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Label bank

Discussions on the partial revision of the labelling system for genetically modified food

As of February 2019, discussions regarding “a partial revision of the Food labelling standards (Labelling of genetically modified food)” are being held at the Food Labeling Section of the Cabinet’s Office of the Consumer Commission.
Many people might be considering a future food labeling plan (including how to deal with the new Country of Origin for ingredients labeling system), so I would like to feature it in this article.

Reflecting on past

Back in time, from April 2017 to March 2018, the “discussion concerning the labeling system for genetically modified food” was held at the Consumer Affairs Agency (CAA), and the report was published later on. Then in October 2018, they begun collecting public comments and ‘’discussions about the partial revision of the Food labelling standards system for genetically modified food ‘’ started in the same month at the Cabinet’s Office of the Consumer Commission of the Food Labeling Section.

Finally, and based on the summary of the public comments, further discussions have been held consequently in December 2018, January and February 2019.

Main content of the discussion (concerning official inspections)

The following two points are the main changes from the current system that have been reported from the discussions on the partial revision of the Food labelling standards system for genetically modified food (note: this has already been discussed in our previous issues).

  • A draft suggesting alternatives to the labeling mention “GM not segregated” will be discussed, and later showed in the Q&A section.
  • The requirements for a “non-genetically modified” labeling will be made more strict, from their current state  (i.e. "unintentional presence of genetically modified soybeans and corn should be equal to or lower than 5%"), to "undetectable.”

In case it is 5% or less, it will be possible to (voluntary) mention on the label that the food was treated under proper ‘identity preserved handling’ (IP).
Therefore, in order to ensure the system’s effectiveness, discussions have mainly focused on “official observation and inspection methods”.
Particularly, the truthiness of products marked as "non-genetically modified" or "treated under proper identity preserved handling IP" will be an object for a content verification by tracing back as far as the raw material’s agriculture origins from which the final products were made.

The “guidelines for the supervision of labeling of genetically modified food based on scientific and social verifications” proposed by the Consumer Affairs Agency (CAA) contained the following verification methods:

[Supervision of genetically modified food labeling]

(Snip) Regarding “non- genetically modified” labeling (which is voluntary), in addition to:

  • - providing documentation regarding a proper ‘identity preserved handling IP’
  • - and social verification method such as ground inspection that genetically modified agricultural products did not contaminate the product

, it should be confirmed that the product does not contain genetically modified agricultural products (from soybeans and corn ingredients), thanks to scientific verification method.

[Examples of labeling that would be subject to supervision/ verification]

(1) Labeling displaying that the food (containing target crops) have been confirmed to be treated under an identity preserved handling (IP) in order to prevent the mixture with genetically modified agricultural products (including cases where only the name of the target crops was set out on the label)

Example of labeling

Legal Name: Natto (fermented soybeans)
Ingredients: Soybeans (Canada, treated under the identity preserved handling IP), etc…
Legal Name: Corn-grits
Ingredients: Corn (USA)

(2) Labeling showing that the food product is a non- genetically modified agricultural product, with no contamination from genetically modified agricultural products

Example of labeling

Legal Name: Tofu
Ingredients: Soybeans (domestic product, non-GM)

[Commercial product purchasing survey]

Objective: Specify target products possibly containing genetically modified agricultural products
Method (scientific verification): qualitative examination of processed foods
If the scientific analysis results are positive, the possible causes might be: - The use of genetically modified agricultural products (contaminated)
- The contamination of the product by genetically modified ingredients used in other products on the same production line
- The unintentional contamination of agricultural products treated under proper identity preserved handling system IP by genetically modified agricultural products
- Others

[On-site inspection of business operators (in case where the result of the “commercial product purchasing survey” is “positive”)]

Objective: Confirmation and identification of a violation fact.
Method (scientific verification): Social verification method: - Documentation related to IP handling, or other related materials
- Confirmation of production/manufacturing site, interviews/ surveys, etc.
Scientific verification method: - Quantitative (Note 1) or qualitative (Note 2) examination of the ingredients crops
- Qualitative examination of processed foods

(Note 1) Target food: Labeling with no GM information, nor mentions regarding IP handling
(Note 2) Target food: Ones with “Non-GM” labeling

Besides, the “accuracy of the inspection” and efforts in doing these verifications have been considered as important points to tackle, which explains the accumulation of commission’s discussions.

Labeling methods and future schedule

Labeling methods are also being discussed, and opinions related to the “report from the discussions on partial revision of the genetically modified food’s labelling system” (the ones which numbers of arguing points are appended in “the opinions of committee members regarding the partial revision draft of the labeling system for genetically modified food”) are excerpted as following.

[Labeling content, labeling methods]

  • It should be make easy (for the consumers) to understand the meaning of labeling expressions such as “not segregated”, “…from non-detected to 5% (contamination)...”.
  • Use of subjective expressions should be avoided, and labeling examples should be shown in the Q&A as much as possible.
  • Attention should be paid to expressions such as “non-detected”, since consumers tend to have too much expectations for it.
  • Discussions on labeling should be directed to the use of simple methods that ensure comprehensive labels.
  • There are two possible meanings for the absence of “non-genetically modified ” term on a label: this might be the underlying cause explaining why consumers misconception /misunderstanding cannot (currently) be prevented.
  • How about using a specific mark/logo to show that identity preserved handling IP systems were applied through the process?
  • Also how about trying to increase efforts on improving the general public understanding of the term “IP handling”?

The reason why the contents which were already talked about in the last discussion are being discussed again is the result of public comments.

- 773 public comments were submitted, but considering materials of their resulted summary (that is, “About the (summary of the) result of opinions solicitation regarding the draft of the Cabinet Office Ordinance for the partial revision of the genetically modified food labeling system in the food labeling standards”), it is clear that there isn’t enough understanding about the current labeling system for genetically modified food nor the proposed amendments in the “report on the discussion for the labeling system for genetically modified food.”

From there, a final draft of the report is scheduled to be discussed.

Speaking about business practices of food labeling, while it is currently not required to know all details of this issue (in term of daily business practices), it is and will be helpful to know the system’s background history in order to establish an easy and understandable labeling for your products. Therefore, we recommend to keep an eye on it already.

The 50th Food Labeling Section Meeting (Cabinet Office Consumer Commission)

Guidelines on supervision of the labeling for genetically modified food using scientific verification and social verification (CAA)

April 2019