At the end of 2016, the Consumer Affairs Agency published an advisory committee report on provision of information on food products sold online. Along with some other proposals, the Report presents survey results of consumers and business operators, and we believe that it can serve as a reference for food manufacturers and distributors. Unlike the "mandatory country of origin labeling", you may find it difficult to set aside time to deal with issues relating to voluntary labeling, especially when you are busy. Since voluntary labeling, however, can potentially serve as a tool of differentiation with competitors, in this newsletter we would like to provide information in this respect.
Overview of background and proposals discussed at the committee meetings
The committee was established in recognition of the fact that consumers purchasing food products online cannot read or verify food labels at the time of purchase, because they are not physically available.
After a series of meetings (10 times in total), the following proposal has been presented among others:
While aiming to create an environment that, at the time of purchase, allows online consumers to get information equivalent to the one provided on the label and packaging of products sold at physical stores, business operators should step up efforts, by referring to "Initiatives for Promoting the Provision of Information", to promote the initiatives and expand the provision of information relating to mandatory labeling requirements.
Statistical information and key survey findings
Before discussing the "Initiatives for Promoting the Provision of Information" – a useful reference, and which will be saved for the conclusion of this newsletter – we would like to provide some statistical information on online shopping in Japan and key survey findings (as found in the report) below:
Statistical information from the Ministry of Internal Affairs and Communications
- The households (two or more people) using online stores make up 24.8% of all households. (2014)
- The amount spent on online shopping per household per month is 9,138 yen. (2015)
- “Food” accounts for 11.8% of household’s (two or more people) online expenditures on main items. (2015)
Key research findings
- Whereas only about 10% of consumers think information relating to mandatory labeling requirements is important, about 90% of consumers who have purchased foodstuffs via internet refer to some kind of information relating to mandatory labeling requirements at the time of purchase.
- Shoppers who have allerg(ie)s and are mindful of what they eat specifically check for allergen information.
- For the first time purchase of a product, shoppers tend to check the country of origin, manufacturer, and use by or best before date.
- When a regularly purchased item is needed urgently, shoppers are less likely to check the product descriptions.
- Shoppers specifically check ingredients when buying a “minimally processed” food such as canned food.
- Shoppers especially check the Nutrition Facts when buying frozen, retort or snack food products.
- When asked the reasons for choosing the particular online store for shopping, some responded that it was because the online store they use provides more information relating to mandatory labeling requirements (of which 37.4% shop online once a week, 21.2% shop one to three times per month, and 15.9% shop less than once a month).
- In a survey of consumers who don’t have experience of online shopping, respondents were asked what specific mandatory information they would like to see on an online shopping website, and here are the results: Use by or best before date, or equivalent (74.4%), ingredients (73.4%), country of origin or origin of ingredients (70.7%)
Challenges related to updating information
In short, the best way would be to post exactly the same information written on the actual label in the online store, but there is a major challenge with updating information. You would have to ensure that the information available on the website and the one on the actual product shipped to the customer match. Those who are selling food products online probably know that from experience, but we would like to share with you the following extract taken from the Report.
- As to the question of whether all the mandatory information obtained from the manufacturer is available in your online store, about 40% of business operators answered “No”; some of them for the reason that it is difficult to keep such information up-to-date.
- Since whether or not there has been any change – or possibility of change – in the information provided by the manufacturer is unknown at the start of the supplying transaction, online retailers sometimes cannot respond immediately. In fact, the communication flow between manufacturers and retailers for dealing with such changes has not been fully established.
- As for fresh food, there are many cases where fresh seafood and produces cannot be sourced from the suppliers as planned due to bad weather and therefore product information could change at the last minute.
Initiatives for Promoting the Provision of Information
Based on the above issues, the Report states that “While referring to Initiatives for Promoting the Provision of Information, business operators should step up efforts to promote the initiatives and expand the provision of information relating to mandatory labeling requirements.” Some points to note are as follows:
- Starting with mandatory information that you can manage to provide
- Starting with a food product for which you can manage to provide information
- Posting the contact information for inquiries on your website
Examples of presentation of information by mandatory labeling requirements
Provide such intended storage conditions as “Keep frozen”, “Keep refrigerated” or “Keep at room temperature” in a conspicuous manner.
Provide information relating to expiry date, for example, “We solely deliver products with an expiration date longer than 1 month.”
In addition to the net quantity, give the reference weight per piece and/or the number of pieces.
Specify whether the allergen information covers the 7 mandatory allergens only or includes all 27 recommended allergens
It has been reported that retailers are trying different approaches to provide food safety information, such as on allergens: “Highlight specific statements”, “Present essential information in a concise and accessible manner”, “Put a list on a different page”, etc.
The Report also summarizes measures taken by business operators regarding the issues of updating information, so if you are involved in online retailing you should read through it.
Advisory committee report on the provision of information on food products sold online (CAA)