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 19th, 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/

EU-Vietnam free trade deal gets green light in trade committee

On 21st January 2020, the committee gave its consent to the free trade agreement by 29 votes, six votes against and five abstentions and recommends that EP Plenary should do the same. The agreement will remove virtually all tariffs between the two parties in ten years. It will protect emblematic European products, and allow Europe to access the Vietnamese public procurement market.

The agreement is also an instrument to protect the environment and further social progress in Vietnam, including in labour rights, the resolution accompanying the consent decision states. The trade committee’s demands from Vietnam, including on labour and human rights, as well as on the mechanism ensuring the enforceability of the sustainability clauses, was adopted by 29 votes for, nine against and two abstentions.

The main elements of the trade deal are the following:

  • removal of customs duties: 65% of EU exports to Vietnam will be immediately duty free, with the rest – including motorcycles, cars, pharmaceuticals, chemicals, wines, chicken and pork – gradually liberalised over ten years. 71% of Vietnamese exports to the EU will be duty free on day one, with the rest catching up in seven years. Duty-free Vietnamese exports of sensitive agricultural products, such as rice, garlic or eggs, will be limited;
  • non-tariff barriers will be eliminated in the automotive sector, export and import licensing, and customs procedures. Vietnam accepted the “Made in EU” marking, beyond national markings of origin, for non-agricultural products;
  • geographical indications: 169 emblematic EU products such as Parmigiano Reggiano cheese, Champagne, or Rioja wine, will enjoy protection in Vietnam, as will 39 Vietnamese products in the EU;
  • services: EU companies will have improved access to business, environmental, postal and courier, banking, insurance and maritime transport services in Vietnam;
  • public procurement: EU firms will be able to bid for contracts with Vietnamese ministries, state-owned enterprises, as well as with Hanoi and Ho Chi Minh City;
  • sustainable development: there are legally-binding rules on climate, labour and human rights. The agreement commits Vietnam to apply the Paris Agreement. Vietnam scheduled the ratification of two remaining bills on the abolition of forced labour and on freedom of association by 2020 and 2023, respectively. If there are human rights breaches, the trade deal can be suspended.

For more info visit: https://www.europarl.europa.eu/news/en/press-room/20200121IPR70703/eu-vietnam-free-trade-deal-gets-green-light-in-trade-committee

(Source: EU Parliament)