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Revised Food Labeling Act (food recall system) to be enforced soon (Japan)

The "Law to partially amend the Food Labeling Act" promulgated on December 14, 2018, will come into effect on June 1, 2021. The main points of the amendment are as follows.

summary of the revision

  • In the case of voluntary recalls, notification to the administration agency (online in principle) is required
  • Notified information of the voluntary recall will be made public on the system (The system is scheduled to be operated by June 1).

As those engaged in food business know, there are more and more business operators entering food business these days through the change business model and review of business structure in response to the spread of Covid-19. I would like to organize the information here.

Labeling for which notification is to be mandatory

Foods sold without "Labeling according to Food Labeling Standards regarding Definitions set by the Cabinet Office Ordinance of Article 6, Paragraph 8" are the subjects of the voluntary recall. "Definitions set by the Cabinet Office Ordinance of Article 6, Paragraph 8" means labeling related safety such as indications that Allergens or L-Phenylalanine chemical compounds are present/contained, Used By/Expiration date, or whether or not the food needs to be heated, and if some of them are missing, or incorrect, they are subject to the voluntary recall.

The details of "Definitions set by the Cabinet Office Ordinance of Article 6, Paragraph 8" can be checked in "Cabinet Office Ordinance which specify allergens, expiration date, whether or not the food needs to be heated for safe ingestion or any other matters which impact on the safety of ingestion of food, which are specified in Article 6, Paragraph 8 of Food Labeling Act".
(Specifically, a number of labeling items are specified for categorized foods such as Foods with Health Claims, meat, meat products, dairy products, liquid Egg, fish and seafoods, frozen foods, etc. other than "Legal name", "Storage method", "Best Before or Used By/Expiration date", "Allergens", "Indication that L-phenylalanine compound is present/contained", "Items related to food containing designated ingredient, etc.".

The "case where voluntary recall is not required" was also announced on February 26, 2021.
e.g., "After a local food manufacturer sells foods with no ‘used by date’ to a privately-run retailer in the same district, the retailer suspends the sales of the product before selling to consumers, having been informed by the food manufacturer, and also consumption of the product by the retailer's staff is not expected" or "Labeling fish or shellfish as a food for heat processing but it was intended to be labeled as a food for raw consumption.

Moreover, the notification shows the classification of "CLASSⅠ" and "CLASSⅡ" according to damage to human health. "CLASS I" is "Labeling regarding indication that allergens (including items equivalent to specified raw materials (recommended labeling for Japan)) or L-phenylalanine compound is present/contained", and "CLASS II" is for other items. Please refer to "Notification of food voluntary recall based on Food Labeling Act Article 10-2, Paragraph 1(No.80)" for details.

About online notification and publication

The two major difference for business operators who have experienced voluntary recall and notifications in the past will be the change to "online notification" and "publication on the system".
Notification and publication are implemented on "Food sanitation application system"(the Ministry of Health, Labour and Welfare (MHLW)). The actual search screen image shown below will help you visualize this.

Food sanitation application system (Search for publicized recall cases)

Note: The actual screen is in Japanese only.

In this way, you will be able to search for information such as "Product name," "Name of notifier," "Reason for recall," " Method of picking up products for the recall " as well as "Degree of danger to health" by specifying by prefecture. In addition, the publicized recall cases include not only those due to violations of Food Labeling Act, but also voluntary recall information of violations of Food Sanitation Act (mold, pesticide residue, contamination by foreign objects).
(【Caution】This system is only for the voluntary recall cases of the products which have been distributed in Japan (including imported products). Many cases of violations found at the time of import (such as non-conformity to the standards for use of additives) can be searched in "Recent Cases of Violation of the Food Sanitation Act (MHLW)".

Notification for voluntary recall can be done here.

Food sanitation application system (Log-in for business operators)

Not all the settings of the system do not seem to have been completed (as of 25, April, 2021), but I think you can get a whole image of the system necessary for notification process.

For an opportunity to review your workflow

Cases of recall will be made public, so business operators as well as consumers can search for the information. It would be reference to inform you what kinds of food products have been recalled for what kinds of labeling and to be utilized for considering your workflow of labeling verification.

The manuals for the system and other information are expected to be added by the full enforcement on June 1. I hope that you will use this article as an opportunity to review or create your workflow of confirmation of food labeling.

June 2021