Public Consultation on Draft Amendment of the Cabinet Office Ordinance Specifying Food Labelling Standards and Allergens, Expiration Dates, Whether or Not Food Requires Heating for Safe Consumption

Japan's Consumers Affairs Agency (CAA) has launched a public consultation on the draft amendment of the Public Consultation on the Cabinet Office Ordinance (Draft) Amending the Cabinet Office Ordinance that specifies the Food Labelling Standards and Allergens, Expiration Dates, Whether or Not Food Requires Heating for Safe Consumption, and Other Matters That Have a Significant Impact on Food Safety, as Stipulated in Article 6, Paragraph 8 of the Food Labelling Act on 26 December 2025.

The CAA has drafted a partial amendment to the Food Labelling Standards (Act No. 70 of 2013) and the Cabinet Office Ordinance (Cabinet Office Ordinance No. 11 of 2015; hereinafter referred to as the "Article 6, Paragraph 8 Ordinance"), which stipulates allergens, expiration dates, whether food requires heating for safe consumption, and other matters that significantly affect food safety as stipulated in Article 6, Paragraph 8 of the Food Labelling Act. The outline of this amendment is as follows:

Matters Related to Allergy Labelling:

The "FY2024 Nationwide Survey on Health Damage Caused by Immediate-Type Food Allergies" revealed that the number of cases of cashew nuts among tree nuts and the proportion of cashew nuts among all tree nut cases have increased, and this is unlikely to be a temporary phenomenon. Based on these results, the 7th Advisory Council on Food Allergy Labelling, held in January 2025, proposed a policy that it would be appropriate to transition cashew nuts from the category 'equivalent to a specified ingredient' to the

'specified ingredient' categoty.

Now that the establishment of an official inspection method for cashew nuts is in sight, the CAA has proposed to add "cashew nuts" to Appendix 14 (specified ingredients) of the Food Labelling Standards.

Under Appendix Table 14 of the Food Labelling Standards, “Specified Ingredients” refer to allergens that are highly likely to cause allergic reactions and are therefore required to be labelled as a food allergen on processed food labels. These allergens must be indicated in the list of ingredients or equivalent sections of food labelling and play a critical role in ensuring consumer safety.

There are currently eight specified allergens subject to mandatory labelling:

• Shrimp

• Crab

• Wheat

• Buckwheat

• Egg

• Milk (cow’s milk)

• Peanuts

• Walnuts (added on 9 March, 2023, and effective as of 1 April 2025)

In addition to these eight allergens, there are also 20 “Ingredients Equivalent to Specified Ingredients”, for which labelling of the ingredient as an allergen is recommended but not mandatory. Cashew nuts are currently classified as one of these 20 allergens recommended for labelling.

Background information:

The 2023 survey results, following the 2017 and 2020 surveys, revealed a continuing upward trend in health risks from immediate-type food allergies to tree nuts, including walnuts and cashews.

Walnuts accounted for the largest number of cases, ranking second only to eggs as the causative food. The increase in cases of other tree nuts, including cashews, macadamia nuts, pistachios, and pecans, was more than 1.5 times higher than in the previous survey.

Future trends should be closely monitored. Furthermore, macadamia nuts, pistachios, and cashews are associated with many cases of shock, making it necessary to take prompt measures to avoid risk at the initial onset and prevent accidental ingestion. Hence, the CAA believes continued efforts should be focused on ensuring the proper implementation of the "Food Allergen Labelling Act" (food labelling for foods containing allergens).

Impact on stakeholders:

Affected stakeholders would have to consider the formulation of their processed food and also whether relabelling is necessary.

Key timelines:

Comments deadline:

Comments can be sent via CAA's web form by 30 January 2026.

Proposed implementation dates:

The planned implementation dates are as follows:

○ The labelling of cashew nuts as an allergen is expected to be implemented from 1 April 2026, with a 2 year transititional deadline.

○ The proposed revisions for the labelling of individual products will have a four-year transitional period from the implementation date*.

* Notwithstanding the revised provisions, the labelling of processed foods (excluding commercial processed foods) manufactured, processed, or imported by the transitional period and commercial processed foods sold by that date will continue to be governed by the previous standards.

[Source document]:

Public Consultation on the Cabinet Office Ordinance (Draft) Amending the Cabinet Office Ordinance that specifies the Food Labelling Standards and Allergens, Expiration Dates, Whether or Not Food Requires Heating for Safe Consumption, and Other Matters That Have a Significant Impact on Food Safety, as Stipulated in Article 6, Paragraph 8 of the Food Labelling Act.