Rules for Labeling the Origin of Raw Materials in Processed Foods: 4 Labeling Methods and Penalties for Violations

Raw-material-origin labelingis a labeling system, based on the Food Labeling Act, made mandatory forall processed foodsmade within Japan. The food labeling standards were revised and enforced on September 1, 2017, and after a 5-year transitional period,fully enforced on April 1, 2022. Because a labeling-rule violation carries the risk of penalties or product recall, staff at processed-food OEM and food makers must grasp the system's overview and practice.

This article organizes the latest raw-material-origin labeling system based on the Food Labeling Act and Consumer Affairs Agency guidelines—the 4 labeling patterns, the difference between “domestic” and “made in Japan,” practical points for dried vegetables, violation cases and penalties, and an in-house checklist—based on official information.

We have materials available to help you understand dried processing OEM

Agriture OEM, flexibly handling everything from small lots to large lots

• OEM supported from 100 g of existing raw material
• Drying of brought-in raw materials also possible
• Support from processing to filling in one place

Download the materials here

What is the raw-material-origin labeling system

Raw-material-origin labeling is a system that clearly shows consumers the origin of theraw material ranked first by weight ratioin a processed food. The September 1, 2017 revision of the food labeling standards expanded it from the former 22 food groups + 4 individual items toall processed foods.

Fresh foods have a separate system (origin labeling for fresh foods), and individual items like soybeans, wheat, and meat have further detailed labeling rules, so sorting out which system your product falls under first is the starting point of practice.

References:Consumer Affairs Agency | Information on the new raw-material-origin labeling system for processed foods、Ministry of Agriculture, Forestry and Fisheries | On the raw-material-origin labeling system for processed foods、e-Gov | Food Labeling Act

The 4 patterns of origin labeling

For raw-material-origin labeling, besides the principle ofcountry-by-country weight-order labeling, three exception labels are permitted according to the actual sourcing situation. You need to choose the pattern that fits your own raw-material sourcing flow.

Notes on using “or” labeling and broad-grouping labeling

“Or” labeling and broad-grouping labeling are convenient, butrecording of usage results or past evidenceis required. If the label and the reality diverge, it's judged false labeling and canbecome subject to a corrective order or recall, so retaining per-lot raw-material-origin records is essential in practice.

References:Consumer Affairs Agency | Information on the new raw-material-origin labeling system for processed foods、Ministry of Agriculture, Forestry and Fisheries | On the raw-material-origin labeling system for processed foods

The decisive difference between “made in Japan” and “domestic”

An easily confused point in processed-food labeling is the difference between“made in Japan” and “domestic.”The two clearly differ in meaning, and it's a point consumers watch closely.

It's not rare for the raw material to be an import even when “made in Japan” is labeled. If you're putting forward a “domestic appeal” in product design, you needbacking that the raw material is Japanese-grown from the ingredient level, and you have the right to use the wording “domestic” on the label.

Labeling points to watch for dried vegetables and processed foods

Dried vegetables often circulate as processed foods, so they're an item where the labeling-rule application pattern tends to get complex. Grasp the following points.

• Treated as fresh food or as processed food: drying alone may be treated as fresh food, but cutting, blending, or the packaging form can make it treated as processed food
• domestic dried vegetables: if the raw material (fresh vegetable) is Japanese-grown, the “domestic” label is possible. If the drying process is overseas, it won't be “made in Japan”
• Mixed products: origin labeling is mandatory only for the top-weight raw material. The remaining items are optional labeling
• AdditivesIncluding (glucose, etc.) also applies the separate labeling rules for food additives
• Additive-free appeal: separately from raw-material-origin labeling, you must also follow the Consumer Affairs Agency's “additive-free” guidelines (revised 2022)

References:Consumer Affairs Agency | Food labeling、Consumer Affairs Agency | Food Labeling Act, etc. (laws and consolidated information)

Violation cases and penalties

If you violate the Food Labeling Act, the Consumer Affairs Agency, local governments, and the Ministry of Agriculture, Forestry and Fisheries issuean instruction, order, or corrective guidance. In malicious cases or those involving health harm, a penalty may be applied directly.

Range of main penalties

• Food Labeling Act violation (serious matters such as false origin labeling):up to 3 years' imprisonment or a fine of up to 3 million yen (individual) / a fine of up to 300 million yen (corporation)
• General labeling violation: administrative guidance or order; penalty upon violation of an order
• Premiums and Representations Act (in case of joint application for misleading superiority/advantage): measure order / surcharge

References:e-Gov | Food Labeling Act、Ministry of Agriculture, Forestry and Fisheries | On the number of guidance cases related to Food Labeling Act and JAS Act violations、Consumer Affairs Agency | Premiums and Representations Act

A checklist for your product's origin labeling

A checklist for processed-food makers and OEM buyers to inspect their own product's labeling. We recommend confirming at an inventory review at least once a year.

• Is the top-weight raw material identified?
• Do the chosen labeling pattern (of the 4) and the reality match?
• Are you retaining the evidence records for “or” labeling and broad-grouping labeling (at least the past 3 years)?
• Is the use of “domestic” and “made in Japan” correct?
• Are the labels for food additives, allergens, and nutrition facts also complete?
• Do the actual packaging material and label match the spec sheet?
• Is a labeling-update flow in place for new suppliers and origin changes?
• Do you check for Consumer Affairs Agency guideline revisions once a year?

We have materials available to help you understand dried processing OEM

Agriture OEM, flexibly handling everything from small lots to large lots

• OEM supported from 100 g of existing raw material
• Drying of brought-in raw materials also possible
• Support from processing to filling in one place

Download the materials here

FAQ

Summary | Protect your labeling with “records” and “consistency”

With full enforcement in April 2022, the raw-material-origin labeling system has become an essential item of practice for food makers and OEM buyers. Beyond choosing the labeling pattern, securingper-lot record retention and consistency between label and realitywithin your yearly operation is what minimizes violation risk. We recommend regularly checking the latest revision trends on the Consumer Affairs Agency's official information. For how Agriture handles origin labeling for commercial dried vegetables, see the[Commercial] Dried vegetables | Domestic dried-goods ingredientspage.

Recommended reading

→ [Commercial] Dried vegetables | Domestic dried-goods ingredients

→ The Difference Between Domestic and Chinese Dried Vegetables: Quality and Cost Comparison and Practical Uses

→ Practical Guide to Importing Dried Vegetables: Tariffs, HS Codes, and Quarantine Explained

→ HACCP Compliance in Food Processing: A Practical Guide to the Necessity by Processing Form and Use

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