On July 28, 2017, a Consumer Commission Food Labeling Section Meeting was held, and the commission members basically agreed on the amended draft. Although the report included partial revisions and preconditions, the amended draft was adopted mostly as the way it was before public comments were collected.
We will try to sum up the important points of the system amendment once more and summarize the partial revisions and preconditions as follows.
Outline of the amendment and labeling examples
1. Targets of the mandatory labeling
Foods subject to COOL: All processed foods made or processed in Japan (except imports) are subject to COOL. Ingredients subject to COOL: The most predominant ingredient by weight in the product is subject to COOL. It is important to remember that even when a most predominant ingredient (belonging to one of the 22 food categories designed as subject to COOL) by weight represents less than 50% of the total product, it still become the target of COOL.
2. Method of mandatory labeling
- Supplying countries of the ingredient subject to COOL must, in principle, be listed in descending order by weight contained in the product, as with the current rules.
- If the ingredient subject to COOL is semi-processed, the country where the ingredient was processed must be noted on the label.
- If the ingredient is supplied by three or more countries, they must be listed in descending order by weight contained in the product, and the term “other(s)” may be used from the third largest supplier, as with the current rules.
- In case it is difficult to list supplying countries in descending order by weight, “Listing of Possible Suppliers” and “All Inclusive” Labeling methods are approved under certain conditions.
(Sample label of supplying countries)
|Product name||Pork sausage (wiener)|
|Ingredients||Pork (USA), lard, hydrolyzed protein, reducing sugar syrup, salt, spices / seasoning (amino acid, other.), phosphate (sodium, potassium), …|
(Sample label of processing countries)
|Product name||Non-alcoholic beverage|
|Ingredients||Apple Juice (made in Germany), fructose-glucose syrup, fructose / acidulant, vitamin C|
3. Labeling in cases where it is difficult to list supplying countries in descending order by weight
1) Sample label of “Listing of Possible Suppliers” Labeling (use of the term “or”)
|Product name||Pork sausage (wiener)|
|Ingredients||Pork (Canada, or USA, or others), lard, hydrolyzed protein, reducing sugar syrup, salt, spices / seasoning (amino acid, other.), phosphate (sodium, potassium), …|
*Pork: This COOL is based on the weight of the ingredients used in xxxx (year).
2) Sample label of “All Inclusive” Labeling (use of the term “import”)
|Product name||Loin ham|
|Ingredients||Pork loin (domestic, import), saccharides (sugar syrup, sugar), salt / seasoning (organic acid, other.), polysaccharide thickeners, color former (sodium nitrite), spices|
3) Sample label of “All Inclusive” Labeling mixed with “Listing of Possible Suppliers” Labeling (use of the term “or”)
|Product name||Wheat flour|
|Ingredients||Wheat (import or domestic)|
*Wheat: This COOL is based on the weight of the ingredients used in xxxx (year).
4. Other amendments
- If the proportion of a supplied ingredient is less than 5% for a certain period of time, a statement such as “less than 5%” must be provided.
- As for nori (dried seaweed sheets to wrap rice balls), supplying countries of the raw material of nori, must be listed.
- In cases where it is difficult to list supplying countries in descending order by weight (and so an alternative method is used), it shall be mandatory to store supporting documents.
About the opinions mentioned in the report
The following is a sum up of information relative to “preconditions” and “additional amendments”, summarized from the report submitted during the Consumer Commission Food Labeling Section Meeting on July 28, 2017.
[Preconditions to confirm that the draft of the Food Labeling Standard consulted in the meeting is appropriate] (outline)
- Target values for the level of understanding and other goals must be set and activities to disseminate the information to consumers and business operators must be conducted.
- New ways of disseminating and raising awareness must be adopted for aforementioned activities.
- Create a permanent consultation counter to sufficiently inform business operators and therefore prevent mislabeling caused by their lack of understanding.
- The Q&A section must be expanded and the system must be explained precisely so that business operators will not misinterpret it. (Especially the criteria for exceptional requirements, the rules on supporting documents storage, the points to be explained to the government, etc.)
- “The research to evaluate the level of understanding of the COOL system” must be conducted not only to consumers but also to business operators.
- The inspection system of food labeling must be strengthened even more.
- The standards to select items to be added to the appended table 15 must be clarified and made public.
- The percentage of labeling in descending order by weight and “exceptional” labeling use must be regularly examined.。
- After the transition period is finished, a research must be conducted to examine the level of understanding and the result must be announced.
- In two years after the transition period, the system must be revised as needed.
[Contents requiring to be corrected or added in the draft of the food labeling standard consulted in the meeting] (Complete sentences quoted bellow)
(1) Article 3, paragraph 2, table 1-5, a-b
If the proportion is less than 5% for a certain period of time, a statement such as “less than 5%” immediately after the name of the supplying country, must be provided in brackets. However, this does not apply to labeling of “others” following the rule in Article 3, paragraph 2, table 1-4.
(2)Enforcement of the effective date, transitional measures and range of products which are not subject to the new COOL system shall be effective on the promulgation day of the partial revision of the food labeling standard, and the transition period shall start from the Cabinet Office Ordinance enforcement date, to March 31, 2022. Besides, processed foods which are still in the production process in a manufacturing or processing facility when this partial revision of the food labeling standard is enforced can conform to the former food labeling standard.
In addition, several supplementary opinions are added to the report such as one suggesting to consider labeling on the internet since the number of mandatory labeling systems is increasing, or a concern about the impact on business transactions abroad, and also a request for the simplification of the draft of the standards and Q&A information for an easier understanding.
The most significant change overall is the point that the transition period was extended from March 31, 2020 to March 31, 2022. Other more detailed information such as criteria for the “exceptional labeling” system, and rules for storing supporting materials will be confirmed after Q&A is issued.
This is the end of these series of review meetings and the amendment of the system is planned to be officially enforced this summer.
In actual practice, storing supporting materials will be essential, so it will be crucial to organize information such as specifications already available to you, while revising your information management system.
Consumer Commission Food Labeling Section Meeting
Report file (in Japanese)