[Cabinet No. 43, 2017] New Food Labeling System for Processed Food Products for Japan
- Source: CAA, Japan
- Sep 2, 2017
- 10 min read
Background:
The Ministry of Agriculture, Forestry and Fisheries of Japan has held 10 discussions on the “Discussion on Country of Origin Labeling (hereinafter referred to as “COOL”) System for Processed Food” from January to November 2016. The new rule requires Japanese food manufactures to display the country of origin of a product’s main ingredients by weight on the product label.
There is one exception to this. It applies to “Onigiri” (Japanese rice ball). Even though the main ingredient is rice, the country of origin of the seaweed (commonly known as nori in Japanese) used in the rice ball is also required to be displayed based on the new expanded rule. It’s reportedly included for the following reasons:
The “Onigiri” is a national food.
Japanese local seaweed manufacturers strongly lobbied for its inclusion.
The local industry argued that the country of origin of the seaweed is an important factor which may affect consumers’ choice when selecting a rice ball.
[3D render by Zsolt Popa]
In a nutshell, the below were finalized on 29 November 2016.
Labeling of the country of origin of the highest ranking raw material based on weight shall be compulsory.
When certain conditions are satisfied, "or” display and "batch” display based on past results etc. are accepted, and "intermediate processing place of raw materials" shall be permitted as "place of manufacture" display.
Related documents:
Main Changes Of Country of Origin Labeling System:
(Date of Publication and Enforcement: Sep 1, 2017 )
Change no. 1: Target Product, Target Raw Materials of Country of Origin Labeling (COOL)[Article 3 (2)]
ALL PROCESSED FOOD produced/processed domestically (excluding imported products) will be subject to the COOL requirements.
Objective:
Country of origin is one of the factors which affects a consumer’s product selection, hence making it obligatory to display the country of origin for all processed foods raw materials will be in line with the interests of consumers.
Food Items Removed From List:
Items which do not require display:
In the case of providing processed food for eating and drinking purposes (food catering service) [Article 1]
When the processed food is sold without packaging [Article]
When selling processed food at the place where the food is manufactured or processed [Article 5]
When transferred (excluding sales) to unspecified or numerous persons [Article 5]
When labeling is required under other laws and regulations [Article 3] such as:
"Act on Recording Information and Communication of Production Area Information on Rice, etc. Transactions" (Act No. 26 of 2009)
"Act on Securing of Liquor Tax and on Liquor Business Associations" (Act No. 7 of 1952)
Items where labeling can be omitted:
When the displayable area of packaging is approximately 30 ㎠ or less [Article 3 of Act]
Target Raw Materials [Article 3 (2)]
In principle, the raw material with the highest weight percentage in the product is subject to the COOL.
In addition, the business operator can voluntarily display place of origin of raw materials ranked 2nd or more in the weight ratio. Raw materials with the highest weight percentage of less than 50% from the 22 food categories are also subject to COOL requirements.
Change no. 2: New Labeling Method, Labeling Example
Additional New Labeling Method
For the origin of the target raw material, the principle shall be to “display by country by weight” where the country name is displayed in descending order of weight percentage, similar to the labeling method before the revision. [Article 3 (2) Table 1]
If the target raw material is a processed food, display the "manufacturing place" of the intermediate processing raw material. [Article 3(2), Table 1-2]
If there are three or more country of origins, the country name can be displayed in descending order of weight percentage in the same way as the display method before the revision, and the third and subsequent countries can be displayed as "others". [Article 3, (2), Table 1 - 4]
When "country-by-country weight order display" is difficult, "Or" display or "batch" display is allowed under certain conditions. [Article 3(2) Table 1 of 5]
Examples of New Labeling Method
Change no. 3: "Or"（又は表示）Display［Article 3(2) Table 1 of 5(イ)］
"Or" display refers to the display of multiply countries possibly used as a Country of Origin by connecting them with "or" in descending order of the weight percentage that is expected to be used based on the past actual usage.
Condition to Acknowledge:
In view of the past record of use by locality during a certain period of time or the plan for each locale during a certain period in the future, if it is difficult to display County of Origin by country in the descending order of weight, "or” display can be used under the condition that evidence of proof of use is maintained.
Misidentification Prevention:
In the case of “or” display, make an indication that Country of Origin is displayed in descending order of the weight percentage of the raw materials based on its use history in the past certain period or the plan to use it in the future fixed period.
Examples of "Or" Display
Change no. 4: "Batch"（大括り表示）Display［Article 3(2) Table 1 of 5(ロ)］
"Batch Display" refers to the display of 3 or more foreign Country of Origin collectively as "Imported". Further, when imported products are mixed with domestic products, it refers to displaying the imported and domestic items in descending order of weight percentage.
Condition to Acknowledge:
"Batch Display" can be used when it is difficult to display Country of Origin in accordance with the weight percentage of raw materials used by their actual production area during a certain period in the past or usage plan for a certain period in the future. It can be used under the condition that evidence of proof of use is maintained.
Examples of "Batch" Display
Change no. 5: "Batch"+"Or" (大括り表示+又は表示）Display［Article 3(2) Table 1 of 5(ハ)］
"Batch" + "or" Display refers to the display based actual past usage, when it's possible to display 3 or more foreign Country of Origin collectively as "Imported" and "Imported" and "Domestic" are displayed using "or" in descending order of projected use.
Condition to Acknowledge:
"Batch" + "or" Display can be used when it is difficult to display Country of Origin using "Batch Display" only in accordance with the weight percentage of raw materials used by their actual production area during a certain period in the past or usage plan for a certain period in the future under the condition that evidence of proof of use is maintained.
Misidentification Prevention:
In the case of "Batch" or "Or" display, make an indication that Country of Origin is displayed in descending order of the weight percentage of the raw materials based on its use history in the past certain period or the plan to use it in the future fixed period.
Examples of "Batch" + "Or" Display
Change no. 6: "Place of Manufacture" (製造地表示）Display［Article 3(2) Table 1-2］
In principle, when the target raw material is an intermediate processed raw material, the manufacturing place of the said raw material is displayed as "Made in XX".
However, if the Country of Origin of the fresh raw material which is the target intermediate processed raw material is known, it is possible to display the Country of Origin together with the name of the raw material in place “Made in XX”.
Examples of "Place of Manufacture" Display
Change no. 7: Misidentification Prevention Measures (誤認防止策）Display［Article 3(2) Table 1-5 (イ, ハ)］
When "or” display is carried out, as a measure to prevent misunderstanding with regards to the Country of Origin of target raw materials with a very small use ratio will be displayed with parentheses to indicate that the use ratio in a certain period that is less than 5%.
Change no. 8: Seaweed of Onigiri［Article 3(2) Table 6][Appendix Table 15-6］
Using parentheses after the name of seaweed used, display Country of Origin in descending order of weight percentage.
Examples of Onigiri Seaweed Display
Scope of Onigiri (Rice balls) [As Prescribed in Notice etc.]
The scope of rice balls (whose seaweed are required to be individually displayed) shall refer to the ones commonly known to consumers such as those sold in convenience stores etc. where the seaweed is already wrapped around the rice balls at the time of sale or before consumption.
The following items are out of scope:
Rice balls which are packed into containers together with side dishes such as fried chicken and pickled radish.
All rice balls which are considered as sushi including rolled sushi, gunkan rolls, hand - rolled sushi etc.
Change no. 9: Country of Origin of Processed Food Raw Materials for Industrial Purposes [Article 10 (1)(11)]
In the old regulations, the Country of Origin information is required to be communicated to food related operators who are required to display Country of Origin information in the final products only when the general processed raw material was used as a raw material in final products.
There is no change this way of thinking. Even in the revised standards, obligation to convey the Country of Origin information is imposed only on industrial processed food which will be used as raw materials in final products.
Among food operators, the information can be displayed not only on the containers and packages but also on delivery notes, invoices, etc. or in specifications of the product.
Before Revision:
Industrial processed foods to be used as processed foods listed in Appendix Table 15 excluding imported goods, it is required to display the Country of Origin of perishable foods with the highest weight percentage among raw materials and additives and this weight percentage is above 50%.
(In the case of agricultural pickles, the top 4 ranking (in the case of products weighing 300g or less, the top 3 ranking) agricultural products or fishery products that occupy the highest weight percentage among the raw materials and additives which is 5% or more; in the case of vegetable frozen foods, the top 3 ranking items which occupy the highest weight percentage which is 5% or more; in the case of processed eel, the eel, and in Katsuo kezuribushi (Bonito flakes), katsuonofushi)
Targeted Processed Food: 22 food categories, pickled agricultural products, frozen vegetables, processed eel and Katsuo kezuribushi (Bonito flakes)
New Regulations:
In addition to the existing standards, for industrial processed food used in general processed food, raw materials of the relevant general processed food will be required to display its Country of Origin going forward.
To be more specific, seaweed of Onigiri (rice balls) and processed food to be used as raw materials in general processed food are added to the mandatory list of items where COOL is required.
Change no. 10: Country of Origin of Processed Food Raw Materials for Industrial Purposes [Article 10 (1)(12)]
Conventionally, industrial processed food to be used in final products to be sold as imports are required to display their Country of Origin in order for the appropriate Country of Origin to be displayed on the final products to be sold as imports. In the case where the target raw materials (No. 1 ranking raw material by weight ratio) of the final product is an imported processed food, it will be required to display the place of manufacture (Country of Origin) of the imported industrial processed food which will become the highest weight ratio raw material in the final product. Further, in the case of domestic products as well, for industrial processed food which will be subject to COOL requirements for raw materials in the final product, it was not required to display the Country of Origin of the domestically produced product. However, in view of the fact that labeling for consumers are done based on the premise that the “necessary information is communicated”, and also in order not to over burden the people selling industrial processed food, COOL requirements are required (COOL is required for domestic products even in the case of the regulations for industrial perishables before the revision).
Among food operators, the information can be displayed not only on the containers and packages but also on delivery notes, invoices, etc. or in specifications of the product.
Before Revision:
In order to appropriately display the Country of Origin in the final product to be sold as imports, it is necessary to display the Country of Origin of the industrial processed food which will become the final product to be sold as “imports”. Thus, such industrial processing food are required to display their Country of Origin.
New Regulation:
In addition to regulations before the amendment, it is required to label the industrial processed food to be used as processed food for general purpose (when manufacturers of general processed foods display the Country of Origin of the target raw material, it is not limited to industrial processed food manufacturers providing information on the Country of Origin of the raw material.)
Change no. 11: Country of Origin of Perishables Used for Industrial Purposes [Article 24 (3)]
Conventionally, since it was required to communicate the Country of Origin only when an ingredient was used as a raw material of processed foods subject to COOL requirements, even under the revised regulations, only items which are required to be displayed on the final product is the Country of Origin information required to be communicated.
The place of COOL for perishable food products traded between food operators is not limited to containers and packages. The information can also be displayed on delivery notes, invoices etc. or specifications.
Before Revision:
In the case of perishables to be used in processed foods, it is required to display the Country of Origin of perishable foods with the highest weight percentage among raw materials and additives and this weight percentage is above 50%.
(In the case of agricultural pickles, the top 4 ranking (in the case of products weighing 300g or less, the top 3 ranking) agricultural products or fishery products that occupy the highest weight percentage among the raw materials and additives which is 5% or more; in the case of vegetable frozen foods, the top 3 ranking items which occupy the highest weight percentage which is 5% or more; in the case of processed eel, the eel, and in Katsuo kezuribushi (Bonito flakes), katsuonofushi)
New Regulation:
In addition to regulations before the amendment, it is required to label the industrial perishables to be used in processed food for general purpose (when manufacturers of general processed foods display the Country of Origin of the target raw material, it is not limited to industrial processed food manufacturers providing information on the Country of Origin of the raw material.)
To be more specific, industrial perishables which holds the highest weight percentage of processed foods for general use, has been added to the list of industrial perishables which were required to be displayed before the amendment.
Change no. 12: Transition Period [Supplementary Article 3]
For processed foods (excluding industrial processed foods) manufactured or processed from the date of enforcement until March 31, 2022, and for industrial processed foods and commercial processed foods sold until that day, labeling according to the regulations before amendment will be allowed.
For processed foods (alcoholic beverages and fruit vinegar etc. brewed over a long period of time) that are in the manufacturing process at the manufacturing facility or processing plant at the time of enforcement, display is not required even after April 1, 2022.
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