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The "guidelines on the provision of the countries of origin of ingredients in the "ingredient-name-labelled" (prefix labeling)" has been published

On March 29, 2019, the Consumers Affairs Agency (CAA) published the "guidelines on the provision of the countries of origin of ingredients in the "ingredient-name-labelled" (prefix labeling, hereafter referred as "ingredient-name-labelled" only)". They are now guidelines on how to provide voluntarily information concerning the countries of origin of ingredients that are going to be mentioned in the "ingredient-name-labeled", regardless of the weight-based ranking list of ingredients.
In Japan, there is a history where consumers have been highly interested in labeling highlighting the country/place of origin (or manufacturing) of specific ingredients such as "using an ingredient from 〇〇".  Hence we think that this month topic could be interesting for our readers interested in the latest news concerning Japan’s food labeling regulations and state of affairs.

Definition of "ingredient-name-labelled" (JP: 冠表示)

In the "guidelines on the provision of the countries of origin of ingredients in the "ingredient-name-labeled", the meaning of "ingredient-name-labeled" for which it is possible to voluntarily provide the countries of origin of ingredients information is defined as follows.

  • "Labeling where a product name is prefixed with a specific ingredient name"
  • "Labeling where the usage of a specific ingredient is expressly  claimed near the product name"

Examples of "labeling where a product name is prefixed with a specific ingredient name" were also provided:
- "crab fried rice"
- "beef curry"
- "stew with plenty of onion"
- "shrimp gratin", etc.

Also, examples of "Labeling where the usage of a specific ingredient is expressly claimed near the product name" were listed too:
- "making lavish use of matcha"
- "sesame is abundantly kneaded"
- "using selected beef"
- "plenty of corn grains included", etc.

As for these ingredients mentioned in the "ingredient-name-labeled", even when they are not the most predominant ingredients in terms of weight ratio in the product, it is expected to voluntarily state their country/place of origin (or the manufacturing country) on the label.

About products not subject to this labeling

Regarding mentions that will not be considered as an "ingredient-name-labeled", the following examples are listed, as "labeling which are less likely to be requested to provide information".

  • Those which are not categorized as product name prefixed with a specific ingredient (the ingredient is not specified)
    (Examples: niku gyoza (meat dumpling), gomoku pilaf (five ingredients pilaf), vegetable curry, fruit jelly, seafood doria, etc.)
  • Those which does not highlight nor claim the use of specific ingredients
    (Examples: using honey, mandarin orange included, fresh cream mixed, corn grains (30% from Hokkaido) included, etc.)

Also, products which are not subject to the guidelines are summarized as follows.

  1. Products which are required to state the countries of origin due to the Food Labeling Standard, Act for Keeping Transaction Records and Transmitting Place of Origin Information Relating to Rice and Rice Products Trade, Act on Securing of Liquor Tax and on Liquor Business Associations, or other laws and regulations.
  2. Products which express the variation in their seasoning or flavors with expressions such as "○○ taste" and "○○ flavor" and do not especially highlight the use of a specific ingredient. (Examples: soy sauce taste, apple taste, Shiso flavor, etc.)
  3. Products whose names include a specific ingredient, but are considered to be general names (that is, products with names to which the name of a specific ingredient is generally appended to).
    (Examples: tomato ketchup, corn soup, barley tea, strawberry jam, curry bread, etc.)
  4. Products using the name of a food that people can visualize from their shape as a part of their names.
    (Examples: melon bread, taiyaki (red snapper fish shaped pancake), kakinotane (persimmon seed shaped rice cracker), etc.)

Methods of providing information

According to the guidelines, in case products are subject to an "ingredient-name-labeled", it is required to provide (label) the information in the following ways.

  • When an ingredient mentioned as in the "ingredient-name-labeled" is a perishable food, the country of production has to be provided, and when an ingredient in the "ingredient-name-labeled" is a processed food, the manufacturing country has to be provided.
    (Even if the name of a processed food is written as it is in the ingredients list, in case where the ingredient name in this "ingredient-name-labelled" is labeled as a perishable food, the country of origin for the perishable food must be traced back and provided.)
  • It must be done by "labeling in the mandatory frame part of a product packaging (following labeling methods for the countries of origin of ingredients based on the Food Labeling Standard)", or "labeling in an area outside the mandatory frame part of a product packaging" or "provided through a website, or a customer service call service, etc."
  • In the case where information is written in "an area outside the mandatory frame part of a product packaging",  information can be provided using labeling methods written in the Food Labeling Standard (example: "In case of agricultural products", as for domestic ones, instead of saying they are domestic, the name of the prefecture (or any other generally know area name) can be stated. For imported products, beside the name of the country of production, the name of the state/province (or other generally know area name) can be stated).
  • In the case where information is written in "an area outside the mandatory frame part of a product packaging",  or on a "website", if an ingredient used in the product is sourced from multiple countries, the countries’ names should be basically listed (following the rules in such case), and when they are not listed in order of weight, it should be clarified so on the labeling to prevent misleading consumers.

Points requiring specific attention

In the guidelines, such "examples where information is written in an area outside the mandatory frame part of a product packaging while the ingredient used is sourced from multiple countries" are summarized as references.
Example: "The countries of origin for the ○○ ingredient are: (Japan, USA, Thailand and China). These countries are listed in no particular order, and display the areas from which the ingredient is planned to be sourced from as of the month of ○, 2018.")

In case an "ingredient-name-labeled" is used, it is expected to actively provide information in such manner, but it is also necessary to keep in mind that it constitutes a labeling claim. This means that it is important to ensure not to mislead consumers, while keeping materials indicating reasonable grounds ready. It is specifically necessary to pay attention to this point when using an ingredient sourced from multiple countries, hence we recommend to check the guidelines in depth, and provide the requested information on your labels.

Reference:
Guidelines on the provision of the countries of origin of ingredients in the "ingredient-name-labeled" (from the CAA)

June 2019