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/

Top 10 articles in 2019

Dear readers and friends,

another year passed and I have to thank you everyone for the time spent reading this blog, sharing articles and commenting.

As usual, I recap the most interesting topics of 2019 in the first article of 2020.

  1. Glycaemic index labeling and related claims: EU Commission answer to a MEP query about the possibility to do glycaemic index claims on the labels in EU.;
  2. Transition period to new Food Labeling Standards for Japan is coming to the end: recap of upcoming Japanese labelling rules changes, by Label Bank (Osaka);
  3. EU – Upcoming exemptions for traditional generic descriptors (which could imply an effect on health) from nutrition and health claims Regulation;
  4. FDA Announces Public Meeting to Discuss Modernizing Food Standards of Identity: on 27th September 2019, the U.S. Food and Drug Administration announced a public meeting to give interested parties an opportunity to discuss FDA’s effort to modernize food standards of identity and to provide information about changes the FDA could make to existing standards of identity;
  5. Choices International Foundation front of pack logo: guest article by Choices International Foundation, about a voluntary front of pack labeling scheme;
  6. EU DG Health and Food Safety audit in Sweden – Unexpected flaws in microbial safety of food of non-animal origin: summary of a recent audit of the EU Commission services on the Swedish official control system for food of non animal origin;
  7. FDA moving down the road of Dietary Fibers definition: on 27th March the U.S. Food and Drug Administration announced that it intends to propose that “cross-linked phosphorylated RS4” – regardless of source – be added to the definition of dietary fiber. The action was taken in response to a citizen petition from MGP Ingredients Inc;
  8. Food Allergy Forum Report and New Food Law Latest Youtube Channel; opening video of the Food Law Latest Youtube Channel, regarding the Food Allergy Forum held in Amsterdam on 1st-3rd April 2019;
  9. Japan – Mozzarella di Bufala Campana PDO ‘evocation’ case: in light of the application of the EU-Japan free trade agreement, this Q&A between a MEP and the EU Commission, raise a curious case of evocation of a PDO (Protected Designation of Origin, recognized under Reg. EU 1151/2012);
  10. 100″ food news n. 3 – Allergen labeling and trans fats limitations in UE: weekly issue of our 100″ Food News, with Bert Popping from FOCOS – Food Consulting…strategically, covering several topics: RASFF pathogen data analysis (00:21), Belgium introduces Nutri-Score (01:22), New trans fats regulations (01:54), Pret-A-Manger starts allergen labelling (02:27), Further Headlines: new on-site devices for pesticides and pathogen analysis.