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On Standards of use for ingredients/Labeling standards and what it implies for Import/Export

The food system in Japan is a lot different from the ones in other countries. For instance, items subject to allergen labeling are different. Thus, it is necessary to do a thorough research beforehand. Also, there is a big gap in the level of difficulty to handle each labeling depending on how different rules are. One example regarding the differences in allergen labeling requirements: once you have noticed the difference, it becomes much easier to handle, as you just need to change the labeling. On the other hand, there are cases where even if you understand the difference in regulations, it is still quite hard to actually put them into practice.
Therefore, I would like to simply summarize the “Standards of Use” and “Labeling standards” from the viewpoint of practical labeling related matters in this short column. First, please see the following table.

    How easy are the standards to check How easy are the standards to handle
Standards of Use Ingredient Hard Hard (according to food classification)
Food additives Easy Hard (according to food classification)
Labeling standards Mandatory labeling Hard Easy
Voluntary labeling Hard Easy

Regarding the standards of use, I separated them into “ingredients” and “food additives”, while concerning the labeling standards, I split them between “mandatory labeling” and “voluntary labeling.” in order to make it clearer. Easy means “easy to handle”, and Hard means “hard to handle.”

[Standards of use for ingredients]

As for the standards of use for ingredients, the regulations for food additives are not specifically difficult to find. However, since food additives are used because they are essential, sometimes it is required to find substitutes which have a similar function. In that case, it will take time if it is needed to verify issues related to the manufacturability or the quality assurance for nutrient claims.

As for ingredients other than additives (i.e. food materials), in some cases it is quite difficult to find their standards of use. When the main ingredients/materials of a product correspond to “novel foods” (products or materials - like essences made by extracting and concentrating certain component - which do not have a long history of use as food), it might prove especially challenging to find and select a substitute ingredient.

[Labeling standards]

It is not difficult to handle labeling standards such as (mandatory) labeling items, methods and forbidden labeling once you can understand the regulations. However, unlike the standards of use for ingredients, local regulations are written in long and complicated sentences, which can prove difficult to interpret even for local people in charge of food regulations. In other words, it is far to be easy to correctly grasp the meaning of the regulations themselves. Among these, regulations for mandatory labeling to be performed under specific conditions (such as labeling claims, etc.) can be especially difficult to understand.

And furthermore, a common issue that will likely arise is the“identification of food classification.” Both standards of use for ingredients and labeling standards widely differ depending on the food classification (it is the same in Japan). I hope the topics discussed this month will be helpful for you when reflecting about which process is going to be time consuming when importing and exporting products.

January 2019