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Label bank

Regarding beverage labeling targeted for 20 years and older (Japan)

In the liquor section of supermarkets and other stores, you will see a variety of products every day. Some are alcoholic beverages, some are non-alcoholic beverages with tastes like alcohol, and some are not categorized in alcoholic beverages but contain alcohol and I feel we have more options about drinking alcohol.
In this article, we will take a look at each of the products you see in a liquor section, looking at their definitions from the perspective of alcohol content and what kind of labeling is required.

About Alcoholic Beverages

Liquor Tax Act provides the following definition of alcoholic beverages.

Article 2 The term "alcoholic beverages" used in this Act shall mean beverages containing 1 % or more of alcohol (those that can be diluted to make beverages with an alcohol content of 1 % or more (including those that can be diluted to make beverages with an alcohol content of 1 % or more (excluding those with an alcohol content of 90 % or more that are not produced by a person who have obtained an alcoholic beverage production license pursuant to the provisions of Article 7, Paragraph 1 as ingredients for alcoholic beverages at the production facility that has obtained said production license) , OR powdered products that can be dissolved to make beverages with an alcohol content of 1 % or more.)"

From this definition, we can see those alcoholic beverages are beverages with an alcohol content of 1% or more.
Alcoholic beverages, such as sake, fruit wine, beer, etc., have different definitions for each category, and each category also has different labeling requirements. For example, according to Food Labeling Standards, alcoholic beverages do not need to be labeled with the ingredients list, but beer is required to be labeled with ingredients list under Fair Competition Code, and sake is required to be labeled with the names of ingredients under Quality Labeling Standards for Sake Manufacturing Processes. In addition, Japan spirits & liqueurs makers association has established voluntary standards for ingredients list labeling in low-alcohol liqueurs, stating that "low-alcohol liqueur" in these standards means a liqueur with an alcohol content of less than 10 %, among liqueurs defined in Article 3, Item 21 of the Liquor Tax Act. Some different standards or criteria need to be checked depending on the alcohol content other than their items.

On the other hand, one of the common labeling requirements among alcoholic beverages is the labeling regarding the prevention of drinking alcohol by persons under 20 years old. Labeling such as "Drinking by persons under 20 years old is prohibited by law", "Drinking alcohol is permitted only after turning 20 years old", etc. is required in accordance with "Labeling standards for the prevention of alcohol drinking by persons under 20 years of age".
You may have seen a warning labeling that says "Underage drinking is prohibited by law".
The use of the term "underage" is possible only until the end of March this year, and after April 1, it will be necessary to use the term "those under 20 years old".
The following is an excerpt from the "Partial Amendment to Labeling Standards for the Prevention of Underage Drinking" for easy comparison. According to the Standard, the term "underage" in the subject (the point to establish labeling standards for the prevention of underage drinking) and labeling standards (labeling standards for the prevention of underage drinking) has been changed to "persons under 20 years of age".

After the revision Before the revision
Labeling standards for the prevention of alcohol drinking by persons under 20 years of age
(Labeling on containers or packages of alcoholic beverages)
  1. Containers or packages of alcoholic beverages (hereinafter referred to as "containers, etc.") shall be labeled "Drinking by persons under 20 years of age is legally prohibited".
  2. The label stipulated in the preceding Paragraph shall be clearly displayed in an easily viewable place on the container, etc., and the characters for the label shall be 6 point type or larger (meaning the point type stipulated in the Japanese Industrial Standards Z 8305 (1962). The same shall apply hereinafter.) and well-formed Japanese characters. However, for containers with 360 ml or less net weight, a font size of 5.5 point type or larger is acceptable.
Labeling standards for the prevention of underage drinking
(Labeling on containers or packages of alcoholic beverages)
  1. Containers or packages of alcoholic beverages (hereinafter referred to as "containers, etc.") shall be labeled "Underage drinking is legally prohibited".
  2. The label stipulated in the preceding Paragraph shall be clearly displayed in an easily viewable place on the container, etc., and the characters for the label shall be 6 point type or larger (meaning the point type stipulated in the Japanese Industrial Standards Z 8305 (1962). The same shall apply hereinafter.) and well-formed Japanese characters. However, for containers with 360 ml or less net weight, a font size of 5.5 point type or larger is acceptable.

Supplementary Provisions

  1. This Notice shall come into effect from the date of enforcement of the Act for Partial Revision of Unfair Competition Prevention Act, etc. (July 1, 2019).
  2. During the period from the date of enforcement of this Notice to March 31, 2022, the labeling stipulated in Paragraphs 1, 6 (excluding the part pertaining to the letters used in labeling), and 7 may still be applied according to the previous provisions.

Non-alcoholic beverages

"Voluntary code for the advertising and marketing of alcoholic beverages and the labeling of alcohol beverage containers" provides the definition of non-alcoholic beverages as follows.

Non-alcoholic beverages are beverages containing 0.00% of alcohol by volume that taste similar to alcoholic beverages intended and recommended for adult consumption for persons 20 years of age or older.

Since the alcohol content is 0.00%, the legal name in the collective labeling frame should be "soft drink" or "carbonated drink," as is the case with general beverages. However, since non-alcoholic beverages are intended to be consumed by adults, the voluntary standards stipulate the following criteria for labeling containers, etc.

  1. Indicate on the product that it is intended for persons 20 years of age or older.
  2. The same brand name as existing alcoholic beverages or similar designs that may cause misleading shall not be used.

Beverages containing alcohol (less than 1%)

Beverages containing less than 1% alcohol, such as 0.3% or 0.5%, are not classified as either "alcoholic beverages" or "non-alcoholic beverages". There are no defined standards for beverages containing less than 1% alcohol at present. Therefore, they are not classified as alcoholic beverages in spite of the fact that they contain alcohol and they are labeled as "soft drinks", "carbonated beverages", etc. for the legal names in the collective labeling frame in the same way as for non-alcoholic beverages.
Since it is not an alcoholic beverage, the labeling of alcohol content and the prevention of alcohol drinking by those under 20 years of age is not mandatory, but it is probably recommended that such beverages with low alcohol content be labeled as containing alcohol and preventing persons under 20 years old from drinking in the same way as alcoholic beverages, and be labeled as intended for people 20 years or older in the same way as non-alcoholic beverages.

The intention that the target consumers are 20 years of age or older for the products needs to be informed when considering the labeling of the products. As new products will be developed and marketed in the future, we hope that this information will be helpful for labeling purposes.

March 2022