“The guideline for nutrition labeling based on the food labeling standard, 2nd edition” was published

By | 2018年7月18日
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On May 11, 2018, the Consumer Affairs Agency (CAA) published “the 2nd edition for the guidelines for nutrition labeling based on the food labeling standard.” The structure was significantly altered from the 1st edition, which was published at the same time as the new food labeling standard. Therefore, we would like to feature it here.

Major changes


The 1st edition started with an explanation of “the method for setting nutrition labeling” such as a calculation method and an analysis method of a labeled value. Thus, the content was rather technical. However, in the table of contents of the 2nd edition, there have been significant changes as to “what type of food is to be labeled”.

Major changes are as follows.

  • The regulations are written in the following order (subject food → with or without claims → method of labeling → grounds of labeling)
  • The regulations are written by nutrient (refer to table 9*, etc.) and by category (processed, perishable, additive, general use, industrial use)
  • The appended table for “the food labeling standard” such as the standard value for food with nutrient function claims has been published
  • The content of “the food labeling standard Q&A” which includes assorted foods and size of labeling space has been published
  • The content of the notification “regarding the food labeling standard” including the smallest unit and the significant figure of nutrient values has been published
  • *36 components and calories which are defined in the 9th appended table for the food labeling standard

What can be understood is that it was changed to a comprehensive guideline which includes descriptions and an appended table for nutrients in the food labeling standard and also “the food labeling standard Q&A” as well as major rules written in the notice “regarding the food labeling standard.” So it will be helpful when you are experiencing difficulty in making nutrition labeling or checking it.

Structure of the guideline


The structure of the revised guideline is as follows:

1. What type of food is the food you are trying to label?

  1. The target food of the food labeling standard
    About the target food of the food labeling standard
  2. Nutrients that need to be labeled
    (1) Nutrients that are defined in the food labeling standard
    (2) Regulations of nutrients labeling for processed food, perishable food and additives
      
    1. Processed food for general use
    2. Perishable food for general use
    3. Additive for general use
    4. Processed food for industrial use, perishable food for industrial use, additive for industrial use

2. Do you use nutrient claims labeling? Do you sell your product as a food with nutrient function claims?

  1. Nutrient claims labeling
    (1) Regulations of nutrient claims labeling

    1. Indication that the food enables supplement of nutrients and moderate intake of nutrients or calories
    2. Indication that no sugars are added or no sodium is added
    3. Points of attention regarding regulations for nutrient claims labeling

    (2) Labeled value in case of nutrient claims labeling

    1. Labeled value to indicate that the food enables supplement of nutrients and moderate intake of nutrients or calories
    2. Labeled value to indicate that no sugars are added or no sodium is added

    (3) Examples of expression for nutrient claims labeling

    1. Examples of expression to indicate that the food enables supplement of nutrients and moderate intake of nutrients or calories
    2. Examples of expression to indicate that no sugars are added or no sodium is added
    3. Points of attention regarding expression for nutrient claims labeling

    (4) In case of using nutrient claims labeling for ingredients or food composing of a set

    1. In case of using nutrient claims labeling for ingredients
    2. In case of using nutrient claims labeling for each food composing of a set

    (5) In case of no standard for nutrient claims labeling

    1. Nutrients for which there is no standard of nutrient claims labeling
    2. In case of using nutrient claims labeling for food for industrial use
  2. Food with nutrient function claims
    (1) Regulations for food with nutrient function claims
    (2) Points of mandatory labeling for food with nutrient function claims
    (3) Labeled value for food with nutrient function claims
    (4) Points of attention for food with nutrient function claims
    (5) Food unsuitable for labeling of food with nutrient function claims

3. Is it labeled in a proper method?

  • Method of nutrition labeling
    (1) Form of nutrition labeling (Refer to appended form 2 or 3 of the food labeling standard)
    (2) Name and unit to be used for labeling
    (3) Number of digits for labeled value

    1. Smallest position for labeling
    2. When the amount is less than the smallest unit but more than “the amount to be labeled as 0”

    (4) Points of attention regarding a method of labeling

    1. Labeling for the amount of nutrients and calories
    2. Labeling for the amount of sodium
    3. Method of labeling when several foods are in a container or a package

4. Is the labeled value accurate?

  1. Types of labeled value
    (1) Types of labeled value

    1. Labeling by a fixed value
    2. Labeling by a lower limit value and an upper limit value
    3. In case of using both the above a. and b.

    (2) Guideline of “Values falling within the range”
    (3) Tolerance range

    1. Regulation for the tolerance range
    2. Standard value and tolerance range for nutrient claims labeling

    (4) Fixed value which is a result of a rational estimate

  2. In case of calculating a labeled value by analysis
    (1) Basic thought process
    (2) Point of attention in case of calculating a labeled value by analysis
    (3) Example of a variation factor of a value

    1. Natural factor
    2. Artificial factor
  3. In case of calculating a labeled value by a method other than analysis
    (1) Basic thought process

    1. Method to use a value based on database
    2. Method to calculate a labeled value based on a value of each ingredient from database

    (2) Example of database accuracy for reference
    (3) Inaccurate case for a reference of a database value

As you can see, the content is largely different from the 1st edition. This is easier to understand even for those who found the previous guideline for mandatory nutrition labeling difficult. Therefore, we recommend having a look over it.

[Note] It was partly revised on May 18, 2018.

4. Is the labeling value accurate?

  1. Types of labeled value
    (3) Tolerance range

    1. Regulation for the tolerance range
      “When labeling ‘the fixed value within the tolerance range,’ a value of every product calculated by a method listed in the 3rd column of the 9th appended table for the food labeling standard needs to be within the range of allowable difference for the labeled value while the product is sold.”
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