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Label bank

Six months since the introduction of the Japanese new Food Labeling Standard.

It's been six months since the introduction of the Japanese new Food Labeling Standard, which took effect on April 1, 2015. In this newsletter, we would like share with you what we have noticed thorough work for the last six months.

The time to change food labels under the new Standard.

Over the last 6 months, quite a few companies--contrary to my expectations--have changed their labels to meet the new Standard, but most of them are manufacturers and have already been providing nutrition information on their labels. Such a quick response may also have something to do with the product range; a smaller range of products makes for easier control over changes. For companies who have never provided nutrition information, it will take time to prepare to switch their labels to comply with the new Standard, so nutrition information will be one of factors responsible for the delay.

Some companies with large product range are taking time, 6 months at least, to review their information management systems, such as updating a manual for label review procedures.

Some companies that manufacture the same product in several facilities will start applying their new ID codes (manufacturer's identification code) from April 2016 onwards, and then will change labels, maybe around next summer or autumn.

There are some companies that are unable to set a schedule, at least as of now, when to change labels during the five-year transition period. This is attributed, in part, to the ID code: under the new Standard, ID codes are only permitted when a product is manufactured at more than two facilities, which means small companies must provide the name and address of the manufacturing facility on all product labels. Another possible reason is content claims such as "no sugar added" or nutrition claims--under the new Standard, such claims can no longer be made on some food labels. Those companies being largely affected by the new Standard often have yet to decide when to renew their labels.

How to declare food additives and allergens on food labels.

There are two formats for Ingredient labeling: one is to have a separate food additive labeling section, and the other is to separate food additives and other ingredients in the same ingredient list. The latter seems to be more popular so far, especially the one separating food additives and other ingredients with slash "/".

The latter style is more popular not just because the word count can be reduced, but also because some companies think that the term ‘food additive’ could cast a negative image on food products and consumers also have a negative impression on food additives. Having said that, food additives will also be conspicuous even if they are included in the list with other ingredients. Either way, companies should prevent health hazards caused by not using food additives that are considered necessary in food products, due to being obsessed with an "additive-free" claim.

When it comes to allergen labeling, the individual allergen declaration is becoming a mainstream, notably in food products with a few ingredients rather than the collective allergen labeling, which requires all names of allergens appear in parentheses collectively at the end of ingredient list.

The readability may be enhanced by using the collective allergen labeling when it comes to food products with many ingredients as all names of allergens must be declared. The individual declaration is the general requirement for allergen labeling, but each company would need to consider which labeling (individual or collective) would provide better readability to the consumers.

Future food labelling

The popular topics in several lectures that I have given in the past 6 months were "Manufacturer's Identification (ID) Code" and "Function Claims", which would give more impact on people involved in food development and projects than regulatory consultants. Even though some companies are still at the stage of looking for a best solution especially as to the two topics above, it is hoped that a win-win solution for companies and consumers is to be found in the future.

October 2015