Food allergen labeling and exportation to foreign countries

A while ago I got the opportunity to see a food product (made in Japan) bearing a mention “allergen free” and which was scheduled to be exported abroad. When I asked the manufacturer, they said they were using the labeling since “No allergic ingredients were used”, which made me think that it might be necessary to raise the awareness around food allergen labeling. Therefore, I would like to write about an important topic in this month’s column: “food allergen labeling and exportation to foreign countries”

Difference in items target to local food allergen labeling systems

There is a difference in items subject to food allergen labeling between countries. To begin with, the items subject to food allergen labeling in Japan are the following 27 items (7 of them are subject to mandatory labeling).

Mandatory (7 items): shrimp/prawns, crab, wheat, buckwheat, eggs, milk and peanuts

Recommended (20 items): abalone, squid, salmon roe, oranges, cashew nuts, kiwifruit, beef, walnuts, sesame, salmon, mackerel, soybeans, chicken, bananas, pork, “matsutake” mushrooms, peaches, yams, apples and gelatin

Meanwhile, the items subject to food allergen labeling in other countries are slightly different. For example, in Hong Kong, the following 8 items are subject to mandatory labeling.

  1. (i) Grains containing gluten
  2. (ii) Crustaceans and crustacean products
  3. (iii) Eggs and egg products
  4. (iv) Fish and processed fish products
  5. (v) Peanuts, soybeans and their products
  6. (vi) Milk and dairy products (including lactose)
  7. (vii) Nuts and nut products

Reference: Standards and criteria for foods and additives in various countries (Ministry of Agriculture, Forestry and Fisheries)

Also rules themselves are being constantly revised as well as in Japan ( where“sesame” and “cashew nuts” were added to items recommended to be labeled in 2013). For instance, in 2018, there was a revision in rules for food allergen labeling in Taiwan (it was revised on August 21, 2018 and will be enforced on July 1, 2020), the number of target items was increased from 6 to 11.

  1. Crustaceans and their products
  2. Mangos and their products
  3. Peanuts and their products
  4. Sesame, sunflower seeds and their products
  5. Milk, goat milk and their products (except lactitol derived from milk or goat milk)
  6. Eggs and their product
  7. Nuts and their product (almonds, hazelnuts, walnuts, cashew nuts, pecans, Brazilian nuts, pistachio nuts, macadamia nuts, pine nuts, and chestnuts, etc.)
  8. Gluten from grains such as wheat, barley, rye, oats, and products including these grains
  9. Soybeans and their products (except highly purified or refined soybean oil and fat, tocopherol and their hydrolysates, phytosterol and phytosterol ester)
  10. Usage of sulfites and sulfur dioxide whose concentration is equal or more than 10mg/kg calculated as the total content of SO2 in the final product
  11. Salmon, mackerel, Chilean sea bass (Yuan xue), Greenland halibut (Bian xue) and their products

Reference: Standards and criteria for foods and additives in various countries (Ministry of Agriculture, Forestry and Fisheries)

Regarding food products exported from Japan to foreign countries, you need to pay attention especially on the ones which do not contain “wheat” but contain “gluten”, or the ones whose carry-over additives include “sulfite”(On the contrary, you need to be careful with the ones that do not contain “gluten” but contain “wheat” when importing food products to Japan). As a consequence, those who plan to export food products to foreign countries will need to check regulations for food allergen labeling in their target countries. You can read “the standards and criteria for foods and additives in various countries” created by the Ministry of Agriculture, Forestry and Fisheries (unfortunately in Japanese only), but we recommend to read through it at least once for all exporters from Japan.

Difference between the mentions “free” and “Not used”

Next, it is also necessary to confirm and clarify the meaning of labeling like “allergen free.”

The labeling of “use no XXX” does not necessarily mean “contain no XXX.” (Snip) For example, in general, “wheat flour (specified allergic ingredients)”is used for making cakes, but in case a cake is made without “wheat flour” and it is properly confirmed by the manufacturer’s data report, the product can be labeled as “This product does not use wheat (flour).” However, even in this case, contamination might be caused if the factory where this product is manufactured also produces foods (ex: cakes) containing wheat flour. So we cannot deny the possibility that the product may contain wheat by this labeling.
(From the food labeling standard Q&A)

In Japan a clear threshold to use labeling like “allergen free (not included)” has not been established, but in some countries a standard for this kind of labeling is. For example, in the US and EU, “20ppm (mg/kg)” is set as a standard value for the labeling of “gluten-free.” Besides, depending on the country there might also specific regulations for labeling methods (ex: possible use of “no gluten” instead of “gluten-free”, etc). Hence if you want to use this type of labeling, we recommend you to check such regulations beforehand.
Also on a related topic: there are countries with specific regulations for "low gluten”. For instance, the regulations in Australia and New Zealand are as follows.

Gluten Free

The food must not contain –
(a) detectable gluten; or
(b) oats or their products; or

(c) cereals containing gluten that have been malted, or their products.
Low The food contains no more than 20 mg gluten per 100 g of the food.

Reference: Federal Register of Legislation. Standard 1.2.7 Nutrition, health and related claims

There are also other countries which require a notification when using allergen free labeling, so it is necessary to check not only the regulations for labeling methods but also related systems.


I would like to point out that one of the underlying reasons for such gaps in countries systems and regulations is the differences in their food cultures. We are seeing more and more labeling of Japanese foods planned to be exported abroad, and I have the feeling that the number of labeling claims such as “allergen free” and “use ingredients from ○○ (area)” is also increasing. As for the labeling of food products sold in Japan, it is also required to prepare proper evidences when using labeling claims.
Since regulations are different depending on countries, in many cases labeling claims which can be used in Japan cannot be used in other countries (and vice&versa). In that case, you can strive and go out of your way to find alternative claims that can be used, but you can also, for instance, use this freed space to explain the nature of your food product instead: it will make it easier for your consumers with a different food culture to understand it. I hope you can use the ideas expressed above when selling products to foreign countries.

Standards and criteria for foods and additives in various countries (Ministry of Agriculture, Forestry and Fisheries)

Food labeling standard Q&A (Consumer Affairs Agency)

Standard 1.2.7 Nutrition, health and related claims (Australia)Standard 1.2.7 Nutrition, health and related claims (Australia)

January 2019