Today we published a guest post from our friends from Osaka, Label Bank ! (see link at the end of the article for more info)
Although many products complying with the new food labelling standards (hereafter: FLS) have arrived on the Japanese shelves since their implementation on April 2015, a transitional period of 5 years has also been given (till 31 March 2020) during which the labeling of processed food and additives according to the old FLS is still allowed, however depending on the purpose of the product:
General use (B2C): products manufactured, processed or imported to Japan by 31 March 2020
Business use (B2B): products sold by 31 March 2020
Furthermore, based on the “Summary of the Food Labeling Standards” issued by the Consumer Affairs Agency, the main changing points in the new FLS are as listed here:
1 Standardization of the classification between processed food and perishable food: Now follows the line of thinking of the previous JAS law (ex: even simply processed food like dried fruits are classified as “processed”)
2 Amendment of rules regarding the use of Manufacturer Identification Codes: Which strictly concern products that are produced in two factories or more
3 Amendment of rules regarding allergens: Changes in the terminology/symbols used. Writing all allergens separately is now the standard way to proceed (gathering allergens labeling is still allowed but only in certain specific case)
4 Labeling of a nutrition facts panel is now mandatory: For all processed food and additives aimed at consumers, in addition to a couple of adjustments to the labeling rules themselves (ex: “Sodium” item changed to “Salt equivalent”, etc.).
5 Amendment of rules regarding Nutrient Content Claims with new rules for claims like “No use of sugar”, and an update in the nutrient’s standard values (ex: in the requirements to indicate an increase or decrease in nutrients content compared to other products, or for labeling stating that the product can fulfill certain nutrients needs)
6 Change of rules regarding the Foods with Nutrient Function Claims system: New nutrients have been added (n-3 fatty acid, vitamin K and potassium). Perishable foods can now be targets of this labeling system.
7 Change of rules regarding the labeling of the ingredients list: Rules for labeling according to individual food categories has changed (ex: for “breads”, ingredients and additives must now be separated)
8 Amendment of rules regarding labeling of additives for sales: The labeling items “name and address of the person in charge of labeling” and “net weight (for Additives aimed at general consumers)” are now mandatory
9 Regulation of parts of the labeling rules that used to only be stated in notifications: The labeling of measures concerning food poisoning (fugu, botulism, etc.) is now mandatory, and the standard values for nutrients labeling have been summarized/regulated.
10 Amendment of the labeling layout: labeling items pertaining to safety matters cannot be omitted anymore, no matter how small the labeling area is, and the classification of ingredients and additives now should be clear on the label.
In addition to the mandatory labeling content (of which the above is a general overview), there have been changes in the labeling claims standards also.
On a side note, it should be noted that some of the standards are to be found outside the FLS: it is essential to also check the complementary documents “regarding food labeling standards”/”Food labeling Standards Q&A”.
Overall, we strongly recommend to carefully check the labeling of your food products aimed at Japan during the remaining period and update as necessary!
Reference:
Summary of the food Labeling Standard, in Japanese (食品表示基準の概要)
https://www.caa.go.jp/policies/policy/food_labeling/food_labeling_act/pdf/150331_kijyun-gaiyo.pdf
More info about the changes, in English:
https://label-bank.com/newsletter/issues/201904_2.html
More about Label bank:
Label bank is company specialized in all services (formulation and label review, development, regulatory consulting, databases) related to the labeling of food product for the Japanese market.
Learn more here! https://label-bank.com/
