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About the food additives labeling system in Japan and other foreign countries (comparative summary)

A summary of the food additives labeling systems in foreign countries was shared in the materials of The First Discussion on the Food Additives Labeling System” held on April 18, 2019.
As the number of business operators exporting food products that were manufactured in Japan is increasing, I would like to bring out that summary here.

Food Additives Labeling Systems in Foreign Countries/organization (summary)

  Japan CODEX USA Canada Australia China France
Labeling order Labeled separately from food ingredients, and ordered by weight Ordered by weight Ordered by weight Any order following the ingredients Ordered by weight Labeled separately from food ingredients, and ordered by weight Ordered by weight
Labeling method - General name
 (Substance name)
- General name
(Actual name)
- International number
- General name - General name - General name
(Name)
- Code number
- General name
(Actual name)
- INS code
- General name
(Substance name)
- E number
Together with the category name - 8 categories - 25 categories - 5 categories - Not confirmed - 25 categories - 24 categories - 25 categories
Subject to category name - 14 categories - Gum base, flavoring agent, modified starch - Flavoring agent - Flavoring agent, seasoning, gum base - Flavoring agent - Flavoring agent - Starch, gum base
Substances used for the purpose of nutritional enhancement/fortification Exemption from labeling (except for some foods categories) Not an additive Deleted from the provisions Not an additive Not an additive Not an additive Not an additive
Processing aid Exemption of labeling Exemption of labeling Exemption of labeling Labeling is mandatory (not additive) Labeling is mandatory (not additive) Exemption of labeling Exemption of labeling
Carry over Exemption of labeling Exemption of labeling Exemption of labeling Exemption from labeling (with conditions) No description Exemption from labeling (with conditions) Exemption of labeling

Reference: “Current situation of the Food Additives Labeling System (Japan’s Consumer Affairs Agency CAA)”

For further details, please refer to the “Business report on the actual situation of the Food Additives Labeling System” which is a part of the materials of this 1st discussion.

For export and import business operators, a lot of time is spent to “check the additives Standards of Use (Allowed food category, category name, quantity, etc.)”, but I think this material will remind you once again of the importance of also checking the “labeling standards” for additives as well.

Actually, in the process of reviewing the labeling for food to be exported/imported, there are specifically two important review points within the above labeling system:

  1. Whether an ingredient falls under the definition of “additives” and
  2. Whether it is subject to an exemption of labeling or not

When some additives are exempted from labeling in a country (local or target), detailed information might not be reviewed during the check of the Standards of Use. As a result, it is a common problem for business operators to only notice this at the time of import/export - and panic over the issue.

Issues such as carry over are related to labeling standards, and as such they have to be differentiated from problems related to the Standards of Use. However, and firstly, it is important to have a good understanding of the regulations in both/concerned countries while conducting export or import operations.

Indeed, I would recommend anyone involved in export/import operations to have a look at the topic discussed in this entry.

Reference:
Discussion on the Food Additives Labeling System (CAA)

July 2019