Expansion of Labeling Requirements for Processed Foods: Origin of Ingredients (4) ~Mandatory for all processed food products/the most predominant ingredient by weight/country of origin labeling in descending order by weight (as a general rule) ~

By | 2016年12月8日

On September 23rd, 2016, the 9th review meeting on “country of origin labeling system for ingredients in processed food products” – co-hosted by the Consumer Affairs Agency (CAA) and the Ministry of Agriculture, Forestry and Fisheries (MAFF) – has been held where a proposal on the future labeling system was discussed. An interim report is going to be reviewed at the 10th meeting, and this suggests the framework of the proposed labeling system is expected to remain unchanged.

Country of origin labeling (COOL) for all processed food (as a general rule)

Key features:

  • All processed foods made or processed in Japan are subject to mandatory COOL.
  • The most predominant ingredient (by weight) in the product is subject to mandatory COOL.
  • Supplying country names must, in principle, be listed in descending order by weight contained in the product.
  • If the ingredient is supplied by three or more countries, the term “other(s)” can be used from the third largest supplier.

Some specific examples are provided in the proposal:

Product name Curry
Ingredients Beef (Australia), cheese, sauté d’onions, (…)
Product name Pork sausage
Ingredients Pork (Canada, USA, other), lard, hydrolyzed protein, (…)

Exceptions to the “country of origin” labeling in descending order by weight

The labeling of “Listing of possible suppliers” is, however, permitted if the product packaging requires a change for each modifications in the “countries of origin” of an ingredient in consideration of the previously used materials records/using plans over a defined (or possible, for new products) period of time, and it is going to be difficult for manufacturers to list the name of supplying countries in descending order by weight contained in the product.
(In order to prevent misleading the consumer, a cautionary statement must be provided on the product packaging, suggesting that the COOL is based on the past purchasing records; and such records to support the statement must be readily available.)

Product name Pork sausage
Ingredients Pork (Canada or USA), lard, hydrolyzed protein, (…)

*Pork: COOL is based on the previously used materials records of xxxx (year).

If the country of origin of the ingredient switches between three or more foreign countries and the product packaging should require a change, manufacturers can use an “all inclusive” labeling, labeling the country of origin as “import”.

Product name Loin ham
Ingredients Pork loin (import), sugars (sugar syrup, sugar), salt
Product name Soy sauce
Ingredients Soybeans (import, domestic), wheat, salt

If it is impossible to list “import” and “domestic” in descending order by weight contained in the product, manufactures can use a combination of “listing of possible suppliers” labeling and “all inclusive” labeling.

Product name Pork sausage
Ingredients Pork (import or domestic), lard, hydrolyzed protein, (…)

*Pork: COOL is based on the previously used materials records of xxxx (year).

If the ingredient is a semi-processed one, then the country where the ingredient was manufactured must be labeled: “made in xx (country name)”

Product name Non-alcoholic beverage
Ingredients Apple Juice (made in Germany), fructose-glucose syrup, fructose

It is important to prevent misleading and prepare source documentation

The theme repeatedly discussed at these series of meetings was “How to prevent misleading the consumer”. While the proposed new system is well received as it will provide the consumer with access to further information on the country of origin, some are concerned that a description such as “import or domestic” is confusing and can also be misleading.

In order to avoid such misleading and concerns, businesses should basically follow the “general rule”, an easy-to-understand rule to label supplying countries. Having said that, quite a few of them may actually end up using “listing of possible suppliers” labeling or “all inclusive” labeling in the light of feasibility, depending on the type of product.

In such case, they would have to provide a cautionary statement regarding the previously used materials records on the product packaging and, moreover, provide further explanation on their corporate websites for the consumer. It is also important to keep track of procedures required for the management of product specifications in the course of their work to ensure that relevant documentation, such as used materials records, is available.

It is also necessary not to mislead on the proportion of the ingredient(s) of mixed origin because supplying countries must be listed in descending order by volume.
Here is a proposal for an ingredient whose use in the product is quantitatively limited:

“For the labeling of a supplying country whose ingredient ratio in the specific product is very small, declare the percentage amount to prevent misleading the consumer, or do not provide “made in xx” statement on the packaging. “

If the origin of the ingredient frequently changes between multiple countries, information control of such ingredients would become important.

Although there will be a transition period for the implementation of the new system, a specific timeline has yet to be provided. An interim report is scheduled to be discussed at the next review meeting on November 2nd, and anyone who is interested should check out the review meeting information.

Review meeting on origin of ingredients labeling system for processed foods


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