect on 1 April 2015. The "Summary of Food Labeling Standard" discusses 10 major changes, in which some newly established standards are included; one of them is "No xxx added" claims.

"The ‘No sugar added’ or ‘No Sodium added’ (’Salt free’) claims may be used only if certain requirements are met." Source:『食品表示基準の概要』(Summary of Food Labeling Standard)

The following requirements are stipulated in the new Standard.

"No sugar added", etc.

  1. The food does not add any sugars.
  2. The food does not contain sugar (added sugars only) substitutes as an ingredient (including compound ingredients) or as an additive.
    e.g.) Jam, jelly, sweetened chocolate, sweetened fruits, non-reducing concentrated juice, dried fruits paste, etc.
  3. The sugar content of the product does not exceed the amount of sugar contained in the ingredient or additive as a result of enzymatic degradation or of some other causes.
  4. Sugar content in the product is declared on the product label per unit (100g, 100ml, serving, package, etc.).

"No salt added", etc.

  1. The food does not add any sodium.
    (This will not apply where the use of the sodium other than salt is for technical purposes, and the sodium content in the product is equal to or lower than the one defined in the 3rd section of the Annex 13.)
  2. The food does not contain sodium (added sodium only) substitutes as an ingredient (including compound ingredients) or as an additive.
    e.g.) Worcestershire sauce, pickles, pepperoni, soy sauce, salted fish, fish sauce, etc

Reflecting a combination of new and old standards on a food label is prohibited. This means that a food product claiming "No added sugars" according to the old Standard may not be able to use the same claim when, for example, the label is to be modified in accordance with the new Standard.

When "No sugar added" claim is made on a food label, "sugars" must appear in the Nutrition Facts label. However when "sucrose" is voluntarily declared, it must appear out of the Nutrition Facts label under the new Standard, not within the Nutrition labeling as defined under the old Standard. So you should keep that in mind. Meanwhile, no changes have been made in requirements for claims such as "No color added" and "GMO free".

Special attention to food additives used in similar products as well as carry-overs of food additives may be required, and when it comes to "GMO", ensure that IP handling procedure is followed for all raw materials.

You have to deal with the massive amount of information in a short period of time, following the introduction of the new Standard. It is imperative that you develop an information management system (especially focusing on product specification data), in order to ensure the consistency of ingredients including allergens, "No xxx added" claims against statements made on the label.

Source: Q&A: Food Labeling Standard (Consumer Affairs Agency)

June 2015