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Moving toward mandatory labeling for walnut (Japan)

walnutAs a new move by the Consumer Affairs Agency (CAA) regarding allergen labeling, experts exchanged views on the mandatory labeling of walnut at The 1st Advisors' Meeting on Food Allergen (February 15, 2021).
Therefore, I would like to look back at the process of making walnut mandatory by the contents of the meeting held this time, as well as look at the future issues to be considered that have been put forward for making it mandatory.

As for labeling foods containing allergens, almond has been added as a "Specified raw material equivalent" (a recommended labeling item for allergens in Japan) for one and a half years (No.322, September 19, 2019), we believe that you have reviewed ingredient formulations and labeling of your products in response to this.
As shown in the table below, almond has been added to the 20 "Specified raw material equivalents" and make them to be 21. On the other hand, walnut, currently listed as one of the 21 items of "Specified raw material equivalents", is considered to be included in the current 7 "Specified raw materials" (mandatory labeling items for allergens in Japan) to make them 8.

Classification and Specification Item Remarks About labeling
7 "Specified raw materials" (mandatory labeling items for allergens)
(Considering whether to add one more item)
Shrimp, Crab, Wheat, Soba (Japanese buckwheat noodle), Egg, Milk, Peanuts
(Considering whether to add walnut)
Particular items that should be labeled in consideration of the number of onsets and severity of the symptom Mandatory labeling
21 "Specified raw material equivalents" (recommended labeling items for allergens)
(-1 item, since walnut is considered to be included in "Specified raw materials")
Almond, Abalone, Squid, Salmon roe, Orange, Cashew nuts, Kiwifruit, Beef, Walnut, Sesame seed, Salmon, Mackerel, Soybean, Chicken, Banana, Pork, Matsutake mushroom, Peach, Yam, Apple, Gelatin Although the considerable number of allergy cases and patients with severe symptoms have continuously been seen, the number is smaller compared to that of "Specified raw materials" (mandatory labeling items for allergens). Recommended labeling
(Voluntary labelling)

First of all, the reason why walnut is added to mandatory labelling is that there seems to be a rapid increase in the number of allergy cases caused by walnut in recent years.
As the following information from the meeting materials indicates the number has certainly increased significantly.

According to the detailed data in the same document, the number of allergy cases in fiscal year 2018 was the fourth highest after eggs, milk, and wheat in terms of both immediate and shock allergy cases, and the number outweighs the cases caused by other ”Specified raw materials” such as peanut and shrimp.

(Excerpted from "[Material 2] Background of mandatory labeling of walnut, etc. ")

5. Consideration for walnut to be added to mandatory labelling items

At the Consumer Commission Food Labeling Section Meeting in July, 2019, a report was made on the start of discussion for adding walnut to the mandatory labeling items based on the report of nationwide fact-finding surveys until FY 2008.

Substance that causes allergy Classification Fiscal year of 2012 Fiscal year of 2015 Fiscal year of 2018 Correspondence

Walnut

Number of immediate allergy cases

40

74

251

Consideration to make labeling mandatory

Number of shock cases

4

7

42

This information has been introduced in our previous Newsletter as follows, so I would like you to see it together.

Food Labeling Newsletter September, 2019:

"Almond" is added to the list of foods recommended to use allergens labeling and "walnut" is changed from recommended to mandatory

In addition, at the time the above report was issued in July 2019, the following points were listed as points to be considered for walnut’s mandatory labeling.

  • It is necessary to confirm whether the number of cases this time was transitory
  • When designating an item for mandatory labeling, the development and validation of test methods should be conducted from the perspective of ensuring implementation.

Based on the above history, the following issues were listed as discussion subjects at this meeting, and are planned to be tackled as a top priority.

1.Consideration for mandatory labeling of walnut
  1. Identifying of necessary research projects
  2. Analysis of results of survey projects, etc. and summary of plans

Looking at the minutes of the meeting held on July 5, 2019, it seems that the development of a test method to detect allergens to walnut and its verification are urgent issues to be addressed in the future.

As mentioned above, the meeting held this time did not indicate a specific timing for mandatory labelling for walnut. It seems that the research toward making it mandatory will start from now on.
However, for those of you who use walnuts as an ingredient in your food products, or who are considering doing so, I suggest that you take this meeting, where the consideration of mandatory labeling for walnut has started, as an opportunity to review your recipes and labeling content ahead of time. Especially for those who label only 7 existing "Specified raw materials", I think that it is necessary to examine the labeling again.
In addition, it may be a good opportunity to review "Specified raw material equivalents" including almond as well.

References:
(No. 322 on September 19, 2019) [PDF:144KB] - CAA
The 1st Advisors' Meeting on Food Allergen (February 15, 2021) (CAA)

April 2021