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The comparison of standard values for nutrient claims between Japan, the U.S. and EU

You will often come across various nutrients-related catchphrases such as "Low Calorie" or, "Low Cholesterol" on food packages wherever you are in the world. Each country sets its own standard values as well as Japan does regarding nutrient content claims.
This time, we are going to compare nutrient content claim standards of the U.S and EU with that of Japan from the perspective of the “moderate intake” statement standard of nutrients for potential excessive intake set by Japan’s Food Labeling Standards. Please refer to the below table of the comparison between those countries which might be useful especially for those who are considering nutrient content claim labelling on their products for export.

The labelling standards in comparison with Japan, the U.S. and EU based on the “moderate intake” statement for nutrients and calories

Nutrients and Calories  "Not Contained" statement "Low" statement "Reduced" statement
Japan
(per 100g)
the U.S. (*1) EU (*2)
(per 100g)
Japan
(per 100g)
the U.S. EU (*2)
(per 100g)
Japan (*3)
(per 100g)
the U.S. EU (*2)
(per 100g)
Calories less than 5kcal

less than 5kcal(*6) per RACC (Reference Amounts Customarily Consumed) and per labeled serving

4kcal or less less than 40kcal 40kcal (*6) or less per RACC (and per 50g if RACC is small)

Meals and main dishes: 120kcal (*6) or less per 100g
40kcal or less 40kcal or more at least 25% fewer calories per RACC than an appropriate reference food (for meals and main dishes, at least 25% fewer calories per 100g) the reduction in content is at least 30% compared to a similar product with an indication of the characteristic(s) which make(s) the food reduced in its total energy value.
Fat less than 0.5g (*5) less than 0.5 g RACC and per labeled serving (or f or meals and main dishes, less than 0.5 g per labeled serving) 0.5g or less less than 3g 3g or less per RACC (and per 50 g if RACC is small) Meals and main dishes: 3 g or less per 100 g and not more than 30% of calories from fat 3g or less 3g or more at least 25% less fat per RACC than an appropriate reference food or for meals and main dishes, at least 25% less fat per 100 g the reduction in content is at least 30% compared to a similar product
Saturated fatty acid less than 0.1g less than 0.5g saturated fat and less than 0.5 g trans fatty acids per RACC (and main dishes, less than 0.5g saturated fat and trans fatty acids per labeled serving) 0.1g or less (the sum of saturated fat and trans-fatty acids) less than 1.5g which is only applied to the case where saturated fat does not provide more than 10% of energy 1g or less per RACC and 15% or less of calories from saturated fat Meals and main dishes: 1 g or less per 100g and less than 10% of calories from saturated fat 1.5g or less (for the sum of saturated fatty acids and trans-fatty acids in the product )

the sum of saturated fatty acids and trans-fatty acids must not provide more than 10% of energy
1.5g or more at least 25% less saturated fat per RACC than an appropriate reference food or for meals and main dishes, at least 25% less saturated fat per 100g the sum of saturated fatty acids and of trans-fatty acids is at least 30% less than the sum of saturated fatty acids and of trans-fatty acids in a similar product

the content in trans-fatty acids is equal to or less than in a similar product
Cholesterol less than 5mg, which is only applied to the product with less than 1.5g of saturated acid which does not provide 10% or more of energy of the whole product less than 2mg per RACC and per labeled serving (or for meals and main dishes, less than 2mg per labeled serving) not mentioned less than 20mg which is only applied to the product with less than 1.5g of saturated acid which does not provide more than 10% of energy 20mg or less per RACC (and per 50g of food if RACC is small)

meals and main dishes: 20mg or less per 100g
not mentioned 20mg or more, which is only applied to the product with 1.5g or more of saturated acid reduced compared to a similar product at least 25% less cholesterol per RACC than an appropriate reference food or for meals and main dishes, at least 25% less cholesterol per 100g not mentioned
Sugars less than 0.5g "Sugar Free": less than 0.5 g sugars per RACC and per labeled serving (or for meals and main dishes, less than 0.5 g per labeled serving) 0.5g or less less than 5g not defined
May not be used
5g or less 5g or more at least 25% less sugars per RACC than an appropriate reference food (or for meals and main dishes, at least 25% less sugar per 100g) the reduction in content is at least 30% compared to a similar product

the amount of energy of the product bearing the claim is equal to or less than the amount of energy in a similar product
Sodium less than 5mg less than 5 mg per RACC and per labeled serving (or for meals and main dishes, less than 5 mg per labeled serving) 0.005g or less less than 120mg 140mg or less per RACC (and per 50g if RACC is small)

meals and main dishes: 140mg or less per 100g

*"Very Low Sodium": 35mg or less per RACC (and per 50g if RACC is small)

meals and main dishes: 35mg or less per 100g
0.12g or less (0.04g or less for "Very Low Sodium") 120mg or more at least 25% less sodium per RACC than an appropriate reference food or for meals and main dishes, at least 25% less sodium per 100g the reduction in content is at least 25% compared to a similar product
  • (*1) Regarding the "not contained" statement of the U.S. that is a fat, saturated fatty acid, cholesterol, sodium, sugars ingredient or generally understood to contain these nutrients shall not be contained except if the ingredient listed in the ingredient statement has an asterisk that refers to footnote. (e.g., “* adds a trivial amount of fat”).
  • (*2) There is an exception depending on EU food categories.
  • (*3) In Japan when the “reduced statement” the reduced amount must be the value or more set by the standard and also the reduction rate in content is at least 25% compared to a similar product.
  • (*4) As for calories the standard values are given per 100ml except for sweetener.
  • (*5) There is an exception depending on food categories.
  • (*6) In the U.S. ‘calorie’ spelled with the small ‘c’ actually refers to the kilocalories provided in food in the reference.

The above comparison table shows the following points in terms of the substantial differences from Japan.
More attentions should be paid to the standards set by both EU and the U.S. , both of which set more detailed standards. In addition to that it is noticeable that the U.S. has a lot of uniqueness in their standard.

  • While Japan and EU set standards by 100g in general.(there are standards by 100ml for liquid form), the U.S. sets their own units such as RACC (Reference Amounts Customarily Consumed) and per 100g “for meals & main dishes.
  • The U.S. has no definitions of claims for “low “statement in sugars in their standard, which EU and Japan have.
  • The U.S nutrient claims for “not contained“ statement of saturated fatty acid include the upper limit for “trans fatty acid”.

In addition, the U.S. standard have the detailed criteria for the nutrient claims regarding “fat” of fish or game meat when labeling “Lean(low in fat)” and “Extra Lean(extremely low in fat)”.
(See the below FDA web page 10. APPENDIX B (10.appendix B))

After summarizing the labelling standards in comparison with Japan, the U.S. and EU based on the “moderate intake” statement we consider that special attentions should be especially paid to the U.S standard, which set their individual standard. We recommend those who consider labelling your products for export to the U.S. fully confirm if your products meet their standards.

References:
Nutrition claims~European Commission
FDA Food Labeling Guide Guidance for Industry (Appendix A - Definitions of Nutrient Content Claims and Appendix B - Relative (or Comparative) Claims.)
Food Labeling Standards

August 2019