Dissecting Changes in new Japanese Food Labeling Standard

From April 1, 2014 to March 31, 2015 the Consumers Affairs Agency (CAA) made a concerted effort to publicly discuss proposed changes to the Japanese Food Labeling Standard, as well revise its regulatory language to provide greater clarity to those in the industry. The changes were primarily designed to supply consumers with clear, coherent labeling on food products. The Standard, which applies to all food and drinks sold in Japan, does not require nutritional labeling on fresh foods, alcoholic beverages, products created by companies employing less than 20 individuals, or products imported by companies employing less than five individuals. Upon completion of the WTO notification procedure, the Standard was introduced in April 2015 with an implementation period set for five years for labeling of processed products and food additives and one and a half years for fresh products.

Below are the significant changes ushered in under the new Standard:

  1. Unified Categorization of Food Products: Given the previous confusion surrounding the categorization of processed and fresh foods under both the Japan Agricultural Standard(JAS) Law and Food Sanitation Act, the Standard provides clear framework for the classification of products as either fresh food, processed food, or a food additive.
  2. Modification to Manufacturer Identification Codes: The Standard dictates new rules for the use of ID codes, which are now only authorized for use on products manufactured in multiple factories (if produced at a single site, name and address of facility is needed). ID codes must also be accompanied with contact info or a website address, otherwise the manufacturer must provide the names/addresses of production facilities. All labels require the name/address of both the manufacturer and distributor (similar rules apply to imported products).
  3. Alteration to Labeling of Allergen: Allergen now require individual labeling, meaning each ingredient containing an allergen must be listed (ex. Whey [including milk]). View the updated list of mandatory and suggested allergens, here (in Japanese).
  4. Nutritional Facts Labeling: The Standard calls for all processed foods and additives to incorporate nutritional labeling on packaging. Manufacturers/importers are now permitted to determine the serving size of their product, and what constitutes a “reasonable serving.” Lastly, three groupings were defined for the elements of nutritional labeling: mandatory, voluntary but recommended, and voluntary. For a complete breakdown of the groupings, click here.
  5. Revision of Claim Regulation: New standards are established for product content claims under the Standard. For instance, when claiming that a product contains a reduced amount of specific nutritional component, the actual difference must amount to a 25 percent difference (or more) from the previous formulation. Claims of “no added sugar” and “no added salt” are now permissible under certain conditions.
  6. Change to Rules Regarding Nutrient Function Claims System: Food products with nutrient function claims are now permitted to create claims regarding the following nutrients: vitamin K, n-3 fatty acid, and potassium. Fresh foods (excluding eggs) are now exposed to functional nutrition food standards.
  7. Amendment to Labeling of Food Additives: When manufactured for commercial sale, food additives must provide a detailed label consisting of the following: name of additive, contents (including percentage of each ingredient), amount, expiration (to be printed on box), storage instructions, and name/address of the distributor and manufacturer.
  8. Change to Food Labeling Layout Requirements: Regardless of the total surface area of a container/package, manufacturers and importers now must provide the following on a product’s label:  product name, storage instructions, expiration date, contact information of manufacturer, allergen (if applicable), and L-phenylalanine compounds (if applicable).       

How can Manufacturers Stay Compliant?

As the official end of the implementation period approaches (March 31, 2020), manufacturers may feel the pressure of the impending enforcement period (April 20, 2020). Nonetheless, resources remain to aid in the preparation of changes to the food labeling standards. Over the last five years, the CAA and health authorities at municipal governments have hosted seminars and workshops designed to assist manufacturers in comprehending the amendments to the Standard. Fear not if you’ve missed out on these opportunities, as the CAA has made documents available that offer guidance for the industry. Additionally, questions about the Standard can be directed to the CAA or local government. Once the enforcement period begins, authorities will carry out regular market surveys on food labels and will pinpoint improper labels for penalization.    

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