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Regarding revision of labeling system related to brown rice and milled rice (Japan)

On March 17, 2021, the Cabinet Office Ordinance on the Partial Revision of Food Labeling Standards was promulgated. The content of this revision is related to the labeling system of brown rice and milled rice.
I would like to take up this revision, which came into effect on July 1, 2021.

Summary of the revision of labeling system for brown rice and milled rice, and the basic labeling concept

Summary

Food labeling standards have been revised

  1. to enable to label the place of origin, variety, year of harvest even without agricultural products inspection certificates but under the condition where the material should be kept showing the grounds for a place of origin, variety, year of harvest for such labeling
  2. to enable to label a confirmation method of reasonable grounds such as agricultural products inspection certificate, etc., for labeling items,
  3. to enable the appropriate information when consumers select foods, such as producer's name, etc., to be indicated in a frame.

Basic labeling concept

The case for labeling as single raw rice

  • For raw brown rice of the same place of origin, variety and year of harvest, and for which documents showing the grounds for these pieces of information is kept, "単一原料米" (EN: single raw rice)must be indicated together with its place of origin, variety and year of harvest.
    ( In this case, a place of origin shall be indicated by the name of the prefecture, city, town or other generally known places for domestically produced products, and by the name of the country of origin or generally known place for imported products.)

The case for labeling as raw brown rise other than single raw rice

  • For raw brown rice that does not fall under the category of single raw rice, the indication is needed such as "複数原料米" (EN: multiple raw rice), etc. showing they don’t have the same place of origin, variety or year of production of raw brown rice, together with the places of origin and the percentages of use. In this case, the products must be listed separately each for Japan and country of origin for imported rice, in descending order of the percentages of use.
  • If you want to indicate the place of origin, variety or year of harvest, you may indicate the place of origin, variety or year of harvest given in parentheses following the "name of the country of origin and the percentage of use" in the labeling under the condition that the materials showing the basis for the indication are kept.

Indication of the method of confirming the information on the grounds of labeling

  • When you indicate the whole or a part of a place of origin, variety, and year of harvest, you may indicate the method of confirming the information on which the labeling item is based.

Quote: Regarding revision of labeling system related to brown rice and milled rice, March 2021 (Consumer Affairs Agency Food Labeling Planning Division)

"The term indicating the variety or the year of harvest for uninspected raw brown rice" which was specified in Article 23, Paragraph 2, Item 1 of Food Labeling Standards before the revision, has been deleted from the prohibited labeling items with this revision. In addition, Food Labeling Standard Q&A was revised on March 17 and new content was added for items related to brown rice and milled rice.

Specific labeling examples

I would like to show some of the labeling examples from Food Labeling Standards Q&A (Brown Rice Milled Rice - 2) 3. 4.

【In the case where it is certified by Agricultural Products Inspection Act】

(eg.1) In the case where all raw brown rice is certified by Agricultural Products Inspection Act and the method of confirming the information is indicated.

Raw brown rice Place of origin Variety Year of harvest
Single raw rice (certified by Agricultural Products Inspection Act)
XX Prefecture XXXX XX

【In the case where a part of raw brown rice is certified by Agricultural Products Inspection Act】

(e.g.4) In the case where using
-20% of raw brown rice, of which place of origin, variety and year of harvest are different, the material for the place of origin, variety and year of harvest use is not kept, or no indications of which place of origin, variety and year of harvest are made, and
-80% of raw brown rice certified by Agricultural Products Inspection Act and the method of confirming the information is indicated.

Raw brown rice Place of origin Variety Year of harvest Content ratio
Multiple raw rice
Produced in Japan
    100%  
( XX Prefecture XXXX XX 80% )
certified by Agricultural Products Inspection Act

I would like to show some of the labeling examples from Food Labeling Standards Q&A (Brown Rice Milled Rice - 2) 3. 4.

【In the case where certification by Agricultural Products Inspection Act is not obtained】

(e.g.6) In the case where materials showing the grounds on the place of origin, variety and year of harvest are kept and how to confirm such information is labeled

Raw brown rice Place of origin Variety Year of harvest
Single raw rice (Confirmed by voluntary standards of XX Rice)
XX Prefecture XXXX XX

*Our voluntary standard is based on confirmation by XXXX.

The method of confirming a place of origin, variety and year of harvest is a labeling item that a person responsible for the labeling content can make an indication voluntarily, therefore, not "a must" since it is not mandatory labeling. However, it is considered desirable to indicate this information because it contributes to consumers' voluntary and rational selection of products. (Food Labeling Standards Q&A (Brown Rice Milled Rice-3))

About materials showing the grounds

In the Q&A of the Food Labeling Standards (Brown Rice Milled Rice-19), the following is information on the grounds for labeling all or part of a place of origin, variety and year of harvest.

  1. Specifically, the production stage materials include
    1. For products that have been certified by Agricultural Products Inspection Act, agricultural products inspection certification (a certificate from the public institution, etc. of the exporting country for imported products), or
    2. for products that have not certified by Agricultural Products Inspection Act,
      1. materials that show what kind of seeds and seedling were used to produce (e.g. purchase records, etc. of seeds), and
      2. materials that show the cropping status per variety to the whole cropping status (official document such as 水稲共済細目(Current status reports on changes in detailed items for crop insurance of wetland rice)), farming plan/journal, etc.
  2. In addition to 01 or 02 above, as a material for the distribution stage according to the actual distribution status
    1. Specifications indicating places of origin, variety, year of harvest of raw rice, invoices, delivery receipts, customs clearance certificates (in the case of imported products), and
    2. Documents that show the raw rice was actually used (instructions for preparing, milling, and subdividing rice, receipt and delivery records of raw rice, rice milling records, rice polishing ledgers, etc.) may be used.
  3. At any case, it is necessary that the materials showing clearly the mutual relationship between raw rice and the product are kept. If the raw rice cannot be traced back accurately, then the case is not considered that the materials showing the grounds.

Materials showing the grounds for these labeling must be kept for three years from the date of preparation, milling or import by the person responsible for the content of labeling on the products sold to consumers. However, in some cases, it may be acceptable for the producers, etc. to keep some of the materials showing the grounds. Please refer to Food Labeling Standards Q&A for further details.

Also, the partial revision of Food Labeling Standards this time allows labeling of "appropriate labeling items that contribute to consumer’s selection of products" in mandatory frame. Producers and sellers can indicate information that they want to claim to consumers in their original ways as additional value in mandatory frame as long as the information will contribute to consumer’s selection of products. Specifically, the information can be a name of the producer, storage method, the fact that the rice is 分つき米(rice that has been milled with some of the germ and bran left out of the brown rice), analytical data indicating the eating quality, award history of competitions, etc.

This is the major revision for business operators who handle brown Rice/milled rice. We hope this article will provide you with an opportunity to check the content and requirements for acceptable labeling and future consideration for labeling.

July 2021