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Regarding the "Gluten-free" label on Imported Food Products

On June 23, 2016, the Consumer Affairs Agency released a discussion report on "Measures for Proper Food Labeling Practices". This is part of a "Food Labeling Compliance and Education" campaign regularly conducted by the Agency, and in this newsletter we would like to focus on a topic covered in the report: gluten-free labeling.

Summary of key measures to be taken for proper food labeling

One of the key measures included in the report is "A Full Allergen Declaration on the Label of Imported Food Products", and here is the summary:

"In recent years, processed foods that are for instance made with rice flour and "gluten-free" labeled have been imported into Japan. Given that the standard definition for "gluten-free" labeling in Western countries and Japan’s allergen labeling based on the Food Labeling Standard is different, we will work to encourage food related businesses including importers to check their products for any cross-contamination from allergen sourced ingredients, enlighten and educate them about proper allergen labeling, using education materials such as brochures."

The Content of the Education Materials for Importers

A brochure for importers has also been issued, and its content is as follows:

  • The standard for gluten-free labeling in countries such as the EU and the U.S and for Japan’s allergen labeling is different.
  • Check your food products for any cross-contamination from allergen-sourced ingredients and provide proper allergen declaration on the label.
  • A "gluten-free" claim on food products containing wheat, a known allergen, may conflict with the "Act against Unjustifiable Premiums and Misleading Representations" because consumers would assume that the product does not contain wheat.

Gluten-Free Labeling in the EU and the U.S.

  • Food products may bear a gluten-free labeling claim, in terms of the benefit for consumers with celiac disease, provided that the gluten concentration in the product does not exceed 20 ppm.

Allergen Labeling in Japan

  • A food allergy reaction can occur even in response to tiny amounts of an allergen-containing food, it is therefore mandatory that specified ingredients (allergens such as wheat) present in the product be declared regardless of their intended use.
  • The products containing not less than a few ppm of total protein content in wheat must have allergen labeling on the packaging.
  • In the case where there is a risk of cross-contamination, it is recommended that the product label bear a warning statement for consumers with food allergy.

The difference between "xxx-free" and "no use of xxx"

The difference is explained in the FAQ of the education brochure but the section is intended for food labeling experts, we therefore provide additional information below - from an excerpt from our past newsletter titled "Allergen-Free Claims" - especially for those starting a food import business.

It probably is confusing which term to use, "xxx-free" or "no use of xxx", when you create a claim for your food product. Strictly speaking, those two have different meanings, and it is important to understand the difference in order to avoid accidents. There is a useful reference in the "FAQs on Food Labeling Standard", when it comes to such claims as "products made without any specified ingredients (allergens)" (Note: Do not confuse with "xxx-free" claims).

(E-22) Would it be considered that "no specific ingredients are present" in a food product if there is a claim on the packaging saying that it was "made without specified ingredients"?
(Answer) A claim "made without allergens" does not necessarily mean "does not contain allergens".

Cross-Contamination and Product Analyses

Another important issue given in the education brochure is cross-contamination (example of warning statement appearing on the packaging: "Made on a line that processes products containing wheat"). It is wrong to assume that a small amount of cross-contamination won’t do any harm to the body. In fact, some analyses have showed that cross-contaminated food products contain as much as dozens of ppm (not a few or ten-something range). This suggests that it is difficult to control the allergen level in food products as it is "unintentional" contamination.

It is important to check for cross-contamination particularly if allergen-free, such as gluten-free, claims are going to be made on your product packaging. We should take this as an opportunity to ensure food safety by such means as double checking the product ingredients and conducting regular analyses of product samples, thereby providing accurate information to consumers who need it.

"Measures for Proper Food Labeling" (Consumer Affairs Agency)

July 2016