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New labeling system of countries of origin of ingredients (Japan)
~Six months until end of transitional measures period~

"Fair Competition Code concerning labeling of dressings", "Fair Competition Code concerning labeling of hams and sausages", "Fair Competition Code concerning labeling of fermented milk/fermented milk drinks", etc.
These are the rules that were revised this June. The items of "names of countries of origin of ingredients" have been added to all of the rules to ensure consistency with Food Labeling Standards. New labeling system of countries of origin of ingredients for processed foods came into force four years ago, and its transitional measures period is to end in about six months. We would like to organize the content of the system again before that.

Foods subject to labeling countries of origin of ingredients

All processed foods (excluding imported products) manufactured or processed in Japan for the purpose of providing information to consumers.

Target ingredients

Ingredients with the highest weight ratio to all the ingredients (Top 1 ingredient by weight). However, 22 food groups indicated in the Appended Table 15-1 of Food Labeling Standards and 5 food items of pickling ingredients have their specifications for countries of origin of ingredients, which stipulate their target ingredients. There are also some foods not subject to labeling countries of origin of ingredients because they already have some specifications based on other acts. Please refer to Food Labeling Standards Q&A (COI (countries of origin of ingredients) -2)For further information.

Labeling methods

Now we would like to check the revised content by looking at the examples indicated in Food Labeling Standards Q&A.

1. As for places of origin of target ingredients, "labeling by weight by country", in which the names of countries are listed in descending order by weight by country in the same way as the method used before the revision.

(COI -18) 1. (labeling countries of origin of ingredients in parentheses immediately after the name of the first ingredient in the list)
*Translation of the Japanese labeling

Legal name Pork Sausage (Vienna sausage)
Ingredients list Pork (Canada, USA), Pork Fat, Hydrolyzed protein (Contains Soybean・Pork・Gelatin), Reduced sugar syrup, Salt, Spice (Contains Soybean)/Seasoning(amino acid, etc.) Phosphate (Na, K), …

2. When the target ingredients are processed foods, "the place of manufacture" of the semi-processed ingredients used in the foods must be indicated.

(COI -42) 1. The case where When "apple juice" as a semi-processed ingredient is purchased and used
 (labeling countries of origin of ingredients in parentheses immediately after the name of the first ingredient in the list)
*Translation of the Japanese labeling

Legal name Soft drink
Ingredients list Apple Juice(produced in Germany), Fructose-glucose syrup, Fructose/Acidulant, vitamin C

3. When it is difficult to label "labeling by weight by country", "Or labeling" or "All Inclusive Labeling" under certain conditions is permitted.

◆"Or labeling"

"Or labeling" is a method of labeling in which multiple countries are connected by "or" in descending order by weight of ingredients expected to be used, based on actual usage of the ingredients of country of origin over a certain period in the past or a plan for use of the ingredients of country of origin for a certain period in the future.
This labeling method is allowed to use under the condition that the grounds materials are stored only when it is difficult to label in weight order by country such as the cases where
-the place of origin is expected to be switched within one year from the date of the labeling (manufacturing date)
in the view of the actual usage of the ingredients of country of origin over a certain period in the past (or a plan for use of the ingredients of country of origin for a certain period in the future when changes in new products or ingredients suppliers are certain.
In the case of "or labeling", labeling that indicating in descending order by weight of ingredients (use ratio for a certain period) based on actual usage of the ingredients of country of origin over a certain period in the past or a plan for use of the ingredients of country of origin for a certain period in the future must be made.

(COI -28) (e.g.1 the case where there are two countries of origin)
*Translation of the Japanese labeling

Legal name Pork Sausage (Vienna sausage)
Ingredients list Pork (Canada or USA), Pork Fat, Hydrolyzed protein (Contains Soybean・Pork・Gelatin), Reduced sugar syrup, Salt, Spice (Contains Soybean)/Seasoning(amino acid, etc.) Phosphate (Na, K), …

*The places of origin of pork are based on the actual usage in 2018

In this case, there are four patterns of labeling for places of origin such as "Canada only", "USA only", "Canada, USA (in this order)", "USA, Canada (in this order)". This pattern shows that pork from Canada has been used more than one from USA in the view of the actual usage of the ingredients of country of origin over a certain period in the past or a plan for use of the ingredients of country of origin for a certain period in the future.

◆"All Inclusive Labeling"

"All Inclusive Labeling" is a labeling method in which three or more countries of origin are lumped together and labeled as "imported". When using a mixture of imported and Japanese products, the products must be labeled in descending order by weight between imported and domestically made (in Japan).
This labeling method is allowed to use under the condition that the grounds materials are stored only when it is difficult to label in weight order by country such as the cases where regarding three or more foreign countries of origin
-the place of origin is expected to be switched within one year from the date of the labeling (manufacturing date)
in the view of the actual usage of the ingredients of country of origin over a certain period in the past (or a plan for use of the ingredients of country of origin for a certain period in the future when changes in new products or ingredients suppliers are certain.

(COI -33) (e.g.1 the case where there are three or more foreign countries of origin)
*Translation of the Japanese labeling

Legal name Soy Sauce, "koikuchi-shoyu" (authentically-brewed)
Ingredients list Soybean (imported), Wheat, Salt

The difference from "Or labeling" is that there is no need to indicate that labeling is based on actual usage of the ingredients of country of origin over a certain period in the past or a plan for use of the ingredients of country of origin for a certain period in the future.

◆"All Inclusive Labeling + Or labeling"

The "All Inclusive Labeling + Or labeling" is a method of labeling in which "imported" and "domestically made (in Japan)" are connected by "or" in order of the weight rate of ingredients expected to be used, based on past usage or a plan for use of the ingredients of country of origin for a certain period in the future.
It can also be used only when it is difficult to make "all Inclusive Labeling" in the view of the actual usage of the ingredients of country of origin over a certain period in the past or a plan for use of the ingredients of country of origin for a certain period in the future. This method also requires storing the grounds materials.
When "All Inclusive Labeling + Or Labeling " is used, the indication mentioning actual usage of the ingredients of country of origin over a certain period in the past or a plan for use of the ingredients of country of origin for a certain period in the future must be made.

(COI -36)
*Translation of the Japanese labeling

Legal name Pork Sausage (Vienna sausage)
Ingredients list Pork(Imported or Domestic (Japan)), Pork Fat, Hydrolyzed protein(Contains Soybean・Pork・Gelatin), Reduced sugar syrup, Salt, Spice(Contains Soybean)/Seasoning(amino acid, etc.) Phosphate (Na, K), …

*The places of origin of pork are based on the actual usage from June 2018 to May 2019.

In this case, there are four patterns of labeling places of origin such as "Imported only", "Domestically made (in Japan) only", "Imported, Domestically made (in Japan) (in this order)", or "Domestically made (in Japan) (in this order), Imported". Also, this means more imported products (total) have been used/will be used than domestically made (in Japan) products in the view of the actual usage of the ingredients of country of origin over a certain period in the past or a plan for use of the ingredients of country of origin for a certain period in the future.

Please refer to
-(COI -37) for labeling of "actual usage of the ingredients of country of origin over a certain period in the past or a plan for use of the ingredients of country of origin for a certain period in the future", which are needed for "Or labeling" or "All Inclusive Labeling + Or labeling"
-(COI -38) for "grounds materials to be stored"

In addition to the Food Labeling Standards Q&A, manuals and pamphlets are available from the Ministry of Agriculture, Forestry and Fisheries. We assume that many of you have already deal with countries of origin of ingredients labeling, but we hope this will be an opportunity for you to reconsider the labeling.

September 2021