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/

QeA to EU Commission – Aflatoxin content of almonds: “aflatoxin free”?

Question for written answer to the Commission
Giovanni La Via (PPE) – 13th July 2016

Subject: Aflatoxin content of almonds

Aflatoxins are mycotoxins produced by fungal species belonging to the class of Ascomycota (Aspergillus, Fusarium), or other moulds. They are highly toxic and are believed to be among the most carcinogenic substances that exist. They are often found in high quantities in Californian almonds, grown in California (USA) and exported to Europe in significant quantities. EU Regulation No 165/2010, amending Regulation (EC) No 1881/2006 setting maximum levels for certain contaminants in foodstuffs as regards aflatoxins, has increased the levels for aflatoxin total in almonds from 4 ug/kg to 8.10 ug/kg. The Avola almond, cultivated in the Syracuse area of Sicily, is one of the most well-known and best Italian almonds and has a zero aflatoxin content.

Does the Commission not, therefore, consider it appropriate, in order to protect consumers, to authorise the words ‘aflatoxin-free’ in almonds which, after being tested, are shown to contain no traces of this substance?

Answer given by Mr Andriukaitis on behalf of the Commission – 10th August 2016

Commission Regulation (EC) No 1881/2006 establishes strict maximum levels for aflatoxins in almonds providing a high level of human health protection. Only almonds compliant with the maximum levels for aflatoxins can be placed on the EU market.

Regulation (EU) No 1169/2011 does not provide for labelling requirements related to the presence of contaminants, including aflatoxins.

Aflatoxins are mycotoxins produced by fungi primarily Aspergillus sp. These fungi are also present in Italian agricultural environments. There are no almond varieties resistant to infection by these fungi. Fungal growth and aflatoxin production occur in almonds pre-harvest, but may proliferate in storage and continue in the handling stage. The growth of the fungi is strongly influenced by climate and they are more common in warm regions with extreme variations in temperature, rainfall and humidity. The fungi can produce aflatoxins at quite low moisture levels and over a broad temperature range (13-37 °C).

The Commission does not have at its disposal the information necessary to compare the level of aflatoxin contamination in recent years in almonds from California compared to almonds grown in Sicily. However it is evident from the conditions in which the fungi Aspergillus sp grow and aflatoxins are formed, and the absence of aflatoxin resistant almond varieties, that there are no almond producing regions in the world where aflatoxins do not occur in almonds at all. It is therefore of major importance to apply prevention measures during growth, storage and handling to keep the levels of aflatoxins in almonds as low as reasonably achievable.

(Source: EU Parliament)