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Inspection methods for unintentional presence of genetically modified agricultural products
"Regarding Food Labeling Standards" partly revised (Japan)

The 24th revision of "Regarding Food Labeling Standards" was implemented on the 15th of September 2021, and newly established inspection methods for unintentional presence of genetically modified agricultural products and the addition of inspection equipment were announced.

Main Points

  • In "Attachment Inspection methods for genetically modified foods of which safely inspection have been completed" in the notice "Regarding Food Labeling Standards"
  • About non-genetically modified grains of soybeans and corns under separate production and distribution management
  • Inspection methods for unintentional presence of genetically modified agricultural products were newly established and some inspection equipment, which is allowed to use for the current inspection methods, were added.

Background of the revision

The background of the revision is based on the fact that "(2) Labeling methods ② labeling methods for ‘non-GM’" in the "Report on discussions on the labeling system for genetically modified foods" published by the Consumer Affairs Agency (CAA) on the 28th of March 2018 have been summarized as follows.

Some consumers request that "unintentional presence " should be as low as possible, however, considering the possible difficulty in stable procurement of ingredients by business operators and increase in workload and costs related to inspections for an allowable rate, etc., the maintenance of the current system, under which 5% or less than presence regarding soybeans and corns is considered as appropriate. With regard to the requirements for "non-GM" labeling, there are some opinions that it can be misleading to label a product as "non-GM" even when GM agricultural products in soybeans and corns are present (up to 5%). Thus, from the perspective of preventing misunderstandings, ensuring the accuracy of labeling, and expanding the range of choices available to consumers, it would be appropriate to lower from their current requirements (equal to or lower than 5%"), to "Not detected." In lowering the level, it is necessary to establish new official inspection methods to ensure smooth verification and monitoring, and to fully inform businesses and consumers with caution that the new labeling system will not cause any confusion considering the possible impacts on current manufacture, distribution, consumption of food products. The establishment of new official inspection methods should be balanced between accuracy and feasibility such as the current official quantitative inspection methods to judge the contamination rate of genetically modified agricultural products.

Main points of the revision

The added inspection methods are as follows, There are many revisions of notices other than the inspection methods, so please refer to the 24th revision "(attached) The old and new comparison table" for details.

2.2. The inspection methods of grains of soybeans (Inspection methods for determination of generally modified agricultural product contamination)

2.2.1. Qualitative PCR methods using Real-Time PCR

2.2.1.1. Qualitative PCR using ABI PRISM® 7900HT 96 well

2.2.1.2. Qualitative PCR using Applied Biosystems® 7500

2.2.1.3. Qualitative PCR using QuantStudio 5

2.2.1.4. Qualitative PCR using QuantStudio 12K Flex

2.2.1.5. Qualitative PCR using  LightCycler® 96

2.2.1.6. Qualitative PCR using LightCycler® 480

2.2.2. Judgement of results

2.4. The inspection methods of grains of corns (Inspection methods for determination of genetically modified agricultural product contamination)

2.4.1. Qualitative PCR methods using Real-Time PCR

2.4.1.1. Qualitative PCR using ABI PRISM® 7900HT 96 well

2.4.1.2. Qualitative PCR using Applied Biosystems® 7500

2.4.1.3. Qualitative PCR using QuantStudio 5

2.4.1.4. Qualitative PCR using QuantStudio 12K Flex

2.4.1.5. Qualitative PCR using LightCycler® 96

2.4.1.6. Qualitative PCR using LightCycler® 480

2.4.2. Judgement of results

It is necessary for those who handle foods exported to Japan to be aware that the confirmation of "whether the safety inspection for your products has been completed" is needed as well.

"Only the requirement, "Not detected", allows non-GMO labeling

The purpose of the inspection is to confirm whether there is "unintentional presence" is "5% or less" or "Not detected". In response to "Report on discussions on the labeling system for genetically modified foods" mentioned above, "’non-GM’ labeling" is not allowed except "Not detected" according to the revision of Food Labeling Standards in April 2019. In case it is 5% or less, it will be possible to (voluntarily) mention on the label that the food was treated under "separate production and distribution management".

Here is the excerpt from the material, (material 4) Guidance of draft of partial revision of the Cabinet Office Ordinance relating to new GMO labeling system (the 10th of October 2018), used in the 46th Food Labeling Section Meeting (Consumer Commission (Cabinet Office)).

labeling system

Main points of revision in April 2019

The requirements for a "non-genetically modified" labeling will be made stricter from their current state (i.e. "unintentional presence of genetically modified soybeans and corn should be equal to or lower than 5%") to "Not detected."
In the case where there is 5% or less, voluntary labeling indicating separate production and distribution management is appropriately implemented is allowed.

The transitional period for the revision of Food Labeling Standards (April 2019)(the revision of GMO labeling system) ) is until March 31, 2023.
I assume that some of the readers who handle products with "non-GM" labeling" have already prepared. I would be grateful if this article is helpful and provides an opportunity to understand the Japanese labeling system for GMO for others, too.

November 2021