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About labeling of "low salt" and "no sugars"
~Referring to the trend of low-salt-low-sugar labeling overseas~

In September 2021, Center for Food Safety (CFS) of Food and Environmental Hygiene Department (Hong Kong) announced the "low-salt-low-sugar" mark as a new strategy, which can be voluntarily labeled on pre-packaged foods. As more concerns for sodium (salt) and sugars have globally been raised against the background of the growing health consciousness, I would like to summarize the current food labeling standards system in Japan regarding "low salt" and "no sugars" in this article.

About indicating the ability of a food to ensure the proper intake of certain nutrients (indication that it is "XX not contained"/"low XX"/" XX reduced" (Japan)

The standards of claims such as "no sugars", "low salt", " reduced 25% sugars", etc. are stipulated in Appended Table 13 of Food Labeling Standards as "indicating the ability of a food to ensure the proper intake of certain nutrients/calories". When making "the indications that it is not present/contained" such as "no sugars", the content value of the target nutrient must be less than its standard value. For "low claims" such as "low salt", the content value of the target nutrient is equal to its standard value or less. As for "indications that it is reduced" such as "reduced 25% sugars" the reduced amount of the reduced nutrient compared to other foods of the same type must be equal to its standard value or more and also the reduced rate must be 25% or more. In addition, there are no regulations for "available carbohydrate", it is up to business operators to decide to make a claim such as "XX% off available carbohydrate" on products.

Nutrients The labeling standard values for not present/contained claims The labeling standard values for low claims The labeling standard values for reduced claims
per 100g (value in parentheses is per 100 ml of liquid food generally used for drinking)
Sodium 5mg(5mg) 120mg(120mg) 120mg(120mg)
Sugars 0.5g(0.5g) 5g(2.5g) 5g(2.5g)

For more specific labeling examples, please refer to "For business operators: The guideline for Nutrition Facts labeling based on Food Labeling Act, the 3rd edition".

Indications that it is not present/contained: No xx, xx zero, non-xx, etc.
Indication that it is low: low xx, xx reduced, xx light, diet xx, etc.
Indications that it is reduced: 30% less XX, 10g less XX, 50% less XX, etc.

Appended Table 9 of Food Labeling Standards stipulates the measuring method of nutrients. Sodium measured by "Atomic absorption spectrophotometry" or "Inductively coupled plasma atomic emission spectrophotometry" is converted into salt equivalent (Salt equivalent (g ) = Sodium (mg) ×2.54÷1000 ).
The value is to indicate to a first decimal place as salt equivalent in Nutrition Facts. Sugars are measured by "Gas chromatograph or High performance liquid chromatography". In addition, regarding sugars, it is important to note that the definition that sugars must be monosaccharides or disaccharides and confined to "not sugar alcohol".

Regarding indication that no xx is added (Japan)

Article 7 of Food Labeling Standards stipulates "indication that no xx is added" regarding " claims such as "Salt not added", " Non-use of salt", "Sugars not added", "Non-use of sugar", etc. Since sodium salt is used not only for sodium chloride but also for additives of seasoning such as Trisodium phosphate, Monosodium glutamate, the substance name must be checked. Sugars are defined as "only monosaccharides or disaccharides, and not sugar alcohols," and examples include sucrose, dextrose, honey, and corn syrup.

Indication that no sodium is added

"Indications that no sodium is added" is allowed to label when meeting all of the following items.

  1. No sodium salt must be added (However, this does not apply when sodium salt other than common salt is added for technical purposes and the amount of sodium contained in said food is less than the standard value specified in the third column of Appended Table 13).
  2. No alternative ingredient (including compound ingredients) of sodium salt (limited to those added) or no alternative additives of such are used.
Indication that no sugars are added

"Indications that no sugars are added" is allowed to label when meeting all of the following items.

  1. No sugars added
  2. No alternative ingredients (including compound ingredients) of sugars (limited to those added) or no alternative additives of such are used.
  3. Content of sugars of the food does not exceed the amount contained in the ingredients and additives by enzymatic decomposition or some other method.
  4. Content of sugars per 100g/100ml or per serving/package/other unit of the food must be labeled.

Examples of alternative ingredients of sodium salt are indicated in "Regarding Food Labeling Standards" such as Worcester sauce, pickles, pepperoni, soy sauce, salted fish, fish sauce, etc. Specific examples of "alternative ingredients of sugars" are jam, jelly, sweetened chocolate, sweetened fruit piece, fruit juice concentrate, dried fruit paste, etc.

Other labeling methods (marks, etc.) except Nutrition Facts (Japan)

The Consumer Affairs Agency (CAA), which is the implementing body of Food Labeling Standards in Japan, does not distribute any marks that promote labeling claims. As examples of efforts made by organizations other than CAA, there is "かるしお認定マーク (EN:"KARUSHIOH" Certification Mark, which is a mark indicating low salt food)" by the National Cerebral and Cardiovascular Center and "ロカボマーク(EN: Locabo mark, which is a mark indicating low available carbohydrate food )" by Eat & Fun Health Association.

Overseas trend

The standard for labeling claims in Hong Kong, as mentioned in the beginning, is stipulated in Food and Drugs (Composition and Labelling) Regulations (Cap.132W). The "low-salt-low-sugar" mark(figure1) announced in September 2021, which is allowed to use upon application to the Centre for Food Safety (CFS) of the Hong Kong Food and Environmental Hygiene Department, is intended to promote the development of low-salt and low-sugar foods by the food industry.

figure1: "Salt/Sugar" Label Scheme for Prepackaged Food Products (Hong Kong)

In Canada, Health Canada is proposing mandatory front-of-package (FOP) labeling foods high in nutrients that are a public health concern. These nutrients are sugars, sodium, and saturated fat. Four proposed nutrition symbols(figure2) as FOP labeling such as designs of "High in sugars", "High in sodium" are being considered.

Food Front-of-Package Nutrition Symbols (Canada)

figure2: Food Front-of-Package Nutrition Symbols (Canada)

In the U.S. the labeling item of added sugars became mandatory in 2018 when the Nutrition Facts Labeling System was revised. The definition of added sugars includes sugars that are added during the processing of foods, sugars from syrups and honey, and sugars from concentrated fruit or vegetable juices, etc.

The revision plan for Nutrition Facts labeling has not been announced in Japan, but foods with claims such as "low salt", "no sugars", etc. are widely available. (Foods, which lead to excessive intake of sodium or sugars, are not subject to Foods with Function Claims). I hope this article will be a helpful reference not only when you sell foods with claims but also when you plan to import new products into Japan or export ones overseas.

December 2021