About the new Country of Origin Labeling system for ingredients and "actions causing substantial changes"

The Food Labeling Standard Q&A was amended on September 1, 2017, and more detailed information about the "produced domestically" mention for the country of origin labeling (hereafter COOL) is written in it. This time we will try to summarize all aspects of the "imported semi-processed ingredients" and "produced domestically" labeling, based mainly on the content of the Q&A.

What is the producing country labeling?

As a general rule, it is a method used to label the producing country of an ingredient subject to COOL as "produced in **" when said ingredient is semi-processed. (However, when the country of origin of a fresh raw material for a semi-processed ingredient subject to COOL is known, instead of using the mention "produced in **", that country of origin can be noted along with the name of the fresh raw material.)

In the beginning of the discussions, the use of a "processed in **" mention was first considered, but using the word "processed" may have meant admitting to use the names of countries where ingredients are just cut or blended. Therefore, it has been decided to note the country of production using "produced in **", and only when something fundamentally different from the raw ingredients is produced.

List of actions which do not allow the use of the "produced domestically" mention

When a semi-processed ingredient is a domestic product, it needs to be noted as "produced domestically" to show that it was produced in Japan. When it is an imported product, it needs to be noted as "produced in **" to show that it was processed abroad.

Therefore, when an imported semi-processed ingredient which has been processed by an "action causing substantial changes to the content of the product" in a (different) company in Japan, is then purchased to be used as a semi-processed ingredient, it must be noted as "produced domestically". (Food Labeling Standard Q&A COOL-43)

Specific examples of ingredients not to be noted as "produced domestically" are described in the Food Labeling Standard Q&A COOL-43, so they are quoted as follows:

Add, revise or replace the label used on the packaging Putting a Japanese label on a container or package  
Stuff Stuffing products/ingredients in an outer package for sales  
Subdividing products/ingredients purchased in bulk Example: Purchase broiled eels in bulk and subdivide them, Purchase spaghettis in bulk and subdivide them
Cut Simple cutting process like slicing Example: Slice a ham
Shape Fixing and adjusting the product/ingredient shape Example: Fix the shape of a block of bacon
Sort Sorting by shape or size Example: Sort dried sardines by size
Crush Slightly crushing or grinding (except for powdered product) Example: Crush soybeans
Blend Blending similar kind of foods Example: Blend black teas
Assort Assorting different kinds of foods Example: Assort so that foods can be easily divided into individual packaging, partition, etc.
Remove bones Removing of bones (only) Example: Remove bones from salted mackerels
Freeze Freezing in order to transport or preserve  
Defrost Defrost simply frozen food to the state of cold storage or normal temperature, by natural thawing for instance. Example: Defrost a frozen octopus
Dry Dehydrating in order to transport or preserve  
Brine Brining in order to transport or preserve  
Salt Adding salt to already salted food Example: Sprinkle salt on lightly salted salmon to make it saltier
Slightly add seasoning, etc. Adding little seasoning or small amount of condiments

Example: Add a little bit of soy sauce to food boiled in water
Example: Sprinkle sesame seeds to candied sweet potato

Add an additive Adding an additive Examples: Add vitamin E to grape oil for nutritional enhancement purposes, Color dried shrimps, Add flavouring to orange juice
Sterilize Sterilizing before or after packaging Examples: Sterilize dried young sardines by heating, Sterilize when subdividing concentrated juice
Prevent binding Applying vegetable oil or fat to prevent binding Example: Apply vegetable oil or fat to raisins
Reheat Simple reheating such as refrying, rebaking and resteaming  

What are “the actions causing substantial changes”?

The "actions causing substantial changes to the content of the product" follow the guidelines of the "country of origin" labeling, which clarify when a product is an imported one, and are described in the Food Labeling Standard Q&A Processing-154, 155.

The country of origin of a product means "the country where actions causing substantial changes to the content of the product were done" as specified in "misleading representations about the country of origin of a product", based on the Premiums and Representations Act.
In this case, actions like the following ones are not included in the "actions causing substantial changes to the content of the product."

  1. Put a label on a product, or apply some other marks/mention
  2. Put a product in a container or package
  3. Stuff products in a packaging or combine them.
  4. Assemble simple parts
    In addition to these, in the Customs Act Basic Circular, it is clearly noted that the actions below are not included in the actions that may change the country of origin labeling.
  5. Simple cutting processing
  6. Dry, freeze, brine and other actions similar to these, in order to transport and preserve a product
  7. Simple blend

In the document called "misleading representations about the country of origin of a product" (part: 'operational rules regarding the definition of "country of origin"'), definitions related to the country of origin of a product are stated. Please see below:

Item Actions causing substantial changes
Food Green tea
Black tea
Production of the crude tea

Refreshing drink
(including fruit juice drinks)

Dilution of fruit juice concentrate or solution
Rice cracker Baking or Frying

(Extract of the "food" section from 'operation rules regarding the definition of "country of origin" in "misleading representations about the country of origin of a product"')


Considering the discussions around the new COOL system, using labeling mentions as "made domestically" and "produced domestically" need to be done carefully after a thorough review of such descriptions found in the Q&A. Now regarding materials used as reference/source for the labeling, it will –without any doubt- be important to collect and prepare information that allows, for instance, to:
- Keep specifications where the country of origin is written, and the manufacturer’s data report/manufacturing instructions where the country of origin for the used ingredients is noted.
- Keep track of which product were the supplied ingredients used in

Food Labeling Standard Q&A
Operation rules regarding the definition of country of origin for “misleading representations about a country of origin for a product” (Consumer Affairs Agency)

January 2018