Transition period to new Food Labeling Standards for Japan is coming to the end

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!


Summary of the food Labeling Standard, in Japanese (食品表示基準の概要)

More info about the changes, in English:

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!

Recent FVO report on bivalve molluscs and fishery products

Recently the Food Veterinary Office (FVO) spotted some problems regarding live bivalve molluscs in Greece and fishery products from Bangladesh.

GREECE – Live bivalve molluscs

The first report describes the outcome of a Food and Veterinary Office audit in Greece carried out from 14 to 24 October 2014, as part of its programme of audits for 2014.

The primary objectives of the audit were to assess whether the official controls of bivalve molluscs, echinoderms, tunicates and marine gastropods are organised and carried out in accordance with the relevant provisions of Regulation (EC) No 882/2004 of the European Parliament and of the Council of 29 April 2004 on official controls performed to ensure the verification of compliance with feed and food law, animal health and animal welfare rules and whether the control system in place for the production and placing on the market of bivalve molluscs, echinoderms, tunicates and marine gastropods is in compliance with European Union requirements.

The audit also verified the implementation of the recommendations of the previous 2011 Food and Veterinary Office audit visit covering the same subject.

The current report concludes that considerable improvements have been made since the previous audit, however, the official control system in place covering live bivalve molluscs cannot yet be considered as fully in compliance with all European Union requirements. Important shortcomings are still present, notably related to the definition of sampling points for the collection of water for phytoplankton testing and live bivalve molluscs for biotoxins testing, the frequency of monitoring/testing of live bivalve molluscs for one group of toxins (Paralytic Shellfish Poison) and the absence of demonstration of the efficiency of the purification systems.

Of the twenty recommendations of the 2011 audit, ten can be considered as addressed, three partially addressed, six not addressed (monitoring of biotoxins (for Paralytic Shellfish Poison); decisions taken after monitoring; additional monitoring requirements; purification centres; analytical and legal validity of samples; coordination between Competent Authorities) and one is no longer applicable.

BANGLADESH – Fishery products

This report describes the outcome of a Food and Veterinary Office audit in Bangladesh carried out from20 to 30 April 2015, as part of its programme of audits in third countries.

The objectives of the audit were to evaluate whether the official controls put in place by the competent authority can guarantee that conditions of production of fishery products in Bangladesh destined for export to the EU are in line with the requirements laid down in EU legislation and in particular with health attestations contained in the certificate and to verify the extent to which the guarantees and corrective actions submitted to the Commission services in response to the recommendations of the previous Food and Veterinary Office fishery products report of 2010 have been implemented and enforced by the competent authority.

The report concludes that improvements have been made since the last audit and in principle, the current organisation of the competent authority and its documented operational procedures provide for an acceptable official control system for fishery products which is implemented in a satisfactory way.

However, certain deficiencies in their implementation (i.e. temperature controls, structural standards of freezer vessels; lack of histamine, dioxin/PCBs and additives testing; maximum limits for cadmium) do not offer the necessary guarantees that fishery products intended for EU export fully respect the requirements defined in the health certificate for imports of fishery products intended for human consumption as set out in the model defined in Regulation (EC) No 2074/2005.