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Discussions on the labeling system for food additives have started.

On April 18, 2019, the Consumer Affairs Agency (CAA) held “The First Discussion on the Food Additives Labeling System.”
Regarding the food labeling system in Japan, amendments were made (in the past) such as:

  • The Food Labeling Standard (enforced in April 2015 (the transition period for processed foods is until March 31, 2020))”
  • “The new Country of Origin Labeling system for ingredients in processed foods (enforced in September 2017 (the transition period is until March 31, 2022))”
  • “The partial amendment of the genetically modified food labeling system in the food labeling standards (to be enforced in April 2023)”

The discussions discussed in this entry are following-up the above amendments.
Since food additives and their labeling are matters of high concern for both consumers and business operators, I would like to summarize the issues down below.

Current status of the food additives labeling system

First, I would like to recap the present food labeling system, based on the materials used during the discussions: “Current circumstances surrounding the Food Additives Labeling System (CAA)”.

Definition of food additives

“Food additives“ means substances which are used by being added, mixed, infiltrated (or used in any other methods) into food during the food manufacturing process or for food processing or preserving purposes
[Food Sanitation Act Article 4 Paragraph 2]

Categories of food additives

Food additives Designated additives
455 items (enforced regulations, based on a positive list format)
Additives whose safety and effectiveness are confirmed, and for which use is permitted by the government (number of items is limited)
Existing additives
365 items (MHLW (Ministry of Health, Labour and Welfare) Notification, based on a positive list format)
Additives exceptionally permitted for use for the reason that they are already used in Japan and have a long consumption history (number of items is limited)
Natural flavoring agent
Basic substances (about 600 items are listed as examples)
Substances which can be obtained from plants and animals, and are used for the purpose of flavouring
General food and drink additives
(about 100 items listed as examples)
Substances which are generally used as food but can also be used as food additives

(The number of additives items is defined as of March 31, 2019)

Food additive labeling (processed foods)

In principle, all additives used in the product will be displayed on the food label, by their “substance names*”.
(*Abbreviations can be used for substance names.)

Examples of labeling:

Wheat flour, sugar, vegetable oil and fat (contains soybeans), chicken egg, almond, butter, high-fructose corn syrup, skimmed milk powder, liquor, starch/sorbitol, leavening agent, flavoring agent, emulsifier, coloring (caramel, carotene), antioxidant (vitamin E, vitamin C)

- Underlined: indicating the additives part
- Leavening agent, flavoring agent, emulsifier: Labeling grouped by categories names
- Coloring (caramel, carotene), antioxidant (vitamin E, vitamin C): The additive’s category is written together with the substance name.

Exceptions to additive labeling:

It is allowed to display the category name on the label

Although the combination of multiple additives in order to elicit specific effects is frequent;
for some additives it is considered less necessary to list each of their components individually on the label. Besides, some components normally exist in food, therefore it is allowed to display as category name on the label as it fulfills the primary goal of labeling.
However, this is limited to the case where additives are listed in the notification of the Consumer Affairs Agency’s Vice Chief and are used in accordance to the defined category name.
Examples
: non-ingestible gum base, flavoring agents usually used in combination and added in small amounts, substances present in food as residual components including amino acids (mainly used as seasoning), etc.

“Yeast food” (i.e. nutrients consumed by budding yeast), gum base, lye water (kansui alkaline solution), enzyme, glossing agent, flavoring agent, acidifier, seasoning, coagulant for tofu, bittering agent, emulsifier, pH adjuster, leavening agent, softener for chewing gum
When the category name is written together with the substance name

Regarding additives that consumers are highly concerned about:

the ones which are more likely to be understandable for consumers through the display of the purpose of use or effect should have the category name displayed together with the substance name.
Examples: sweetener (Sodium saccharin), coloring agent (Food Red No.3), preservative (Sorbic acid)

Sweeteners, coloring agents, preservatives, thickening agents (stabilizer, gelling agents or thickeners), antioxidants, color enhancers, bleaching agents, antifungal agents (fungicide)
Labelling not required It is unnecessary to display certain additives on the label when they don’t remain in the final food product or are in the form of traces /small amounts without any functional effects (or expected effects) in the final product. Used as processing aid, carry over or for nutritional fortification* purposes

*As for foods for special dietary use and foods with function claims, these additives need to be displayed on the label.
Also, there are other foods requiring the labeling (of their additives), as defined in Appendix 4 of the Food Labeling Standard.

Background of the discussion meetings

In the background of these meetings is the “Basic Plan for Consumers “which was decided in the Cabinet meeting on March 2015, and during which additives were considered as one of the issues that has to be discussed in the process of considering the unification of systems regulating food labeling in Japan.

Before the discussions, the CAA performed the necessary investigations regarding:

  1. The labeling systems for food additives in overseas countries
  2. The current status of the disclosure of food additives information by the domestic business operators
  3. A survey on consumers opinions

The discussions about the food additives labeling system will be held based on these investigations results as a reference.

Future schedule

From now on, the concerned parties (consumers, business operators, etc.) will be interviewed/heard and the mains issues will be summed up, then a discussion meeting will be held in order to compile the report. The 2nd discussion will be held on May 30, 2019. The compilation of the report is scheduled on March 31, 2020, or at the earliest; by the end of 2019 if possible.

While this is only an assumption based on the 1st discussion, I think that:

  • The relative priority of the display methods for additives (collective name, category Name, etc.) compared to other labeling items
  • the likely addition of mentions like “additive-free” and “no use of 〇〇” to the restricted/prohibited labeling items will be discussed in the second meeting

We highly recommended to read through the meeting’s discussion (for those of you at ease with Japanese), and especially for people who are currently handling products with “additive-free” claims.

Reference:
Discussions on the labeling system for food additives (CAA)

July 2019