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Cabinet Office Ordinance specifying "allergens", "used by/expiration date", "whether or not the food needs to be heated for safe ingestion" or any other information that may have a material impact on the safety of ingestion of food, as prescribed in Article 6, Paragraph 8 of the Food Labeling Act

This month, I would like to take up the above Cabinet Office Ordinance, as it has a serious impact on food safety. As the following was stated in the Ordinance, "… prescribed in Article 6, Paragraph 8 of the Food Labeling Act", so I would like to confirm the details of Article 6, Paragraph 8 of the Food Labeling Act.

“When a Person Engaged in Food-related Business, etc. conducts or intends to conduct the sale of Food that is not labeled according to the Food Labeling Standards with regard to allergens, expiration date, whether or not the Food needs to be heated for safe ingestion or any other information that may have a material impact on the safety of ingestion of Food specified by Cabinet Office Ordinance, if the Prime Minister finds it to be urgently necessary in order to prevent the occurrence or spread of harm to the lives or bodies of consumers, the Prime Minister may order said Person Engaged in Food-related Business, etc. to recall the Food and take other necessary measures or to suspend the whole or part of such business for a designated period.”

There are various labeling items on a food package such as : the product legal name, ingredients list, additives, and countries of origin of ingredients depending on the type of food, but from this sentence, you can see that the items specified by the Cabinet Office Ordinance are important for a safe food ingestion. For consumers, food labeling is an important source of information on the products, so I assume that people involved in food labeling always carefully tackle these tasks.

Let’s take a look at the specific content of the Cabinet Office Ordinance. The items having a significant impact on the safety of ingestion of food, stipulated by the Cabinet Office Ordinance, are stated as follows. Food-related business operators, etc. must comply with these items when putting them on labeling.

  1. Legal name
  2. Storage method
  3. Used by/expiration date or best before date
  4. Allergens
  5. Indication of containing L-phenylalanine compound
  6. Matters concerning foods containing specified components, etc.
  7. Precautions when ingesting Foods for Specified Health Uses
  8. Precautions when ingesting Foods with Function Claims
  9. For the foods listed below, the specific labeling items listed in the middle column of the relevant food items in the Appended Table 19 of the Food Labeling Standards are indicated respectively as follows
    1. Meat: Indication that it is processed, indication that the entire meat needs to be sufficiently heated when served, indication that eating raw meat generally has a risk of food poisoning and indication that children, elderly people and those with weak resistance to food poisoning should refrain from eating raw meat
    2. Meat product: Indication that it is an unheated meat product
    3. Dairy product: Indication that it needs to be heated when served
    4. Foods containing milk or dairy products as the main ingredients: Indication that it contains milk or dairy products as ingredients, indication that it contains milk components as ingredients or indication that at least one type of milk or dairy products is contained as as main ingredients of milk or dairy products
    5. Liquid chicken egg: Indication that it is not sterilized and indication that it needs heat sterilization when served
    6. Raw oyster: Whether it is for raw consumption or not
    7. Blowfish processed product which uses blowfish as an ingredient: Whether it is for raw consumption or not
    8. Frozen food: Whether it needs to be heated or not when served, and whether it is for raw consumption or not
  10. For the food items listed below, the labeling items listed in the middle column of the relevant food items in the Appended Table 19 of the Food Labeling Standards
    1. Boiled crab
    2. Among foods sealed in containers and packaging that are distributed at room temperature,  the ones of which hydrogen ion exponent exceeds 4.6, and of which water activity exceeds 0.94, and also which have been heat-sterilized for less than 4 minutes when the temperature at the center is 120 degrees Celsius and which need to be stored at 10 degrees Celsius or below in order to prevent the occurrence of food poisoning caused by Clostridium botulinum
  11. Precautions when ingesting Foods with Nutrient Function Claims
  12. For the foods listed below, among the labeling items listed in the middle column of the relevant food items in the Appended Table 24 of the Food Labeling Standards, the ones specified are respectively as follows:
    1. Beans containing cyanide compound: Allergens and usage method
    2. Avocado, apricot, cherry fruits, citrus fruits, kiwi, pomegranate, plum, western pear, nectarine, pineapple, banana, papaya, potato, loquat, quince, mango, peach, and apple: Allergens, storage method and used by/expiration date or best before date
    3. Meat: Allergens, storage method, used by/expiration date or best before date, indication that it is processed, indication that the entire meat needs to be sufficiently heated when served, indication that eating raw meat generally has a risk of food poisoning and indication that children, elderly people and those with weak resistance to food poisoning should refrain from eating raw meat
    4. Chicken egg with shell: Allergens, storage method, best before date, usage method, indication that it is desirable to store at 10 degrees Celsius or below, indication that it needs heat sterilization when served after the best before date, indication that it is for heating processing and indication that it needs heat sterilization when served
    5. Seafood which is sliced or peeled and for raw consumption: Allergens, storage method and used by/expiration date or best before date
    6. Blowfish, blowfish testes and blowfish skins which are sliced and for raw consumption: Allergens, storage method, used by/expiration date or best before date and whether it is for raw consumption or not
    7. Among frozen foods, seafood which is sliced or peeled and frozen: Allergens, storage method, used by/expiration date or best before date, and whether it is for raw consumption or not
    8. Raw oyster: Allergens, storage method, used by/expiration date or best before date, and whether it is for raw consumption or not
  13. For raw milk, raw goat’s milk and raw sheep's milk, the labeling items listed in the middle column of the item of raw milk, raw goat's milk and raw sheep's milk in the Appended Table 24 of the Food Labeling Standards
  14. For additives contained in a container and packaging, usage method and indication that it is an L-phenylalanine compound or that it is contained.
  15. Items related to the warning on the labeling of beef for raw consumption prescribed in Article 40 of the Food Labeling Standards

* Since a part of the description is omitted, please check the Cabinet Office Ordinance for items that are likely to be related to the products you handle.

https://www.caa.go.jp/policies/policy/food_labeling/food_labeling_act/pdf/food_labeling_cms101_200327_29.pdf

In addition, due to the enforcement of a law to partially amend the Food Labeling Act, in case you sell food products that are not labeled according to the Food Labeling Standards regarding the items specified by the Cabinet Office Ordinance, it is mandatory to notify the government agency when you recall the food, and the information will be disclosed to consumers. Information such as countries of origin of ingredients, labeling claims for nutrient components, etc. is important to help consumers select products. The items related to the safe food ingestion are also important, so I would recommend checking them again since the enforcement date is June 1, 2021.

Generally, there is still an impression that people do not have a good image about “additives”, but their necessity of use in the food production is undeniable. Therefore, I hope everyone will follow the labeling standard methods in order to enhance its easiness and understandability.

References:
Law to partially amend the Food Labeling Act (2018 Law No. 97)

June 2020