Japan CAA Unveils FAQ for Plant-based Meat Labeling

Recently, plant-based meat headed by "soy meat" (made from soybeans) and "oats milk"(made from oats) are popular with many consumers for being considered more healthier and environmental friendly, and the market is gradually expanding. However, many labeling problems have risen correspondingly. To regulate the labeling of plant-based meat, CAA publicly answered questions related to product labeling of plant-based meat for the first time on August 20, 2021.

The followings are the key points of the Q&A published by CAA:

1. Plant-based Meat Product Name

If the product name of plant-based meat uses the expressions 「大豆肉」(soy meat) and「ノットミート」(not meat), consumers are likely to mistakenly perceive it as meat products. To avoid such misunderstandings, the label must also contain "no meat", "soybeans are used as raw material" or similar expressions that indicate raw materials. Foods that have the same concerns include oats milk, neo-butter, etc.

Product name	Concerns	Expression of raw materials
Burger patties made with soybeans	Misunderstand it is made from 100% alternative meat	Indicates the proportion of alternative meat used
Soy meat & 100% plant-based *Some food additives, including spice, are not plant-based.	Misunderstand that all raw materials including food additives are plant-based	The raw materials are plant-based (except food additives)
Oats milk	Misunderstand the product is milk and milk beverage	Oats are used Not milk or milk drinks
Rice milk	Misunderstand the product is milk and milk beverage	Oats are used Not milk or milk drinks
Next cheese	Misunderstand the product is cheese or butter	Made from soy milk Not a dairy product
Neo-butter	Misunderstand the product is cheese or butter	Made from soy milk Not a dairy product
Alternative fish	Misunderstand the product is a fish product	Made with vegetables Vegetables are used as raw materials No use of fish
Vegetable tunny
Alternative tunny
Bee free honey	Misunderstand the product is honey	Made with XX (directly pointing out the raw material’s name) Not honey

Even if the product names of imported alternative milk beverages or alternative butter are marked as “XX milk” and “XX butter” in English, some consumers may still misunderstand that they are dairy products. Therefore, adding additional statements such as “not milk or milk beverage” and “not dairy products” on the label is necessary.

2. Requirements for Raw Material’s Name

According to the Food Labeling Standards, the raw material’s name shall be displayed with its “most general name." For a food made from soybeans, you cannot label "alternative meat" or "soy meat" in the raw materials but should label them as "soybeans" or "processed soybeans."

Besides, for plant-based meat’s raw material whose name includes "meat" and "egg", cannot be regarded as a "general name".

3. Allergy Alert Label

Plant-based meat's alert labeling requirement is the same as that of generally processed foods. If a processed meat product manufactured on the same production line contains specific raw materials, the manufacturer shall thoroughly clean the production line to prevent unintentional contamination. However, when contamination can't be ruled out, a warning message such as "This product’s manufacturing factory also produces products containing XX (such as beef, etc.)" is required to be displayed on the label.
According to the Food Labeling Standards, the range of "eggs" that require food allergy labeling is chicken eggs and commonly used edible bird eggs such as duck eggs and quail eggs. Regarding plant-based eggs made with raw materials similar to eggs, if it does not use chicken egg and edible bird eggs such as duck egg and quail eggs, there is no need to label “egg” as an allergic ingredient. However, the operator can indicate on the label "XX used in this product contains ingredients similar to eggs. People who are allergic to eggs, please refrain from eating this product." as a reminder message.