On March 30, 2022, the Consumer Affairs Agency, Government of Japan, issued an amendment to Food Labeling Standard. According to the amendment, the labeling requirements for nutrition, genetically modified food, and prohibited terms were revised. The amendment came into force since its publication on March 30, 2022.
Details for the amendment are as follows:
1. Nutrition labeling
Some food labels' nutrient content determination methods were revised, such as lipid, fatty acid, and saccharides.
2. Genetically modified food labeling
Genetically modified labeling is no longer required for soybeans with high oleic acid for it can be produced by conventional breeding;
Genetically modified mustard greens has passed the safety review by Japan MHLW, and are allowed to be sold in Japan. Therefore, it is added to target agricultural products" that are subject to mandatory genetically modified labeling.
Currently, the following foods are obliged to label genetically modified foods.
(1) Nine target agricultural products: soybean, corn, potatoes, rapeseed, cottonseed, alfalfa, sugar beet, papaya, and mustard greens;
(2) processed food (33 food groups) using the nine target agricultural products in item (1) as the raw material, whose recombinant DNA (or protein produced by the recombinant DNA) can be detected;
(3) Stearidonic-acid-produced recombinant soybean and high-lysine genetically modified corn;
(4) Processed foods that use the substances in item (3) as the raw material whose characteristics of genetically modified product is preserved after processing, such as soybean oil, etc.
3. Prohibited terms
The Food Labeling Standards subdivided the types of soy sauce and edible vegetable oils that need to refer to the prohibited labeling terms in respective Japanese Agricultural Standards (JAS). For example, the dark soy sauce and purified safflower oil.
In addition, the Food Labeling Standards revised in 2017 stated that all processed foods manufactured in Japan must indicate the origin of the raw materials. As of the end of March 2022, the transition period of the revision has ended. The stakeholders shall make sure the new requirement is enforced strictly.
Frequently asked questions
Q1: Do the labeling rules for genetic modification in the Act on Japanese Agricultural Standards (JAS) and the Food Sanitation Act apply to alcoholic beverages?
A1: Alcoholic beverages are excluded from "agricultural and forestry products" according to Article 2 of JAS and are not subject to the standards based on JAS, but are subject to labeling requirements specified in Food Sanitation Act. However, in beer, whiskey, etc., DNA derived from raw materials is decomposed in the process of fermentation and distillation. Hence this kind of alcoholic beverage is not considered a food with recombinant DNA. In this case, the labeling can be omitted.
Q2: If to claim what is commonly known (e.g., milk is rich in calcium ) on the containers and packaging of processed foods, does the labeling need to comply with the nutrition claim regulations?
A2: Even if it is generally known, the labeling that emphasizes nutrition content must be indicated in accordance with Food Labeling Standards.
Q3: After April 1, 2023, the requirements for labeling "not genetically modified" will be changed. Is it necessary to have the products analyzed by a third-party analysis organization, confirming that the raw agricultural products are not contaminated by genetically modified agricultural products?
A3: The genetically modified labeling system has mandatory labeling and voluntary labeling. Voluntary labeling system will be implemented from April 1, 2023. Currently, products with 5% or less unintentional contamination can claim "not genetically modified". However, under the new system, only those "not detected" can be labeled as "not genetically modified" while products with 5% or less of unintentional contamination can be labeled with "separate management for production and sales".
The analysis results by third-party analysis organizations are effective as one of the methods for confirming that the genetically modified agricultural products are not mixed in the products. However, it is not the only approach to proving the product is "not genetically modified". Other proofs with the same probative effect are also acceptable.
We provide full-scale global food market entry services (including product registration, ingredient review, regulatory consultation, customized training, market research, branding strategy). Please contact us to discuss how we can help you by 
