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Regarding the labeling of "multivitamins" and "rich in vitamins"

Statistics Bureau of Ministry of Internal Affairs and Communications have announced in the "Household economy survey" that monthly expenditure in September of two-or-more-person households on online shopping was JPY 15, 981, a 2.6% increase compared to the same period of the previous year. Speaking of last September, there was a surge in demand before the consumption tax hike. This time increase exceeded it and a noteworthy fact among them is the expenditure on "health foods" was JPY 670, a 21.6% increase compared to the same period of the previous year, a double-digit increase for six consecutive months.
This shows the increasing needs for shopping online by those who have been refraining from going out because of the Covid-19 Pandemic and consciousness towards their health.

Recently, at stores, I tend to pick up a health food containing vitamin D, which can be obtained not only by eating but also by sunbathing, because I have fewer chances to go out. Many people might pick up "multivitamins" products with the idea that it would be better if they could take not only vitamin D but also other vitamins.

By the way, the Provisions of Nutrient Content Claims are not applicable to the products with no "High" or "Low" claims but only nutrient names such as "multivitamins" conspicuously labeled on containers and packaging. But did you know that the amount of the nutrients must be indicated in the Nutrition Facts frame for such products, too? Since a group name, "vitamins" is labeled, it is required to indicate all of the following vitamin nutrients specified in Food Labeling Standards in Nutrition Facts.

Nutrients listed in Appended Table 9 of Food Labeling Standards (13 types of vitamins)

Niacin, Pantothenic acid, Biotin, Vitamin A, Vitamin B1, Vitamin B2, Vitamin B6, Vitamin B12, Vitamin C, Vitamin D, Vitamin E, Vitamin K, Folic acid

Assuming that there is a product labeled "rich in vitamins!", the labelling of the above vitamins corresponds to the "High" claims of "Nutrient Content Claims", and all the above vitamins contained must be the same as or more than "the standard value for High claims". In addition, it is not allowed to display certain values obtained by rational estimation (including display of "this labeling is a guide", "estimated value", etc.).

If not all of the above 13 types, but only some of the vitamins actually meet the criteria for Nutrient Content Claims, each of their specific nutrient or descriptions which clearly shows each nutrient name are necessary to be labeled such as:
- "vitamin C" or "vitamin D"
- "5 kinds of vitamins (vitamin A, vitamin B1, vitamin B2, vitamin B6, vitamin B12)"
not using a general group name such as "vitamins".

The same applies to "minerals", and when claiming with a general group name, all the minerals must meet the criteria.
In addition, labeling of nutrients to which Food Labeling Standards are applied to is labeling in Japanese such as "ビタミンDたっぷり!" and so on. However, even though labeling in Japanese appears as a whole, it is not appropriate to label using other languages only for the nutrient content claims inapplicable to Food Labeling Standards (e.g. High calcium, etc.).

If any of you handle or manufacture products with general group names such as "vitamins" and "minerals," how about taking this opportunity to reconfirm those claims on "health foods", which have been gaining attention.

By the way, monkfish liver is rich in "vitamin D" and widely used for hot pot dishes, which is the iconic food of winter in Japan. It would be a good idea to take some seasonal ingredients and "health foods" together.

"The guideline for Nutrition Facts labeling based on Food Labeling Act" (pg11,14,23)
Food Labeling Standards Appended Table 9 (pg1 ~)
Household economy survey

January 2021