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Japan to Require Allergy Labeling for Walnuts

Japan’s Consumer Affairs Agency (CAA) will add walnuts to list of allergens that product manufacturers and importers must include on the label of packaged products containing walnuts. Currently, CAA strongly recommends including walnuts on the label, but does not require their inclusion. CAA will hold a public comment period prior to making this modification to the Food Labeling Standards, but have not yet announced dates for the comment period. Exports of U.S. walnuts to Japan have grown from 10,604 metric tons to 21,944 metric tons over the last decade.

General Information

Japan’s Consumer Affairs Agency (CAA) announced that it will add walnuts to the list of allergens that food manufacturers and importers must include on product packaging labels. CAA has not yet scheduled a date for the public comment period. Japan’s Food Labeling Standard currently includes walnuts on the list of allergens that it highly recommends food manufacturers and importers include on packaging. Since February 2021, CAA has held three Advisor Meetings on Food Allergy Labeling to determine if walnuts should be added to the list of allergens with mandated labeling requirements. The advisory panel found that walnuts should be added to the list of allergens required for labeling based on the results of a new longitudinal study on food allergies in Japan. On June 6, during the during the 67th Food Labeling Subcommittee meeting, the Cabinet Office’s Consumer Committee reviewed this issue.

Food Allergy Labeling

The Ministry of Health, Labour and Welfare (MHLW) established food allergen labeling standards in 2001 before oversight of the Food Labeling Standard shifted to CAA, a division of the Prime Minister’s Cabinet Office, in 2009. Cabinet Order No.10 currently requires allergy labeling for seven “required ingredients” and highly recommends allergy labeling for 21 “recommended ingredients,” see Table 1.

If CAA classifies an allergen as a required ingredient, and it is present in a food product, then the product manufacturer or importer must include the name of the individual allergen on the packaging. If a required ingredient is included as part of a processed ingredient within the final product, the label must also include the name of the allergen, for example, “cake mix (including wheat, egg, milk).” For recommended ingredients, CAA highly recommends the label include the name of the allergen within the ingredient list. The labeling standard allows for labels to list all existing individual recommended ingredients and recommended ingredients collectively. The Food Labeling Standard does not require labels indicate which ingredients are allergens, but product manufactures may choose to do so. See Table 2 for examples of approved labeling of allergens. Please see JA7078 for more details on the Food Labeling Standard.

CAA periodically revises the allergy labeling requirements. To do so, CAA relies on the “Reports on Food Labeling Related to Food Allergies Investigation Project,” which it publishes approximately every three years. This series of longitudinal surveys is a compilation of food allergy case reports.

Japanese importers and manufacturers bear sole responsibility for the development of labels compliant with Japanese food labeling regulations, including allergy labeling. There is no legal obligation for U.S. exporters to affix Japanese labels to their products prior to export. Please see Food and Agricultural Import Regulations and Standards for the current Japanese food labeling requirement.

Production and Trade

There is limited walnut production in Japan, hovering around 35-60 metric tons2 (MT) per year. As shown in Figure 1, Japan has roughly doubled walnut imports over the last decade, with most growth coming from U.S. walnuts. In 2021, Japan imported about 21,944 MT of shelled walnuts from the United States. For more details about the tree nuts market in Japan, see JA2022-0036. — By Daisuke Sasatani, USDA Foreign Agricultural Service

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