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Regarding the notifications of the Manufacturer Identification Codes
~In case you need to switch, it is recommended to submit a notification by the end of this year~

The Consumer Affairs Agency (CAA) released the notice “Dissemination of information regarding the operation of Manufacturer Identification Codes”, and called for manufacturers or related business operators to submit a notification in the case of need of Manufacturer Identification Codes based on the new system no later than Friday, 27th of December, 2019 (Because of inundated requests for notifications the examination of the late ones might be completed after the transition period ) In addition to the content of this notice, I would like to summarize again the amendments to the management of Manufacturer Identification Codes.

Content of the notice

The content of this notice is as follows.

  • Foods which will be produced after the transition period ends (March 31, 2020) need to be labeled based on the new system.
  • As existing Manufacturer Identification Codes will not be able to be used, submission of a notification for the new “Manufacturer Identification Codes”  has to be completed.
  • Food related business operators who are planning to use Manufacturer Identification Codes but haven’t submitted a  notification yet need to do it  promptly.

Regarding the Food Labeling Standards (Cabinet Office Ordinance No.10 in 2015. Hereinafter referred to as “the new system”.) based on the Food Labeling Act (Act No.70 of 2013) enforced on April 1, 2015, the transition period will end on March 31, 2020, and foods which will be produced after the transition period, must be labeled based on the new system.
Now we are aware that food related business operators are working on switching their packaging according to the new labeling system, but since the existing (submitted before March 31, 2016) Manufacturer Identification Codes (hereinafter referred to as “Identification Codes”) won’t be usable, if they continue to use them, they will need to submit a notification for Manufacturer Identification Codes based on the new system.
Therefore, food related business operators who are using the existing Identification Codes and planning to use new Identification Codes after the transition period but have not notified yet need to do it promptly.
As the end of the transition period is approaching, the notifications for Manufacturer Identification Codes are rapidly increasing, which requires time to process them.
Therefore, food related business operators who are concerned by this matter, must proceed with notification in order to secure enough time.
I must add that considering the current number of notifications and the processing status, notifications submitted by December 27, 2019 will be examined by the end of the fiscal year of 2019, however the ones submitted after that may be examined in the next fiscal year.

Quote: "Dissemination of information regarding the operation of Manufacturer Identification Codes"

Those who are planning to use the Identification Codes after the transition period but have not notified yet should submit a notification by the end of this year.
However, this is just in the case “the use of Manufacturer Identification Codes is allowed after the transition period ends”.
In the new system, which started on April 1, 2016, the conditions under which the Manufacturer Identification Codes can be used were amended. Let’s review those amendment points here.

About Manufacturer Identification Codes based on the new system

In the new system, Manufacturer Identification Codes will be accepted only when there is a merit of sharing the packaging materials, so in principle, they can only be used in the case the same product is manufactured in two or more factories (except food for business use).
“in the case the same product is manufactured in two or more factories”, detailed explanation is as follows.

The labeling of the Manufacturer Identification Codes is basically allowed only when there is a merit of sharing the packaging materials such as when the same product is produced in two or more factories.

Quote: Attachment of Manufacturer Identification Codes “Food Labeling Standards Q&A”, (Identification Codes-1) 3

  1. The “same product” means a product which uses the same packaging material under the same standard.
  2. “In the case the same product is manufactured in 2 or more factories”, the two following conditions need to be met when reporting Manufacturer Identification Codes.
    1. In two or more factories there are places where the food hygiene will ultimately change.
    2. Sharing the packaging material through using Manufacturer Identification Codes.

Quote: “Regarding Food Labeling Standards” (processed food) 1 mandatory labeling item (6) 5

If the above requirements are not met, Manufacturer Identification Codes cannot be used under the new system. In other words, if Manufacturer Identification Codes used before the transition period doesn’t meet the above requirements, then it cannot be used in the new system and it will be necessary to display the manufacturer’s names and locations on the label.
Please refer to the food labeling standards Q&A regarding the case where “the same product is manufactured in two or more factories”.
To summarize the answers, 1. is “Not applicable”, 2. and 3. are “Applicable if a manufacturing plan is submitted ”, 4. is “Applicable at the time of the notification but it is necessary to stop using the Manufacturer Identification Codes and report the abolition when the number of factories is reduced to only one”.

Do the following cases correspond to “when the same product is manufactured in two or more factories”?

  1. In the case products are manufactured in two factories where one produces raw material for intermediate processing and the other one uses it to produce the final products.
  2. In the case products are manufactured in two or more factories only during the busy season (for example: one to two months at the end of the year).
  3. In the case the product sales are good and is planned to be manufactured in two or more factories.
  4. In the case the product is manufactured in two or more factories at the time of the notification, but the production is reduced within the notification s valid period and eventually adjust the production to only one factory.

Quote: Attachment of “The food labeling standards Q&A”, Manufacturer Identification Codes (Identification Codes -11)

In the case the Manufacturer Identification Codes can be used

In the case the Manufacturer Identification Codes can be used under the new system, the following measures are required:

  • Notification of Identification Code based on the new system
  • The “+” must be prefixed to Manufacturer Identification Codes on the label
  • To display either of the followings on the label:
    1. Contact of the person in charge of providing information when requested such as the factory location.
    2. The website address where the factory location is written.
    3. Locations of all factories manufacturing the same product.

If applicable, it is recommended to check the announcement and make an early notification.

References:
Dissemination of information regarding the operation of Manufacturer Identification Codes (CAA)

October 2019