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Differences and points to be kept in mind about the US and EU methods of labeling for “compound ingredients” as found in their respective food labeling standards

While more and more countries are recently lowering barriers of trade such as customs duties and adopting systems to introduce each other’s products (on their respective markets) inexpensively, the Economic Partnership Agreement (EPA) between Japan and Europe took effect on February 1, 2019.
Thanks to this agreement, customs duties on imported European foods including cheese, chocolate and biscuits will be lowered gradually, so it will be possible to sell them at lower prices.
Also, considering the popularity of Japanese food in Europe, expectations are high for exportations of such products.

Therefore, following the fact that import and export of food are likely to increase, in this entry we will focus on the differences between Japan and foreign countries, and related points to keep in mind, regarding the rules in making food labeling.

And we will explain it by taking “compound ingredients” used for processed food as an example.

In Japan, in case of a food made by using so-called “compound ingredients” (i.e. which consist of multiple ingredients), such ingredients should basically be labeled as the following example; that is with brackets after the name of said compound ingredients, and within those brackets the secondary ingredients should be listed using the most common names.
(Reference: Food Labeling Standards FAQ(加工(processed food)-51)

Mayonnaise (Vegetable oil and fat, egg yolk (contains egg), brewed vinegar, spices, salt, sugar)

On the other hand, under the conditions below, it is acceptable to not write the compound ingredient itself but instead split and mention its secondary ingredients separately in the ingredients list.
(Reference: Food labeling standard FAQ(加工(processed food)-52 to 53)

  • The characteristic of each secondary ingredients would not significantly change even if separated from each other.
  • The name of the compound ingredient is not generally understood by consumers, or there is no merit for consumers to label it as a compound ingredient since it is merely a mix of its secondary ingredients

[Example]
“Sugar-added egg yolk (egg yolk (contains egg), sugar)”
⇒ This can be displayed as “Egg yolk (contains egg), sugar” on the product labeling

Furthermore, the assumption is that such compound ingredients are purchased and used as processed foods, as stated in the mentioned above FAQ: “in case of buying processed foods and using them as ingredients”.

So now let’s see how those compound ingredients are labeled in the EU and US, as examples of what is done in other countries.

[In the EU (Reference: REGULATION (EU) No 1169/2011)]

(Original text)

PART E — DESIGNATION OF COMPOUND INGREDIENTS
1. A compound ingredient may be included in the list of ingredients, under its own designation in so far as this is laid down by law or established by custom, in terms of its overall weight, and immediately followed by a list of its ingredients.

[In the US (Reference: FDA 21CFR101.4 Food; designation of ingredients.)]

(Original text)

(b)-(2) An ingredient which itself contains two or more ingredients and which has an established common or usual name, conforms to a standard established pursuant to the Meat Inspection or Poultry Products Inspection Acts by the U.S. Department of Agriculture, or conforms to a definition and standard of identity established pursuant to section 401 of the Federal Food, Drug, and Cosmetic Act, shall be designated in the statement of ingredients on the label of such food by either of the following alternatives:
(i) By declaring the established common or usual name of the ingredient followed by a parenthetical listing of all ingredients contained therein in descending order of predominance except that, if the ingredient is a food subject to a definition and standard of identity established in subchapter B of this chapter that has specific labeling provisions for optional ingredients, optional ingredients may be declared within the parenthetical listing in accordance with those provisions.
(ii) By incorporating into the statement of ingredients in descending order of predominance in the finished food, the common or usual name of every component of the ingredient without listing the ingredient itself.

As you may notice from the above contents, both in EU and the US, as long as compound ingredients use common names, such names can be written on the labeling (however, in this case, the secondary ingredients must be labeled right after them, as in Japan). Also, you can see that it is allowed in the US to split compound ingredients and only write the common names of their secondary ingredients on the labeling.
In addition, unlike Japan, regarding both labeling methods, there is no mention regarding assumption that compound ingredients are purchased ingredients. (Note: In Japan it is stated in the FAQ of the Food Labeling Standard)

Therefore, you need to be careful when preparing a label and selling products especially in cases of importing foods from the US, since the details of compound ingredients (especially when purchased from a supplier) might already only be shown up to the secondary ingredients on the received specifications (i.e. with the final labeling mention already in mind).
In such cases, it is necessary to check with the local supplier to confirm whether said ingredient is a purchased ingredient before designing the label and its information. If so, it will be necessary to confirm the details of what the compound ingredients contain, since in most case, secondary ingredients will not be written separately, and only the compound ingredient name will be written instead in Japan.

Now let’s think about the case of exportations (from Japan).
Let’s consider to export a food product called “tenkasu (crunchy bits of deep-fried dough produced as a byproduct of cooking tempura)” to the US as a compound ingredient which is often used as a topping of “udon” (thick Japanese wheat noodles).
First, people in the US are not familiar with above-mentioned “tenkasu”, so all secondary ingredients such as “wheat flour” and “vegetable fat and oil” should be written separately.
In regards to the fact whether “tenkasu” is a purchased ingredient or not, it is important to notice that the food labeling regulations/standards in the US are completely different from the one in Japan.
In the US, in case of a “compound ingredient” with an uncommon name, its secondary ingredients must be labeled separately whether they might be purchased ingredients or not: an important point to consider when preparing labeling data for this market.

This time I introduced some differences in the food labeling standards among the US, EU and Japan, but these are just a glimpse of the various differences in making food labeling for both export and import, so dedicated attention should be paid on a regular basis to this overall matter.
Of course, it is needless to say that besides the US and EU, there are also many differences in the labeling standards between Japan and the rest of the world!

March 2019