Food Labeling in Japan and overseas

Thank you for always reading our newsletter. This month we would like to start with reviewing the recent changes in the Japanese food labeling system, one of the most covered subjects in our newsletter.

Recent changes in food labeling in Japan

The past few years have seen many changes: an amendment to Nutrition Labeling Standards, the addition of new items subject to allergen labeling, the expansion of the Country of Origin Labeling for Ingredients, the release of guidelines on restaurant menus, etc. Below we have only listed major changes to avoid confusion with those for which the revision is not confirmed yet.

• Consolidation of food labeling standards (Introduction of the new Food Labeling Standard) (April 2015)
• Introduction of the Food with Function Claims (FFC) System (April 2015)
• Amendment to the Manufacturer ID Code System (Introduction of the database) (April 2016)
• Amendment to New Country of Origin Labeling System for Ingredients (scheduled for 2017)

The major changes in the Food Labeling Standard include: grouping separately food additives and other food ingredients on the label; the new requirement of mandatory nutrition labeling; a revised allergen labeling methods. These changes are affecting not only domestically produced foods but also imported foods.

The FFC system allows food labels to bear function claims based on scientific evidence submitted to the Consumers Affairs Agency (CAA). In the two years after the system was launched, the number of FFC products registered has reached more than 800 entries, while the publication of their scientific evidence has brought about significant changes in the market.

As for the revised Manufacturer ID Code system, a great number of product labels have started to bear the name and address of the manufacturer while the ID code can be used only if the product has been made, in principle, at two or more plants. Also, the CAA website now publishes the name and address of numerous manufacturers (identified by their unique code letters).

The public comment period for the proposed amendment to New Country of Origin Labeling System for Ingredients has just ended, and the new system is scheduled to come into effect this summer. All food products processed in Japan will be subject to the Country of Origin Labeling for Ingredients requirements, and this is also a major change.

Main difference in labeling requirements in Japan and overseas

Over the last few years, many changes have taken place, like Japan, in the food labeling system in other countries, including Japan’s popular export destinations such as the EU, North America and Asian countries. If you are exporting food products to those countries, make sure that you know the difference in labeling requirements between the destination and Japan. Some main differences, from Japan’s perspective, are as follows:

• As foods identified as a food allergens are more widely categorized, the area that needs to be reviewed for allergens labeling can be extensive.
• Allergen statements may have to be highlighted with different font styles such as bold or underline.
• Labeling method may differ as food additives will have to be declared by substance name.
• Calculation method may differ as added water will have to be listed as an ingredient.
• The order in which the ingredients are declared may differ as food additives and other food ingredients are grouped together.
• Specified labeling may be required if any specified ingredient, such as alcohol, is used.
• Detailed nutrition information is required and percent daily values may have to be declared.
• Contrary to the regulations in Japan, labeling requirements for general foods may not be applied to dietary supplements.
• Since there are rules for multi-language labels, a check for consistency between the different languages may be required.

Among other differences, the requirements for type size or font styles vary between countries.

The above are some of the differences in labeling standards that came to our mind, but it is necessary to review relevant specifications and standards when exporting products. For instance, the definition of specific food additives (such as flavorings, etc.) or the standards of use of these additives (intended use, use level, etc.) differ from country to country, and the definition of ‘foods’ itself also differs between countries. As an example of this, products that can claim to be “chocolate” vary among countries even if the ingredients used are the same.

Label review when exporting products

There are organizations, like Label bank, around the world that review food labels for compliance with standards for use of ingredients and ensure consistency between the ingredients used in a food product and the statements on its label. As for the recent expansion of the scope of our label review services for foods to be exported outside Japan, since last year we have partnered with several inspection institutions and companies in different countries, and established a system whose purpose is to provide more accurate label verifications and reviews. Despite some difficulties working with people of different cultures under different regulatory systems, we will always be dedicated to doing the job thoroughly for both domestic and international markets.

Also, we now collaborate on a project to develop a “database of country-specific standards” that would be useful to review standards for use of ingredients and food labeling in each respective country. We will go into more details about this at a later date as the news release should soon be available.

The reviews of food label or ingredients for compliance with relevant regulations is arguably the main challenge when distributing food products across different countries. While the inspection institutions or companies of each country have different areas of expertise, we are willing to help food manufacturers in Japan carry out review process works to export their products, thanks to the local knowledge of our partners. In parallel, we will share the experience we have gained from providing these services in future newsletters, lectures, etc.

June 2017