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On Beer Labelling

Recently, Craft beer has been gaining more popularity. Although it might seem more expensive compared to the major manufacturers’ products, but still lots people are rather attracted to craft breweries products. I would like to feature the labeling standards for beer while mentioning the definition of craft beer and pointing out its differences from the local beer.

On the first hand, according to the website of the National Tax Agency, the “local beer” is described as follows:

A local beer is made in a microbrewery with a production capacity not exceeding 2000 kl* per year in a single production site. According to amendment of the Liquor Tax Act in April 1994, the standard for the minimum production amount required to obtain a brewing license, was lowered from 2,000 kl* to 60 kl*. Therefore, brewing beer on a small scale became possible.
*kiloliter

In addition, there isn’t a clear definition for the “craft beer” in the Japanese standards; in fact, people now are mostly regarding craft beer as a local beer. On the other hand, there seems to be a general concept in the United States considering these breweries as local beer breweries. So, if you are interested, please read the following.

Craft Brewer Definition

https://www.brewersassociation.org/statistics-and-data/craft-brewer-definition/

The labeling is still a necessity for all kinds of beers. Regarding alcoholic beverages labeling, aside from the Food Labeling Standards and the Fair Competition Code, the labeling should also conform with the Liquor Tax Act and the Act on Securing of Liquor Tax and on Liquor Business Associations. The label must comply with all the criteria stipulated in the acts and standards, and none of the labeling items stipulated in them can be omitted from the label. According to the Food Labeling Standard, the labeling items for alcoholic beverages are as follows:

“Name”, “Additives”, “Net content”, “Name of food related business operator, or name of food related business operator and its address”, “Location of the factory or the processing plant , and name of the manufacturer or process operator”, “Contains L-phenylalanine compounds”, “Items related to genetically modified foods”, “Country of origin of ingredients” (excluding imported products.)
(Food Labeling Standard, Article 3 [Paragraph 1 and 2])

* According to the Food Labeling Standard, the labeling of the following labeling items on liquors is not required, therefore not mandatory.: “Ingredients”, “Allergen”, and “Country of origin”; (Food Labeling Standard, Article 5)

(Reference: partial quote from Question 8 of Q&A on the labeling of alcoholic beverages in the Food Labeling Act)

In addition, in the Food Labeling Standard, the “Storage method”, the “Expiration date” or “Best-before date”, and the “Nutrition Facts” can be omitted from the label.

Next, I will discuss the Act on Securing of Liquor Tax and on Liquor Business Associations; I presume those who do not usually handle liquor are not familiar with this. This Act also stipulates the mandatory labeling items as well as the Food Labeling Standard. E.g. liquor classification, alcohol content, warning for the prevention of alcohol consumption for those under the age of 20 years.

Since beer is our main theme in this column, I would like to check the labeling items featured in the “Fair Competition Code on beer labeling”. First, I will talk about the “required labeling items”. This is mandatory labeling, so I think it should not be a problem.

  1. Indication that it is beer
  2. Ingredients
  3. Expiration date
  4. Storage method
  5. Net content
  6. Alcoholic content
  7. Name and location of the business operator
  8. Handling precautions, etc.

Next, I will introduce the “labeling criteria for specific terms”. The following terms must be used according to the corresponding criteria:

  1. Lager beer

    Unless a beer is aged in the storage process, then it must not be labeled as a lager beer.

  2. Draft beer

    When you put these words on the packaging or container, you must also indicate “not heat-processed “words on labeling.

  3. Black beer

    Unless a beer is a dark beer made with dark malt as a part of the ingredients, it must not be labeled as a black beer.

  4. Stout

    Unless a beer is a strong beer made with dark malt as a part of the ingredients and with a strong flavor, it must not be labeled as stout.

* As for the words (1) to (3), in the case it is clear it is beer, the word “beer” can be omitted, and can simply be labelled as “lager” or “draft” etc.

  • Words related to the production methods such as “specially made” and “Ginjo” can be written on the label according to the enforcement regulations.
  • Words related to the quality and ingredients such as “high concentration”, “high purity” and “high alcohol” can be displayed on the label according to the enforcement regulations.

Finally, I’m going to talk about “Prohibition of false and misleading labeling”. Since this section is regarding items which are prohibited on the label, I recommend that you pay attention to the following content. It is prohibited to display false impressions on the contents or on the quality of the product as consumers may be misled or confused by the indications such as it may mislead the consumers with ‘misleading “the country or place of origin” labeling’, ‘misleading labeling that the product is manufactured with the ingredients made only in the country of origin, etc. The prohibition of misleading labels is more detailed in the enforcement regulations of the Fair Competition Code, so I recommend checking them.

As our theme this time was about local beer, we checked the “Fair Competition Code on beer labeling”. As for imported beer, there is also the “Fair Competition Code on imported beer labeling”, so please check them for imported beer. As the definition of beer will be further expanded due to the tax reform in 2017, I expect more attentions will be paid to craft beer. (which is equal to the local beer this time). Since it is alcohol, why don’t you moderately enjoy trying new beers from different areas and breweries to find your favorite?

References:
Information on liquors, especially beer and low-malt beer (National Tax Administration Agency)
Fair Competition Code and Enforcement Regulations on beer labeling.
Fair Competition Code on imported beer labeling

October 2019