Japan – Updates about food allergen labeling

Today we publish the second guest post from our friends in Osaka, Label Bank ! (see link at the end of the article for more info)

On July 5, 2019, the CAA announced two critical amendments during the COCC Food labeling section meeting:

• “Almond has been added to the list of foods recommended to use allergen labeling”, and
• “Walnut has been designated as a food subject to mandatory labeling”

In fact, in Japan a periodic “National survey of state of health damage caused by immediate food allergies” is performed approximately every three years.

On May 31, 2019, the “report on survey and research business of food labeling related to food allergy” was posted on the CAA website (and corresponding to the fiscal year 2018): it showed an increase in the number of allergy cases for almond and walnut – compared to the previous reports from fiscal years of 2015 and 2012.

According to the part “Consideration and Conclusion” pertaining to the labeling of foods containing allergens and based on the allergy cases covered by the mandatory 7 items and/or recommended 20 items of specific ingredients are included, said 27 items were seemingly enough as a subject to control allergy food labeling in Japan.

That said, there are other allergy cases which are not related to those items, of which almond accounted the most twice in a row in the last surveys; actually even more than allergy cases usually reported for banana, cashew and sesame (n.b: those are currently part of the “recommended” list). Those results have drowned attention to the necessity to amend almonds to the recommended list for allergen labeling. Also, there is a sudden increase of allergic reactions to nuts, and for walnuts particularly.

Comparison of the allergy reaction cases for foods containing walnuts and almonds between the fiscal years 2012, 2015, 2018 based on the Discussions

Substance that causes allergy	Classification	Fiscal year of			Correspondence
		2012	2015	2018
Walnut	Number of immediate allergy cases	40	74	251	Consideration to make labeling mandatory (*)
	Number of shock cases	4	7	42
Almond	Number of immediate allergy cases	0	14	21	Consideration to add to the recommended items (*)
	Number of shock cases	0	4	1

(*)“Allergen labeling” according to the Food Labeling Standard’s aim of alerting allergic consumers to certain foods or ingredients in order to prevent any health damages.

Specific ingredients subject to allergen labeling were (before the addition of almond) classified as below under “specific ingredients (7 items of mandatory labeling)” and “those equivalent to specific ingredients (20 items of recommended labeling)”.

Specific ingredients, etc.		Reason	Mandatory labeling
Specific ingredients	Shrimps, crabs, wheat, buckwheat, eggs, milk, peanuts	Ingredients with an especially high necessity of labelling considering the number of occurrences and severity of cases	Mandatory labeling
Those equivalent to specific ingredients	Abalones, squid, salmon roe, oranges, cashews, kiwis, beef, walnuts, sesames, salmon, mackerel, soybeans, chicken, bananas, pork, matsutake mushrooms, peaches, Japanese yams, apples, gelatin	Ones which continuously cause certain numbers of cases and people to present severe symptoms but less than specific ingredients	Recommended to label (Voluntary labeling)

 

Reminder regarding allergen labeling: In terms of labeling, there are two methods accepted in Japan, according to the following examples:

individual labeling: example Ingredients: potato, carrot, ham (containing egg and pork), mayonnaise (containing egg and soybeans), hydrolyzed protein (containing beef, salmon, mackerel and gelatin) / seasoning (amino acid, etc.)

Collective labeling: example Ingredients: potato, carrot, ham, mayonnaise, hydrolyzed protein / seasoning (amino acid, etc.), (partially containing egg, pork, soybeans, beef, mackerel and gelatin).

(n.b: “individual” labeling should normally be used when there is enough labeling space to allow so)

The enforcement of walnut labeling as a mandatory allergen might become effective in two to three years based on the following two discussion points:

• It is necessary to check if this increase in the number of cases is temporary

• If walnut is designated as an item subject to mandatory labeling, it will become necessary to develop a testing method and evaluate validity from the viewpoint of securing enforcement

Meanwhile, almonds have already been amended to the recommended labeling items and enforced as of September 19^th, 2019.

For manufacturers who used to display the 27 items (recommended and mandatory labeling) on their products, it is now necessary to add an entry of “almond” from the specification’s management phase.

Finally, please consider the following critical point:

In many foreign labeling systems, “walnut”, “cashew”, “almond”, etc. are labeled as “Tree Nuts” without further details; therefore when ingredients for use or food products are imported from overseas to Japan, this amendment needs to be seriously taken into consideration and necessary adjustments done to the specifications for instance.

We also recommended to check the CAA material, “About food labeling for foods containing allergen” on the COCC website ahead of establishing your new process/projects for the Japanese market.

CAA: Consumer Affairs Agency

COCC: Cabinet Office Consumer Commission

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/