On November 29, 2016, the Consumer Affairs Agency (CAA) and the Ministry of Agriculture, Forestry and Fisheries (MAFF) have published the interim report on “country of origin labeling system for ingredients in processed food products”. The framework of the proposal offered at the end of September has been kept unchanged, but let us summarize some key points again here.
Mandatory Country of Origin Labeling (COOL)
Food products subject to COOL
- All processed foods made or processed in Japan are subject to COOL. (*)
Ingredients subject to COOL
- The most predominant ingredient (by weight) in the product is subject to COOL.
(*) Exceptions (foods that are not subject to origin labeling) are provided for:
- Food that is manufactured or processed on the premise where it is sold.
- Food that is offered to a great number of unspecified persons for free.
- Food that is sold unpackaged.
- Food packaging with an available labeling area of approximately 30 square centimeters or less.
How to label mandatory origin
- Supplying countries of the ingredient subject to COOL 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)” may be used from the third largest supplier, as with the current rules.
Labeling methods are the same as the current COOL requirements for 22 food categories (Point 15 of Annex: Labeling method) as provided in Food Labeling Standards (Article 3: Country of Origin of Ingredients).
Ingredients: Pork (Canada, USA, others), lard, hydrolyzed protein, reducing sugar syrup, salt, spice
Exception 1 (“Listing of Possible Suppliers” Labeling: the use of the term “or”)
- When multiple possible supplying countries are listed, they should be separated by the term “or”, and in order of largest weight expected to be present in the product, based on the past records on ingredients use.
Ingredients: Soybeans (USA or Canada or Brazil), wheat, salt
*Soybeans: COOL is based on the records on ingredients used over a two-year period since xxxx (year).
The country that is expected to be the largest supplier (by weight) over a defined period of time is put first on the list, whereas smaller supplying countries are put down on the list.
Exception 2 (“All Inclusive” Labeling: the use of the term “import”)
- Ingredients originating from three or more foreign countries may be labeled as “import”. If a mix of imported ingredients (total) and domestically sourced ingredients is used, both categories may be listed by order of largest weight contained in the product.
Ingredients: Soybeans (import, domestic), wheat, salt
*Soybeans: COOL is based on the weight of the ingredients used over a two-year period since xxxx (year).
If the country of origin is labeled as “import” only, the most predominant ingredient does not contain domestically sourced ingredient. If the origin is labeled as “import, domestic”, both imports and domestically sourced ingredients are used, indicating that imported ingredients are predominant in the product.
Exception 3 (“All Inclusive” Labeling + “Listing of Possible Suppliers” Labeling)
- Both categories, “import” (the ingredient originating from three or more foreign countries is labeled as “import”) and “domestic” may be listed, by separating with the term “or”, in the order in which the largest weight is expected to be present in the product, based on the past records on ingredients use.
Ingredients: Pork (import or domestic), lard, hydrolyzed protein, reducing sugar syrup, salt, spice
*Pork: COOL is based on weight of ingredients use in xxxx (year).
This exception assumes that the ingredient subject to COOL was imported from three or more foreign suppliers, and that the manufacturer is changing the proportion of import and domestic ingredients on a monthly or seasonal basis.
Exception 4 (COOL for semi-processed ingredients)
- If the ingredient subject to COOL is semi-processed, the country where the ingredient was processed must be noted on the label (e.g. made in xx (country name)). If the supplying countries of the ingredient are identified, they may be listed along with that ingredient’s name, instead of mentioning “made in xx (country name)”.
Ingredients: Apple Juice (made in Germany), fructose-glucose syrup, fructose
Ingredients: Apple Juice (apple: Germany, Hungary), fructose-glucose syrup, fructose
There initially was a proposal to label the country of origin of a semi-processed ingredient as “processed in xx (country name)”, but it fell through because a country that undertook processing such as cutting or mixing could also be identified as a country of origin. The country of processing must therefore be provided only when a food that is different in nature from the ingredient subject to COOL was prepared by processing that ingredient.
Common points in mandatory labeling
Prevention of misleading labeling
In order to prevent misleading the consumer, businesses should declare, for example, the percentage amount when mentioning a supplying country whose ingredient ratio in the specific product is very small, or do not provide “made in xx” statement on the label.
Preparation of documentation
When applying exceptions noted above, business operators should gather relevant documentation, such as the past records on ingredients use, available to prove that the label information is correct.
Nori (dried seaweed sheets to wrap rice balls)
Although Nori is very light and cannot be the heaviest ingredient (by weight) in the product, its country of origin is considered important for consumers to make choices, thus being subject to COOL.
The government will listen to the voice of the people through medium such as public comment, and an adequate transition period will be provided for the implementation of the new labeling system, giving consideration to business operators who will be required to replace their existing packaging.
Except for those designated processed foods (22 categories and 4 types) currently being subject to COOL requirements and products subject to the Rice Traceability Act, a change of ingredient list will be required for most processed foods.
In order to keep track of past records, where necessary, you will need to have a term-focused ingredient specifications management. If you deal with products whose countries of origin of ingredients frequently change, take this opportunity to review your current operational management system for specifications, and also review the information on the new COOL system before its enforcement.
Interim report on “country of origin labeling system for ingredients in processed food products”