Language:

Removal of the terms "Synthetic" and "Artificial" from Food Labeling Standards

~The transitional period is until March 31, 2022~

On May 25, 2020, The Consumer Commission Food Labeling Section Meeting deliberated on the partial revisions to Food Labeling Standards (such as labeling of food additives, etc.), and approved to the consultation paper and the proposed draft report to remove the terms "Artificial" and "Synthetic" from Food Labeling Standards.
The amendment came into effect on July 16, 2020.

Background

The fact that terms such as "Artificial sweeteners" and "Synthetic preservatives" are used only for "additive-free" labeling in the current situation was pointed out in the "Report on Discussion about the Labeling System for Food Additives" compiled on March 31, 2020. Therefore, the terms "Artificial" and "Synthetic" have been removed to prevent consumers from misinterpreting them. After the revision (after the transitional period), it is considered that the labeling of "Artificial" and "Synthetic" etc. cannot be used for additives since the aim is to prevent consumers from misinterpreting them.

4. Future direction of the food additives labeling system

(2) Regarding the use of "-free" and "non-use" for labeling.

(ii) General direction of future measures

(b) The terms, "Artificial" and "Synthetic"

According to the results of the consumer intentions survey, it was found that some consumers avoid buying products with terms such as "Artificial" or "Synthetic" regarding additives. According to the interviews with related business associations, etc., some people mentioned that use of terms such as "(chemical) seasonings which are not clearly defined in Food Labeling Act affects consumers’ understanding of additives.

The discussions reached the consensus that it is appropriate to remove the terms "Artificial" and "Synthetic", which are contained or prefixed such as "Synthetic preservatives" and "Artificial sweeteners" and so on, of which regulations of labeling for food additives terms are stipulated in Food Labeling Standards. This is mainly due to the inconsistency with the labeling of additives in the Food Sanitation Act of 1989, when the labeling of additives was fully implemented, and in order to prevent consumers from misinterpreting them.

Regarding the labeling of terms such as "chemical seasoning" that are not mentioned in the regulations, and which is pointed out to have an impact on consumers' understanding of additives, it is desirable to hold discussions during the review of the guidelines shown in (2)(ii)(a) (labeling such as "-free", "non-use", etc.) at the same time, so that the business operators wouldn't use those terms on the labels as well as advertisements.

Source: Report on Discussion about the Labeling System for Food Additives

Main revision contents

The amendments to Food Labeling Standards are as follows.

Based on Report on Discussions about the Labeling System for Food Additives, the table of Article 3 Paragraph 1 of the standard, which defines the cross-sectional mandatory labeling items of general processed foods, Appended table 6 and Appended table 7 are to be revised and the terms "Artificial" and "Synthesis"are to be removed.

[ Revision Proposal Table of Article 3, Paragraph 1 (Cross-sectional mandatory labelling) ]

Additives
Current

1 Except for the items listed below, in descending order by weight (within additives):
- as for foods containing additives used as those listed in the upper column of Appended table 6, said substance names and usages (as stated in the bottom column of the table) must be indicated.
- as for the foods containing the other kinds of additives, the substance name of said additives must be indicated.

1 to iii (Omitted)

2 (Omitted)

3 Regardless of the provision of 1, as for the labeling of substance, names of additives whose names are widely used may be used. As for foods containing additives in the upper column of the Appended table 7, the labeling shown in the lower column of the same table may be used.

4 Regardless of the provision of 1, in the cases listed in each of the following items, the indication of the use specified in each item can be omitted.

i  Cases where the character "色 EN:colour" is included in a mention indicating additives are contained  colouring or Synthetic colouring

ii (Omitted)

The revision bill

1-3 (Omitted)

4 Regardless of the provision of 1, in the cases listed in each of the following items, the indication of the use specified in each item can be omitted.

i Cases where the character "色 EN:colour" is included in a mention indicating additives are contained  additive colouring

ii (Omitted)

[ The revision bill Appended table 6 (Usage of additives) ]

Sweetener Current Sweetener, Synthetic sweetener, or Artificial sweetener
The revision bill Sweetener
Colouring Current Colouring or Synthetic colouring
The revision bill Colouring
Preservative Current Preservative or Synthetic preservative
The revision bill Preservative
(Omitted)

[ The proposed revision bill Appended table 7 (Words that can be used as substitute to the additives substance names (collective name)) ]

(Omitted)
Flavouring Current Flavouring or Synthetic flavouring
The revision bill Flavouring
(Omitted)

In addition to these, further revisions are planned such as "Indication regarding types of blowfish used as ingredients" and "Indication regarding special ingredients" (adding "organic livestock products" accompanied by (JAS Law Enforcement Ordinance revised in January 2020 (effective date was on July 16, 2020)".

Future schedules

It has been promulgated and enforced (enforced on July 16, 2020, the same day as the JAS Act Enforcement Ordinance). As a transitional period, the conventional/existing labelling is permitted for processed foods manufactured, processed or imported up to March 31, 2022 (excluding processed foods for business use) and additives of processed foods for business use sold up to March 31, 2022.

For our readers who currently use the terms "Artificial" or "Synthetic" in the labels, we recommend to review not only the materials of the committee, but also the background such as the discussions minutes on the food additive labeling system.

References:
59th Food Labeling Committee (Cabinet Office Consumer Committee)
Document 1-1 Partial revision of Food Labeling Standards May, 2020 (Food Labeling Planning Division, Consumer Affairs Agency)

August 2020