Basic information concerning current country of origin labeling

The first two months of the year have flown by and we are into March now. In terms of food labeling, we got the impression that "country of origin labeling (COOL)" becoming mandatory "for all processed food" has still been a major topic of discussion in Japan during the last few months. While waiting for public comments on the new COOL system to come out, here we would like to outline the current (before amendment) COOL system. We hope this will help you - especially those who, for the first time, are dealing in foodstuffs subject to COOL requirements (22 food categories and four items specified in Annex 15 to the Food Labeling Standard) - review the Japanese food labeling system.

Food products and ingredients subject to COOL

  • For 22 food categories (1 through 22 in Annex 15), COOL is required for a fresh food that is the main ingredient, by weight, used in the product (ingredients/additives), and that constitutes at least 50% of the product.
  • Individual standards are set for four specific items (23 through 26 in Annex 15).
  • Imported food products are exempt from COOL requirements.

Examples of country of origin labels

Several examples of country of origin labeling methods for a dried fruit (apple) are provided below. Country of origin statements are framed in red. Let’s take the label in the middle as an example to further explain about COOL (no specific “country of origin” section is provided on the label, instead the country of origin appears in brackets immediately next to the name of the ingredient).

Basic COOL labeling

  • "Apple (Country A), sugar": If the ingredient is supplied by a single country.
  • "Apple (Country A, Country B), sugar": If the ingredient is supplied by two countries. The order of the countries should start with the largest supplier, by weight, followed by the next largest, in descending order. (The same applies where the ingredient comes from multiple origins as below).
  • "Apple (Country A, B, C and D), sugar": If the ingredient is supplied by three or more countries, or the manufacturer can substitute the third, forth…largest suppliers with the term "other(s)".
  • "Apple (domestic)” or “Apple (Japan)": If the ingredient is domestically sourced, or "Apple (‘a’ Prefecture) ": If the name of the place (Prefecture or the like) is well known to the public.

Labeling for special cases

  • If the supplier of ingredients often changes, a print or sticker may be used to display a country of origin statement, indicating, for example, “Country of origin given under the product name”. Circling the supplying country as shown here would be another option: “Country of origin: Country A, Country B , Country C”.
  • If it is difficult to specify the supplying countries in descending order by weight due to the mixing of raw materials from multiple origins, a statement such as the following may be used: “〇〇 (Country A or Country B)”, “The COOL of 〇〇 is based on the record of xxxx (year) on ingredient use” or “Please contact xx for details” (These are common statements seen on pollock roe products).

Inappropriate labeling

  • “Apple (Country A, other)”: This is not allowed if the ingredient is supplied by two countries. “Apple (‘a’ Prefecture, ‘b’ Prefecture, others)”: This is inappropriate, even if the ingredient is sourced from two or more domestic suppliers - prefectures are geographic subdivisions of the country, thus holding them together as a single country.
  • “■Ingredients: Apple, grapes, sugar ■ Country of origin: Country A”: This is inappropriate labeling if the product contains ingredients, other than the apple, subject to COOL and a “country of origin” field is provided on the label. COOL must be presented in a clear manner: e.g.) “Country of origin: Country A (apple)”.
  • If a label places special emphasis on the place of origin, it must clearly state whether the claim indicates the country of origin or the country of processing. For example, “Dried apple (domestic)” is an inappropriate labeling if the apple originating from Country A has been domestically processed. A statement on the label should be either “Country of processing: Japan” or “processed domestically”.

“Ingredient origin” and “Product origin”

The above are examples only. Since complex supply chains are, in fact, involved in the production of processed foods, some frequently published questions and answers about COOL are summarized below. (Again, “dried fruit (apple)” is taken as an example)

  • If the product is manufactured domestically using apples grown and lightly processed (cutting, etc.) overseas (Country A), the label must state ‘Country A’ as the country of origin of the ingredient.
  • If the product is manufactured domestically using apples grown in ‘Country A’ but lightly processed (cutting etc.) in another ‘Country X’, the label must state ‘Country A’ as the country of origin of the ingredient.
  • If the product is manufactured domestically using apples (‘Country A’ origin) that underwent processing (flavored with sugar, etc.) in another ‘Country X’, the product is not subject to the current COOL requirements.
  • If the product manufactured (flavored with sugar, etc.) in ‘Country X’ using apples from ‘Country A’ undergoes processing (packaging, etc.) domestically, it is classified as an imported product, and the label must state ‘Country X’ as the country of origin of the product.

COOL relating to “characterizing ingredients”

The Food Labeling Standard includes a requirement for claims of a particular place of origin: Characterizing ingredients (Article 7). The percentage of particular ingredients is required on the label of products with such claims, however it will be exempted from this declaration if the weight percentage is stated in the “Name of country of origin of ingredients (Article 3)” field on the label.

For example, when a product contains apples in the following proportion: 70% (domestic), 20% (Country A) and 10% (Country B)

  1. If the origin claim is made for a specific ingredient only, the weight percentage must be declared according to Article 7.
    (This only applies to foods not subject to COOL requirements)

    e.g.) “Ingredients: Apple (70% domestic), ...”

  2. If all supplying countries are to be labeled on the label, the product is exempt from Article 7 (i.e No weight percentage statement is necessary).
    (This applies to all foods regardless of COOL obligations)

    e.g.) “Ingredients: Apple (domestic, Country A, Country B), ...”

  3. If the origin claim is made outside the ingredient list, the weight percentage must be declared according to Article 7.
    (This applies to all foods regardless of COOL obligations)

    e.g.) “Ingredients: Apple (domestic, Country A, Country B), ...”
    (“70% domestic apple (the proportion of characterized apples)” can be added outside the ingredient list.)

Although more detailed requirements are set out in the Food Labeling Standard, the above are arguably the key points to note; FAQs on the Food Labeling Standard have annexes covering COOL, extending to 88 pages. Skimming through the documents would help you to make the necessary preparations towards a revision to the current COOL for ingredients system.

Food Labeling Standard, FAQs on Food Labeling Standard

March 2017