Points to be noted about the labeling of frozen chilled products

"フロチル(fro-chill)” is the abbreviation of “フローズンチルド商品“(frozen” and “chilled product) in Japanese. Although there is no clear definition of the term, this refers to products of which storage condition will be changed from "frozen" to "chilled" such as : - "products that are distributed and stored in a frozen state, thawed at the time of sale and sold in a chilled state'' - "products that are stored in a frozen state, thawed at the distribution stage and sold in a chilled temperature zone".

There has been an increase in the number of “frozen chilled products” in the last few years, but these products correspond to “the case where the storage method is appropriately changed at the distribution stage and the labeling of the expiration date or the best before date needs to be changed accordingly". Also, from the point of view of ensuring proper labeling, the changed storage method and the new accorded expiration date/best before date must be set again and displayed properly on the label.

For example, if the frozen products have a shelf life/best before period of one year and are sold chilled, it will be necessary to reset the best before date on a scientific and rational basis.

Although Food Labeling Standards don’t require labeling such as "the person/business who changed the storage temperature ", It is desirable to display it and to clearly indicate that "storage temperature is changed" on the label. It is also stated that, the Consumer Affairs Agency will proceed with understanding the actual situation, sort out the issues, and continue to consider this matter while consulting with the Ministry of Health, Labor and Welfare and local governments. Therefore, you need to regularly check the Consumer Affairs Agency’ website about the Food Labeling Standards.

Then, what are the rules to be noted regarding the labeling of “frozen chilled products”? For example, for "cakes" and "caramel custards (other than those in cans)" for which the temperature zone is changed, it is important to pay attention not only to the "best before date" and the "storage method" but also to the "net weight" on the labeling.

Normal "cakes" and "pudding" are categorized as the "Western-style fresh confectionery (pies, cakes, castellas (sponge cakes), cream puffs, caramel custards and jellies, and other Western-style fresh confectionery)" (it is written in “item 12 Confectionery” of the Specified Product Classification Table). However, they are not specified products which require to indicate their mass (weight), therefore, it is possible to write the number of contents, for example, "Contents: 3 pieces” on the labeling.

As for "cakes" and "caramel custards (other than those in cans)" for which the temperature zone is changed, the attention must be paid. At the bottom of the same table, there is the following description in "item 12 Remarks (notes, products that people are likely to feel uncertain about)".

"If the cake is sold as frozen food, it will be classified as ‘Cooked frozen food’ in item 21 (2), not in item 12”.

Therefore, if you check the table of "item 21 prepared food", you can see that "pudding" and "cake" are shaded, so they are "specified products" and need to have an indication of mass on the labeling.

There are also some other foods in the "Specified Product Classification Table" that have cautionary notes "when sold as frozen food" as well. Thus, I think it is good for you to confirm whether the "net weight " need to be changed at the same time as “best before date” and "storage method" when handling products of which temperature zone is changed.

Food Labeling Standards Q&A (the relevant part, Process-40 to 42)
Collection of Q&A of the Measurement of Specified Commodities under the Measurement Act: Specified Product Classification Table (page 66)

May 2020