Nutrition Facts labeling under the new Food Labeling Standard
~ Mandatory nutrition declaration and nutrition claims ~
Nutrition Facts label compliance review usually involves several people, not regulatory consultants alone but also an expert or external inspection agency when reviewing the label based on nutrition analysis, or a person in charge of the product development when making a nutrition claim.
Let's summarize the nutrients that require declaration and changes made under the new Food Labeling Standard.
The new Standard requires in principle nutrition labeling on all processed foods and food additives for consumer use, though an exception is made for the cases below:
- Food packages with a surface area of 30cm2 or less available for labeling
- Alcoholic beverages and the product with nutrients that make no significant contribution to health.
- The product that are likely to change their ingredients in a very short time period
- The product sold by small businesses (businesses whose taxable sales of 10 million yen or less) as provided in the Article 9 of the Consumption Tax Law
The declaration must be presented in the following format (Sample 1). It may look relatively simple as just sodium is replaced by salt equivalent, but it becomes more complicated with voluntary declarations.
< Nutrition Facts per serving or other units >
In the case where both "No sugar added" claim (the product contains sugar from raw materials only) and voluntary declaration are also made on the label, the following format will be applied.
* The declaration of sugars becomes mandatory, when "No sugar added" claim is made.
< Nutrition Facts per serving (or other units) >
|－n-3 fatty acids||g|
|－n-6 fatty acids||g|
Further changes are as follows:
- The carbohydrate cannot be replaced by sugars or dietary fiber.
- The title phrase is "栄養成分表示" (nutrition facts), not "栄養成分値" (nutritional values) nor “標準栄養成分“ (standard nutritional information).
- The amount per serving must be provided if the unit of the product is "one serving".
- Where the breakdown of nutrients is declared, indent each line of the breakdown (the hyphen is not necessarily required).
The nutrient whose declaration is not mandatory (e.g. sucrose in the sample 2) must be provided outside the Nutrition Facts label, and the same is true for beta-carotene according to the new Standard, which provides the list of nutrients that are mandatory on the nutrition Facts label.
To get salt equivalent value, you can multiply sodium content by 2.54. The conversion factor (2.54) is also used at external inspection agencies that offer nutrition analysis services.
It must be noted that the nutrient reference value and conditions for the use of nutrition claims have also been changed.
It is important to follow the required nutrition labeling format, but more importantly we need to verify the consistency between what’s said on the label and on the product specification.
The introduction of the new Standard gives a good opportunity for us to review our information management system pertaining to product specifications, reference materials on nutrition, etc.
Source: "FAQs on food labeling standards" (Consumer Affairs Agency)