Concept on New Country of Origin 
Labeling System for Ingredients  
(Supplementary Document)  
June 29 , 2017  
Consumer Affairs Agency  
 - 1 - 
 Table of Contents  
 
(Ingredients Subject to Labeling)  
1 Which processed foods would be subject to the mandatory country of origin labeling for ingredients?  
   .............  4 
2 What types of ingredients would be subject to mandatory labeling?   .............  4 
3 Are food additives subject to the country of origin labeling for ingredients?   .............  5 
 
(Labeling Methods)  
4 What is a basic labeling method used for ingredients classified as perishable food, for which supplying 
countries are listed in descending order by weight are labeled  as a general rule?  .............  5 
 
(Possible Suppliers Labeling)  
5 Which case is permitted for the “possible suppliers labeling” (labeling prescribed in 1 -(v)(a) of the 
processed food other than imported food column in the chart in Article 3, Paragraph 2 of the Food 
Labeling Standards)?    .............  8 
6  What is a basic labeling method used for the “possible suppliers labeling”?   .............  10 
7 When using the “possible suppliers labeling,” in order to prevent information from being misleading to 
consumers, ho w can we list a supplying country, for which in the past records on ingredients use , the 
ingredient ratio used in the specific product is significantly small ?    .............  13 
 
(All inclusive  Labeling)  
8 Which case is permitted for the “all inclusive  labeling” (labeling prescribed in 1 -(v)(b) of the processed 
food other than imported food column in the chart in Article 3, Paragraph 2 of the Food Labeling 
Standards)?  
How long can source documents for the all inclusive  labeling be used as evidence?  .............  14 
9  What is a basic labeling method used for the “all inclusive  labeling”?   .............  17 
 
(All inclusive  Labeling + Possible Suppliers Labeling)  
10 Which case is permitted when using both “ all inclusive  labeling” and “possible suppliers labeling” in 
combination (“import or domestic” or “domestic or import”)?   .............  18 
11 What is a basic labeling method used for a case using both “ all inclusive  labeling” and “possible suppliers 
labeling” in combin ation (“import or domestic” or “domestic or import”)?   .............  19 
 
(Past records on ingredients use , etc.)  
12 What expression is acceptable for a warning to indicate that such labeling is based on the past records on - 2 - 
 ingredients use  in the “possible suppliers labeling” and “ all inclusive  labeling + possible suppliers 
labeling?” How long does the record have to be in order to be recognized?   .............  20 
13 What types of documents should be retained for the “possible suppliers labeling,” “ all inclu sive labeling” 
or “all inclusive  labeling + possible suppliers labeling?”   .............  22 
14 When labeling based on the usage  plan, what level of legitimacy is required for the usage  plan?  
  .............  23 
15 Should source documents, etc. for the “possible suppliers labeling” and “ all inclusive  labeling, etc .” be 
retained?  
How long should these source documents, etc. for the “all inclusive  labeling” and “possible suppliers 
labeling ,” and others be retained for?    .............  24 
 
(Production Country Labeling for Semi -Processed Ingredients)  
16 In which case , the country of origin labeling for ingredients is considered for the production country 
labeling?                                                                 .............  24 
17 What typ es of processed work are not being considered as “domestically produced” among processing 
work performed domestically for imported semi -processed ingredients?   .............  28 
18 Are the “possible suppliers labeling” and “ all inclusive  labeling, etc .” permitted for  the production 
country labeling for semi -processed ingredients?   .............  29 
19 There are rules provided for labeling methods of ingredients for each item in Appendix 4 in the Food 
Labeling Standards. Following these rules and in the cas e of labeling the names of ingredients classified 
as perishable food by tracing them back instead of labeling the names of semi -processed ingredients, how 
shall we label countries of origin for ingredients?   .............  30 
 
(For Professional Use)  
20 Wha t are the labeling requirements for processed food products for professional use in relation to the 
country of origin labeling for ingredients?                                       .............  32 
21 How do we label <1> the country of origin and <2> the c ountry of origin for ingredients for processed 
food products for professional use?   .............  33 
22 Where shall we label the country of origin and the country of origin for ingredients for processed food 
products for professional use?   .............  34 
23 What are the labeling requirements for perishable food for professional use in relation to the country of 
origin labeling for ingredients?                                                .............  35 
24 How shall we label the country of origin for perishable food for professional use?  .............  35 
25 Where shall we label the country of origin for perishab le food for professional use?   .............  36 
 
(Others)  - 3 - 
 26 “Nori for Rice Balls” is individual ly subject to the country of origin labeling requirements for ingredients. 
What is the scope of the “Rice Balls” and how shall we label the country of origin for ingredients?  
  .............  36 
27 In the case of voluntary labeling ingredients of products, where the country of origin labeling for 
ingredients is not required, how shall we label them on the container or package?  .............  37 
28 Is it ok to voluntarily provide information regarding the countries of origin for ingredients on websites, 
etc.?                                                                    .............  37 
29 What are the transitional measures applied for the expansion of the country of origin labeling for 
ingredients  for all processed foods?   .............  38 
30 How do you plan to work on public awareness for consumers on the introduction of this new country of 
origin labeling for ingredients?   .............  38 
  - 4 - 
 1 Which processed foods would be subject to the mandatory country of origin labeling for 
ingredients?  
 
1  For the purposes of provision of information to customers, all processed foods made or processed in Japan 
are subject to  the mandatory country of origin labeling for ingredients.  
 
For imported products (including products, which have been processed domestically after being imported 
but there have been no substantial changes to them), as previously required, the “country of origin” must be 
labeled as imported products. The country of origin labeling for ingredients is not required.  
 
2  The following cases do not require the country of origin labeling for ingredients, which is the same 
procedure for labeling requirements, etc. for ingredients.  
 When setting up a facility to provide fo od and drinks (eating out)  
 When selling food products at a place, where such products are made or processed (so called in -store 
processing)  
 When distributing to an unspecified or a large number of people ( excluding selling ) 
 When selling food without contai ners or packages  
 
Labeling the country of origin for ingredients can be avoided in the following case.  
 When the area on the container or package where labeling could be placed is 30cm2 or less  
 
 
2 What types of ingredients would be subject to mandatory labeling?  
 
1  With respect to providing information to consumers, it is desirable to include as many ingredients as possible 
for mandatory labeling. However, having considered the feasibility of implementation by businesses, the largest 
ingredient by weight in the ingre dients (the most predominant ingredient by weight) is subject to mandatory 
labeling, for which the name of the ingredient and its country of origin are required to be labeled.  
However, the following items have separate standards, which provide with the in gredients that are subject to 
mandatory labeling.  
 For pickled agricultural products, top 4 (or 3) predominant ingredients, which constitute 5% or more  
 For frozen vegetable products, top 3 predominant ingredients, which constitute 5% or more  
 For processed eel products, eel  
 For dried bonito flakes, dried bonito  
 For rice balls, nori  
 - 5 - 
 2  In the case where the country of origin of the most predominant ingredient by weight is labeled under the 
following laws, the provisions for the country of origin labeling fo r ingredients in the Food Labeling Standards 
will not apply for the said ingredient.  
① Act on Information Records on Transactions, etc. and Relay of Information on Origin of Rice, etc. (Rice 
Traceability Act) (Act No. 26 of 2009)  
② Act Concerning Liquor Busi ness Associations and Measures for securing Revenue from Liquor Tax   
(Act No. 7 of 1953)  
As of XX(Month) , 2017, the Production Method and Quality Labeling Standards for Fruit Alcoholic 
Beverages, etc. (National Tax Agency Notice No. 18 of 2015 ) have been adopted as labeling standards under 
②.  
 
 
3 Are food additives subject to the country of origin labeling for ingredients?  
 
1  In the Food Labeling Standards, ingredients and food additives are explicitly distinguished.   
Only ingredients are su bject to the country of origin labeling for ingredients and food additives are not 
subject to labeling requirements.  
 
2  Therefore, even if a food additive is the most predominant ingredient by weight in a particular food, the said 
food additive is not required to be labeled. The largest ingredient by weight in the ingredients (the most 
predominant ingredient by weight) is s ubject to the labeling requirements.  
Any food consisting of only food additives is not required to have such labeling.  
 
3  Countries of origin for diluents (lactose, flour, starch, etc.), which had originally been included in those sold 
as food additives , are not required to be labeled.  
 
 
4  What is a basic labeling method used for ingredients classified as perishable food, for which 
supplying countries in descending order by weight are labeled  as a general rule?  
 
1  For any ingredients domestically produced and for any imported ingredients, these should be labeled 
“indicating that it is domestically produced” and “countries of origin,” respectively.  
 
2  In the case of ingredients being domestically produced, in addition to indicating that  they are domestically 
produced, the following labeling is accepted.  
 - 6 - 
 ① If the ingredients are agricultural products:  
Any names of prefectures or other names of places generally known can be labeled. The labeling of 
“domestic” is a general rule for the country of origin labeling for ingredients. If a name of a place is an 
area that is more restricted than “domestic,” it can be labeled.   
For example, the name of a region that is wider than a prefecture (such as “Made in Kyushu” and “Made 
in Kanto”) can be u sed in a label as the generally known name of the place.  
② If ingredients are livestock products:  
Any names of prefectures or other names of places generally known can be labeled, which is the same 
procedure for agricultural products.   
③ If ingredients are f ishery products:  
Any names of waters, landing ports, or names of prefectures or other names of places generally known, 
where the landing port or the main cultivation site is located, can be labeled.  
 
3  If ingredients are imported fishery products, the na me of the waters can also be labeled with the country of 
origin. For example, if fish (Patagonian Toothfish) is caught in the Kerguelen Islands of the French territory in 
the Indian Ocean and the country of origin is labeled as “France,” this may mislead c onsumers that the fish was 
caught in French waters in the EU. In the case where the name of the country confuses the consumers, the name 
of the waters can also be labeled. For example, “Ingredients: Patagonian Toothfish (France (Indian Ocean)).  
However, i t is not permitted to state only the name of the waters since this may indicate it has been 
domestically produced.  
 
4  The followings are specific labeling examples. (Any of examples 1 to 3 is acceptable.)  
 
<<Example 1: Labeling in the country of origin column>>  
Name  Pork sausage (wiener)  
Ingredients  Pork, Lard, Hydrolyzed Protein (contains Soybeans, Pork, Gelatin), 
Reducing Sugar Syrup, Salt, Spice (contains Soybeans) / Seasoning 
(Amino Acid, etc.) , Phosphoric Salt (Na, K), ...  
Country of Origin  Canada, USA (pork)  
Net 150 g  
Expiration date  March 31, 2017  
How to store  Store at 10ºC or below  
Producer  XX Co., Ltd.  
X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo  
 
 - 7 - 
 <<Example 2: Labeling in brackets in the ingredients column (Remarks 3: Appended Form 1 in the Food Labeling 
Standards)>>  
Name  Pork sausage (wiener)  
Ingredients  Pork (Canada, USA), Lard, Hydrolyzed Protein (contains Soybeans, 
Pork, Gelatin), Reducing Sugar Syrup, Salt, Spice (contains 
Soybeans) / Seasoning (Amino Acid, etc.) , Phosphoric Salt (Na, 
K), ...  
Net 150 g  
Expiration date  March 31, 2017  
How to store  Store at 10ºC or below  
Producer  XX Co., Ltd.  
X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo  
 
<<Example 3: If labeling in the collective labeling column is not possible, the labeling can be shown somewhere 
else>>  
Name  Pork sausage (wiener)  
Ingredients  Pork, Lard, Hydrolyzed Protein (contains 
Soybeans, Pork, Gelatin), Reducing Sugar 
Syrup, Salt, Spice (contains Soybeans) / 
Seasoning (Amino Acid, etc.) , Phosphoric 
Salt (Na, K), ...  
Country of Origin  Written under the product name  
Net 150 g  
Expiration date  March 31, 2017  
How to store  Store at 10ºC or below  
Producer  XX Co., Ltd.  
X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo  
 
  Product Name  
 
Countries of Origin of 
Pork as Ingredients  
Canada, USA  - 8 - 
 <<Inappropriate Labeling Example>>  
*In Example 1, if there are several ingredients, it is required to label the ingredient corresponding to the country 
of origin by adding the brackets after the said country of orig in since labeling only the country of origin in the 
country of origin column may not make it apparent as to which ingredient is derived from the said country of 
origin.  
Name  Pork sausage (wiener)  
Ingredients  Pork, Lard, Hydrolyzed Protein (contains Soybeans, Pork, Gelatin), 
Reducing Sugar Syrup, Salt, Spice (contains Soybeans) / Seasoning 
(Amino Acid, etc.) , Phosphoric Salt (Na, K), ...  
Country of Origin  Canada, USA  
Net 150 g  
Expiration date  March 31, 2017  
How to store  Store at 10ºC or below  
Producer  XX Co., Ltd.  
X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo  
 
 
5  Which case is permitted for the “possible suppliers labeling” (labeling prescribed in 1 -(v)(a) of 
the processed food other than imported food column in the chart in Article 3, Paragraph 2 of  the 
Food Labeling Standards)?  
 
1  For the purpose of providing information to consumers, the labeling of supplying countries in descending 
order by weight is a general rule. The “labeling of possible suppliers” is, however, permitted only if the order 
by weight and supplying countries of a  product are expected to be changed within a year including at a time 
when the new labeling is expected and when labeling supplying countries in descending order by weight in 
consideration of the past records on ingredients use  by supplying country (usage plans  by supplying country  for 
a defined period of time in the future for a new product or if the change of the country of origin for the 
ingredients is very likely) over a defined period of time, and only if it is going to be difficult to label  supplying 
countries in descending order by weight.  
In addition to the above, retention of the following documents is a required condition.  
① Documents indicating that the changes of the order of supplying countries by weight and changes of 
supplying countries over a defined period of time  
② Documents indicating the order of the ingredient ratio by countr y of origin for the said period of time  
 
2  The past records on ingredients use  by supplying countr y must cover at least a period of one year within 
three years prior to the year of production. (See Example 1)  × - 9 - 
  
3  As a general rule, the labeling of possible suppliers is based on the past records on ingredients use  by 
supplying countr y. In the cases of a new product or of the change of the supply ing countries for the ingredients 
being very likely, where  the past records on ingredients use  by supplying countr y cannot be used, the labeling 
of possible suppliers is permitted based on the future usage  plans for ingredients by supplying countr y. 
The future usage plan by supplying countr y must be a plan set one year or less from the scheduled start dat e 
of production based on the said plan. The labeling of possible suppliers based on the said plan is not  permitted 
for a product made outside the planning period. (See Example 2)  
 
4  The labeling of possible suppliers is one of the exceptions. Even if a supplying country is expected to be 
changed, if it is not considered difficult to list the names of supply ing countries in descending order by weight 
such as a case where each label can be changed accordingly or a package itself can be easily changed, this 
labeling is not applicable.   
 
5  Site inspections to businesses by government or local government will c onfirm whether or not the labeling is 
properly implemented for the country of origin labeling for ingredients. Interviews will be conducted to check 
the reasons for the labeling of possible suppliers, etc. Source documents, which should be retained as a re quired 
condition, are also inspected.  
 
(Example 1: Concept of “ the past records on ingredients use ,” which can be used as evidence)  
2013  2014  2015  2016  2017  
Production 
Year 2018  
 
 
Tracing back 3 years 
2–3 years  ago 
1–2 years ago  
V oluntary 1 and a half 
years  
2 years ago  
1 year ago  
V oluntary 1 year  
3 years ago  Concept of evidence of 
the past records on 
ingredients use  for a 
period exceeding 1 year  
Concept of evidence of 
the past records on 
ingredients use  for a 
period of 1 year  - 10 - 
 (Example 2: Labeling using Usage  Plans )  
2016  2017  2018  2019  
 
 
 
 
6 What is a basic labeling method used for the “possible suppliers labeling”?  
 
1  The “possible suppliers labeling” is a method listing potential supplying countries as countries of origin for 
the ingredients in descending order by weight based on the past records on ingredients use , whose country 
names will be connected with “or.”   
 
For example, if labeled “Country A or Country B”  
① They mean the following 4 approaches as a country of origin: “Country A only,” “Country B only,” “the 
order of Country A  and Country B,” and “the order of Country B and Country A.”    
This labeling  means the use  of the ingredient can only be permitted within the scope of labeled countries. 
It is not permitted to use an ingredient  whose supplying country is not labeled. Therefore, if the actual 
product includes an ingredient supplied by Country C, the labeling of “Country A or Country B” cannot be 
used.  
② This indicates that in the past records on ingredients use , the usage portion of ingredients supplied by 
Country A is greater than the usage portion of ingredients supplied by Country B.  
The order of the labeling can only be the order based on the past records on ingredients use  for periods 
Planning Period  
Possible suppliers labeling  
permitted for any products 
produced during this period  
Planning Period  
Possible suppliers labeling  
permitted for any products 
produced during this period  From the middle of 
the year  From the start of 
the year  - 11 - 
 illustrated in Section 5 above. For example, if it is considered difficult to label  supplying countries in 
descending order by weight based on the past records on ingredients us e of 2015, the order of countries 
should be listed based on the past records on ingredients use  of 2015. The names of countries cannot be 
labeled in the order of ingredients use  in other period s.  
 
2  If there are 3 or more countries of origin for an ingredient, the third country and beyond can be labeled as 
“others,” which is the same procedure for labeling supplying countries in descending order by weight.  
For example, if labeling “Country A or Country B or Others,” this indicates that there are 3 o r more 
supplying countries in the past records on ingredients use , and the descending order by weight for the first two 
countries would be Country A and Country B, with the ingredient supplied by Country A having a greater 
percentage.  
 
3  It is required a lways to include a warning to indicate that such labeling is based on the past records on 
ingredients use  on the container or package, together with the country of origin labeling. (See 12 below)  
 
<<Example 1: A case of 2 foreign supplying countries>>  
Name  Pork sausage (wiener)  
Ingredients  Pork (Canada or USA), Lard, Hydrolyzed Protein (contains 
Soybeans, Pork, Gelatin), Reducing Sugar Syrup, Salt, Spice 
(contains Soybeans) / Seasoning (Amino Acid, etc.) , Phosphoric Salt 
(Na, K), ...  
Net 150 g  
Expiration  date March 31, 2017  
How to store  Store at 10ºC or below  
Producer  XX Co., Ltd.  
X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo  
*Countries of origin for pork and the order are based on the past records on ingredients use  in 2015  
 
  - 12 - 
 <<Example 2: A case of 2 supplying countries including Japan>>  
Name  Pork sausage (wiener)  
Ingredients  Pork (USA or domestic), Lard, Hydrolyzed Protein (contains 
Soybeans, Pork, Gelatin), Reducing Sugar Syrup, Salt, Spice 
(contains Soybeans) / Seasoning (Amino Acid, etc.) , Phosphoric Salt 
(Na, K), ...  
Net 150 g  
Expiration date  March 31, 2017  
How to store  Store at 10ºC or below  
Producer  XX Co., Ltd.  
X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo  
*Countries of origin for pork and the order are based on the past records on ingredients use  over a two -year period 
since 2014  
 
<<Example 3: A case of 3 supplying countries>>  
Name  Dark Soy Sauce (Naturally Brewed)  
Ingredients  Soybeans (USA or Canada or Brazil), Wheat, Salt  
Net 400ml  
Expiration date  September 30, 2017  
How to store  Store at room temperature away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
*Countries of origin for soybeans and the order are based on the past records on ingredients use  of last year   - 13 - 
 <<Example 4: A case of 3 or more supplying countries using “others”>>  
Name  Pork sausage (wiener)  
Ingredients  Pork (Canada or USA or Others), Lard, Hydrolyzed Protein (contains 
Soybeans, Pork, Gelatin), Reducing Sugar Syrup, Salt, Spice 
(contains Soybeans) / Seasoning (Amino Acid,  etc.), Phosphoric Salt 
(Na, K), ...  
Net 150 g  
Expiration date  March 31, 2017  
How to store  Store at 10ºC or below  
Producer  XX Co., Ltd.  
X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo  
*Countries of origin for pork and the order are based on the past records on ingredients use  over the period from 
September 2015 to August 2016  
 
 
7  When using the “possible suppliers labeling,” in order to prevent information being misleading 
to consumers, how can we list a supplying country, for which in the past records on ingredients 
use, the ingredient ratio used in the specific product is significantly small?  
 
When using  the “possible suppliers labeling,” the “possible suppliers labeling” will display countries based 
on the past records on ingredients use , etc. It is, th us, necessary to prevent consumers from any 
misunderstanding, in the case of the ingredient ratio used in the specific product being significantly small.  
In order to prevent any information from being misleading to consumers, it is mandatory to label as f ollows 
for any supplying countries, of which the ingredient ratio used in the specific product is significantly small.  
① “Ingredient ratio used in the specific product is significantly small” means a percentage composition of 
“less than 5%.”  
② Including when the “possible suppliers labeling” is used in the “all inclusive  labeling + possible 
suppliers labeling” and “production country labeling for semi -processed ingredients,” in the case of the 
“possible suppliers labeling,” it is required to label “less than 5%” by adding the brackets after the country of 
origin for any country of origin, whose usage percentage per  past records on ingredients use  is less than 5%.  
③ A warning is required to be shown that the percentage composition is based on the past records on  
ingredients use , etc.  
 
  - 14 - 
 <<Example: A case of “Possible Suppliers Labeling” having a country of origin, whose percentage composition is 
less than 5%>>  
Name  Dark Soy Sauce (Naturally Brewed)  
Ingredients  Soybeans (USA or Domestic (less than 5%)), Wheat, Salt 
Net 400ml  
Expiration date  September 30, 2017  
How to store  Store at room temperature away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
*The order of countries of origin and portion for soybeans are based on the past records on ingredients use  in 2015  
 
 
8  Which case is permitted for the “all inclusive  labeling” (labeling prescribed in 1 -(v)(b) of the 
processed food other than imported food column in the chart in Article 3, Paragraph 2 of the 
Food Labeling Standar ds)? 
How long can source documents for the all inclusive  labeling be used as evidence?  
 
1  For the purpose of providing information to consumers, the labeling of supplying countries in descending 
order by weight is a general rule. The “ all inclusive  labeling” is, however, permitted only if the order by weight 
and supplying countries of a product are expected to be changed within a year for the labeling of the ingredient 
originating from three or more foreign countries including at the time when the n ew labeling is expected and 
when labeling supplying countries in descending order by weight in consideration of the past records on 
ingredients use  by supplying countr y (usage  plans  by supplying countr y for a defined period of time in the 
future for a new product or if the change of the country of origin for the ingredients is very likely) ove r a 
defined period of time, and only if it is going to be difficult to list supplying countries in descending order by 
weight.   
In addition to the above, retention of  documents indicating that the changes of the order of supplying 
countries by weight and changes of supplying countries over a defined period of time is a required condition.   
 
2  The past records on ingredients use  by supplying countr y must cover at least a period of one year within the 
three -year period prior to the year of production. (See Example 1)  
 
3  As a general rule, the all inclusive  labeling is based on the past records on ingredients use  by supplying 
countr y. In the cases of a new product or of the change of the purchasing countries for the ingredients being 
very likely, where the past records on ingredients use  by supplying countr y cannot be used, the all inclusive  
labeling is permitted based on the future usage  plans  for ing redients by supplying countr y. - 15 - 
 The future usage  plan by supplying countr y must be a plan set one year or less from the scheduled start date 
of production based on the said plan. The “ all inclusive  labeling” based on the said plan is not permitted for a 
product made outside the planning period. (See Example 2)  
 
4  The all inclusive  labeling is one of the exceptions. Even if a supplying country is expected to be changed, if 
it is not considered diffi cult to list the names of supplying countries in descending order by weight such as a 
case where each label can be changed accordingly or a package itself can be easily changed, this labeling is not 
applicable.   
 
5  The "ingredient originating from three or more foreign countries" means several imported countries from the 
Northern and Southern Hemisphere depending on the season so that a particular agricultural product, for 
example, could be procured consistently throughout the year. As the result, it is a ssumed that the usage status by 
supplying countr y could switch between "only countries in the Northern Hemisphere," "combined countries in 
the Northern and Southern Hemispheres," and "only countries in the Southern Hemisphere."  
It may not be considered di fficult to list the names of supplying countries in descending order by weight, in 
the case where ingredients are intentionally procured from several countries only for a short period of time in 
order to switch or combine countries of origin only for the p urpose of the "all inclusive  labeling," even though 
the procurement circumstances for the ingredients allow the listing of the names of supplying countries in 
descending order. (See Example 3)  
 
6  Site inspections to businesses by government or local government will confirm whether or not the labeling is 
properly implemented for the country of origin labeling for ingredients. Interviews will be conducted to check 
the reasons for the all inclusive  labeling, etc. Source documents, which should be retained as a required 
condition, are also inspected.  
 
 
  - 16 - 
 (Example 1: Concept of “ the past records on ingredients use ,” which can be used as evidence)  
2013  2014  2015  2016  2017  
Produc tion 
Year 2018  
 
 
 
(Example 2: Labeling using Usage  Plans)  
2016  2017  2018  2019  
 
  
Tracing back 3 years  
2–3 years ago  
1–2 years ago  
V oluntary 1 and a half years  
2 years ago  
1 year ago  
V oluntar y 1 year  
3 years ago  Concept of evidence of 
the past records on 
ingredients use  for a 
period exceeding 1 year  
Concept of evidence of 
the past records on 
ingredients use  for a 
period of 1 year  
Planning Period  
All inclusive  labeling 
permitted for any products 
produced during this period  
Planning Period  
All inclusive  labeling 
permitted for any products 
produced during this period  From the middle of 
the year  From the start of 
the year  - 17 - 
 (Example 3)  
Jan Feb Mar Apr May June July Aug Sep Oct Nov Dec 
 
 
 
 
9  What is a basic labeling method used for the “all inclusive  labeling”?  
 
1  The “ all inclusive  labeling” is a labeling method for bundling foreign supplying countries together in a 
category classed as “import.”  
The labeling as "import" indicates that, in relation to the labeling of origin of three or more foreign countries, 
the order by weight and supplying countries are expected to be changed or switched within the year set by the 
business on the basis of the past records on ingredients use  by supplying countr y over a defined period of time.  
The labeling as “import, domestic” indicates that, in rel ation to the actual countries of origin for the 
ingredient, the imported products (total) are greater by weight than domestic products.   
 
2  In addition to “import,” it is possible to label as “foreign product,” “foreign,” “oversea product,” and 
“oversea s,” and others.   
 
  
(An envisaged case)  
Country A  
Country B  
Country C  
Country D  Country A  
Country B  
Country A  
Country B  
Country C  (A case not envisaged)  - 18 - 
 <<Example  1: A case of the ingredient originating from 3 or more foreign countries>>  
Name  Dark Soy  Sauce (Naturally Brewed)  
Ingredients  Soybeans (Import), Wheat, Salt  
Net 400ml  
Expiration date  September 30, 2017  
How to store  Store at  room temperature away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
 
<<Example 2: A case of imported portion being greater than domestic portion>>  
Name  Dark Soy Sauce  (Naturally  Brewed)  
Ingredients  Soybeans (Import, Domestic), Wheat, Salt  
Net 400ml  
Expiration date  September 30, 2017  
How to store  Store at room temperature away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
 
<<Example 3: A case of domestic portion being greater than imported portion>>  
Name  Dark Soy  Sauce (Naturally Brewed)  
Ingredients  Soybeans (Domestic, Import), Wheat, Salt  
Net 400ml  
Expiration date  September 30, 2017  
How to store  Store at room temperature away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
 
 
 
10  Which case is permitted when using both “ all inclusive  labeling” and “possible suppliers 
labeling” in combination (“import or domestic” or “domestic or import”)?  
 
1  The combined application of the "all inclusive  labeling" and “possible suppliers  labeling ” is permitted only if 
the order by weight and supplying countries of a product are expected to be changed within a year including at 
the time when the labeling of "import" and "domestic" is expected and when labe ling all inclusive  suppliers in - 19 - 
 consideration of the past records on ingredients use  by supplying countr y (usage  plans by supplying countr y for 
a defined period of time in the future for a new product or if the change of the country of origin for the 
ingre dients is very likely) over a defined period of time, and only if it is going to be difficult to label all 
inclusive  suppliers.  
 
2  This means that, in addition to meeting the conditions permitted for the “all inclusive  labeling” in Section 8 
above, there is a change for the order by weight for the imported ingredients (total) and domestic ingredients 
during the same period and if it is going to be difficult to display such labels with “import, domestic,” or 
“domestic, i mport.”  
 
(Example: A case, where the combined application of “ all inclusive  labeling” and “possible suppliers  labeling ” is 
permitted ) 
 
 
 
11  What is a basic labeling method used for a case using both “ all inclusive  labeling” and 
“possible suppliers labeling” in combination (“import or domestic” or “domestic or import”)?  
 
1  The combination of the “all inclusive  labeling” and “possible suppliers labeling” is a method listing “import” 
and “domestic” in descending orde r by weight based on the past records on ingredients use , which are 
connected with “or.”  
For example, when labeling “Import or Domestic ,”  
① They mean the following 4 approaches as places of origin: “Import only,” “Domestic, only,” “the order 
of Import, Domestic,” and “the order of Domestic, Import.”   
② This indicates that in the past records on ingredients use , the usage percentage of ingredien ts supplied 
by imported products (total) is greater than the usage percentage of ingredients supplied by domestic 
products.  
 
Apr to Jun e 
July to Sep  
Oct to Dec  
Jan to Mar  Country A  Country B  
Country C  Country C  Domestic  
Country A  Country B  
Domestic  Country B  
Country B  Country A  
Country  A Country C  Country C  
Domestic  Total of Import > Domestic  
Country A is predominant  
Only Import  
Country C is predominant  
Total of Import < Domestic  
Domestic is predominant  
Total of Import > Domestic  
Country B is predominant  - 20 - 
 2  In order to prevent information being misleading to consumers, it is always required to include a warning on 
the container and package that such labeling is based on the past records on ingredients use , together with the 
labeling of countries of origin. (See Section 12 below)  
 
<<Example 1>>  
Name  Pork sausage (wiener)  
Ingredients  Pork (Import or Domestic), Lard, Hydrolyzed Protein  (contains 
Soybeans, Pork, Gelatin), Reducing Sugar Syrup, Salt, Spice 
(contains Soybeans) / Seasoning (Amino Acid, etc.) , Phosphoric Salt 
(Na, K), ...  
Net 150 g  
Expiration date  March 31, 2017  
How to store  Store at 10ºC or below  
Producer  XX Co., Ltd.  
X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo  
*Countries of origin for pork and the order are based on the past records on ingredients use  over the period from 
September 2015 to August 2016  
 
<<Example 2>>  
Name  Flour  
Ingredients  Wheat (Import or Domestic)  
Net 1 kg 
Expiration date  March 31, 2018  
How to store  Store at room temperature in a cool dry place  
Producer  XX Co., Ltd.  
X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo  
*Countries of origin and the order for wheat are based on the past records on ingredients use  that date back 2 
years from  the expiration  date 
 
 
12  What expression is acceptable for a warning to indicate that such labeling is based on the past 
records on ingredients use  in the “possible suppliers labeling” and “ all inclusive  labeling + 
possible suppliers labeling?” How long does the record have to be in order to be recognized?  
 
1  For a warning for the "possible suppliers labeling” and “ all inclusive  labeling + possible suppliers labeling,” - 21 - 
 when labeling the order based on the past records on ingredients use  by supplying countr y over a defined period 
of time, it is required to be shown so that consumers will know that the "labeling is not the order of the 
supplying countries by weight but the order based on the past records on ingredients use " together with the 
period of the said records. The following are specific examples:  
① Countries of origin for XX and the order are based on the past records on ingredients use  in 2015  
② Countries of origin for XX and the order are based on the past records on ingredients use  over a two -year 
period since 2014  
③ Countries of origin for XX and the order are based on the past records on ingredients use  of previous year 
or the past records from  two years ago  
④ Countries of origin for XX and the order are based on the past records on ingredients use  that date back X 
years from  the expiration  date 
⑤ Countries of origin for XX and the order are based on the past records of the period from September 2015  
to August 201 6.   
 As noted in Section 5, the period that can be tracked back is within 3 years from the production year (the 
year which the production date belongs to). For example, if the production year is 2017,  the past record (s) on 
ingredients use  of more than a y ear selected by the business operator among those in 2014, 2015, and 2016 can 
be specified  in the  note. 
It is required to indicate to consumers which period of the records are used for a product whose expiration 
period  is long.   
 
2  The followings are examples of notes for labeling  in the  order of the usage plans by supplying country over a 
defined period of time in the future:  
① Countries of origin for XX and the order are labeled based on the usage  plans of 2017  
② Countries of origin f or XX and the order are labeled based on the assumption from the contracted farming 
from June 2017 to May 2018  
③ Countries of origin for XX and the order are labeled based on the usage plans of 2017. Continuous 
labeling, if there is no change for the usage plans for 2018  
In any of the above cases, it is permitted to use them as a note if a product is produced within the said usage 
plans.  
 
3  For Japanese calendar years,  
① Label “Heisei XX,” if no specifications are given, whose period is assumed to be from January to 
December  
② Label “Heisei XX th Fiscal Year ,” if no specifications are given, whose period is assumed to be from April 
to March. (The same will apply for cases using the Western year instead of Heisei)  
In cases where operations  that differ from the above mentioned such as fiscal years set for each agricultural - 22 - 
 crop are applied,  the scope of the said year should be noted.  
Labeling of “the order based on the past records on ingredients use  of last year” indicates 2016 if the 
production year is 2017 , and 2017 if the production year is 2018. If the said labeling is continued, please check 
whether or not it is misleading labeling.  
 
4  The notes described  above are labeling examples. Please be creat ive in articulat ing country of origin labeling 
for ingredients of the said product is based on.  
 
 
13  What types of documents should be retained for the “possible suppliers labeling,” “all inclusive 
labeling” or “all inclusive labeling + possible suppliers labeling?”  
 
1  In the case of the “possible suppliers labeling,” “all inclusive labeling” or “all inclusive labeling + possible 
suppliers labeling,” as evidence confirming that this labeling is permitted for the ingredients,  
 it is required to retain documents showing th at a change of the order of countries of origin by weight or a 
switch of supplying countries is expected during the period set by the businesses through methods permitted in 
Sections 5 and 8 above for the ingredients used in the said product.  
For the “poss ible suppliers labeling” and “all inclusive labeling + possible suppliers labeling,” in addition 
to the above documents,  
 retention of documents showing the order of usage percentage by countries of origin in the ingredients (the 
total of imported products and domestic products for a case of the "possible suppliers labeling + all inclusive 
labeling") during the said period (a period that the note is indicated for)  
is required.  
 
2  For 1, the following examples could be considered as documents for the past records on ingredients use by 
supplying countr y over a defined period of time:  
① Invoices and delivery statements, etc. listing the country of origin  
② Specifications, etc. listing the country of origin and the container or package, invoices or delivery 
statem ents, etc. indicate that the product is based on which specifications, etc.  
③ Documents that show purchased ingredients have been used for the said product (production records, 
production manuals, etc.)  
. 
If the order of usage percentages by countr y of orig in in the ingredients is not easily determined from 
documents ① to③, any documents summarizing the details of ① to ③ and clarifying the order of usage 
percentages by countr y of origin in the said product are required to be retained.  
 - 23 - 
 3  For 1, the following examples could be considered for documents for the usage plans for ingredients by 
supplying countr y over a defined period of time in the future:  
① A usage  plan clearly specifying a supplying country for a product used in the ingredient  
② A procurement plan stating a supplying country from a supplier (a trading company, etc.) of the 
ingredient and a document clearly specifying the ingredient will be used based on the said procurement plan  
③ A contract on contracted farming, etc. with a producer and a document clearly specifying the ingredient 
will be used based on the said contract  
 
4  In any of the cases, any details that are considered reasonable as evidence for labeling should be retained 
depending on actual situations for production and distribution. At the time of supervising (site inspection), the 
actual circumstances of usage for ingredients will be cross checked with the details of the label. Please retain 
any documents that show the records of ingredients use at the time of produ cing the products.  
 
 
14  When labeling based on the usage plan, what level of legitimacy is required for the usage plan?  
 
1  When labeling based on the usage plan, and if (i) the actual usage results are significantly different and no 
legitimate explanation is given; and (ii) no legitimate explanation is given for the basis of setting the plan, the 
said usage plan is not considered as a source for labeling.  
 
① A case of the actual usage results being significantly different can be when labeling the third country and 
beyond among three or more supplying countries as "others," the majority of ingredients ended up being 
supplied by countries being categorized as "ot hers." This case is problematic because the label does not 
provide any names of supplying countries.  
 
(Examples of the actual usage results being significantly different)  
i) If originally labeling “Country A or Country B or Others,” it has resulted, during the planning period, that 
ingredients from neither Country A nor Country B were used and only ingredients from countries included 
in “Others” were used.  
ii) If originally label ing “Country A or Country B or Others,” it has resulted, during the planning period, that 
ingredients from either Country A or Country B were not used.  
 
② Cases of no legitimate explanation being given can be as follows.   
However, in the event of unexpecte d circumstances such as natural disaster, outbreak of a diseases epidemic 
in domestic animals, or suspension of shipping freight due to a port strike, etc., which is likely to cause 
significant strains on the stable supply of food, it is deemed that legiti mate explanations are possible.  - 24 - 
 i) A case, which is significantly different from the original usage plan, such as procurement, which is 
different from the plan due to the preferences of the company or the business, with which it trades.   
ii) A case, where suppli ers and contractors listed in the original plan were fabricated, as a result, ingredients 
from the labeled countries of origin have not been received.  
iii) Any other cases, where evidence of the plan is ambiguous. (A case, where the period for the usage  plan i s 
not specified or a case, where the names of the countries  where the ingredient will be used  are listed 
vaguely.)  
 
2  When labeling based on the past records on ingredients use  are significantly different (such as a case, where 
the predominant supplying country was, in fact, in the “Others”) with no legitimate explanation given for such 
labeling, which is the same circumstance as 1, such records  on ingredients use  are not regard ed as evidence for 
the labeling.  
 
 
15  Should source documents, etc. for the “possible suppliers labeling” and “all inclusive labeling, 
etc.” be retained?  
How long should these source documents, etc. for the “all inclusive labeling” and “possible 
suppliers labeling, etc .” be retained for?   
 
1  As one of the conditions for the “possible suppliers labeling” and “all inclusive labeling,” it is required to 
retain documents indicating that the changes of the order of supplying countries by weight and c hanges of 
supplying countries over a defined period of time and documents indicating the order of usage percentage by 
supplying countr y for the said period of time.   
 
2  The retention period for source documents, etc. is  
① 1 year from the expiration (best-before ) date on the product, whose label is written based on such 
evidence   
② 5 years from the production date, if the expiration  date is not displayed or omitted.  
 
3  If continuing with the “possible suppliers labeling” and “all inclusive labeling,” the current used percentages, 
etc. by supplying countr y will be used as the previously used records. Please retain these documents 
considering this factor.  
 
 
16  In which case of the country of origin labeling for ingredients is considered for the production 
country labeling?  - 25 - 
  
1  Production methods for processed foods can vary. They can be coherently produced at a company’s own 
factory from perishable ingredients or produced using semi -processed ingredients manufactured at a factory of 
a different company, ev en for the same named product. For these semi -processed ingredients, the country of 
origin labeling for ingredients should, as a general rule, label the country of origin for the ingredient used 
regardless of whether they are perishable ingredients or semi -processed ingredients, in the context of the 
following:  
 it is difficult to track back countries of origin for perishable ingredients used  
 it has always been the case that for labeling of the ingredients then “ingredients used” would be shown 
regardless of whether they are perishable ingredients or semi -processed ingredients  
On the other hand, in the case of the ingredient being a semi -processed ingredient, if a country of origin is 
labeled, this may mislead consumers as though the said country of origin is for a perishable ingredient. Thus, 
the country of origin for the said ingredient should be labeled as “produced in XX.”  
(“Processed in XX” labeling is not permitted.)  
 
2  If there are several countries to label as production countries, supplying countri es in descending order by 
weight is to be labeled as a general rule and the words “produced in” must always be added for each country. 
(The labeling of “Produced in Germany, Brazil” is not permitted.) “Produced in XX” in brackets needs to be 
shown after th e name of a semi -processed ingredient, which corresponds individually with the name of the 
semi- processed ingredient. That means, for example, “Apples (Processed in Germany)” cannot be labeled as 
such because the labeling “Produced in XX” corresponds to t he perishable ingredients.  
 
3  If a country of origin for ingredients used for a semi -processed ingredient can be traced back to a perishable 
ingredient, instead of labeling “Produced in XX,” the said country of origin can be labeled together with the 
said perishable ingredient.  
 
4  The other labeling methods are the same as perishable ingredients. That means that “Produced in XX 
Prefecture” can be used for labeling instead of “Domestically Produced.”  
 
  - 26 - 
 <<Example 1: Production country labeling for semi -processed ingredients>>  
Name  Non-alcoholic beverage  
Ingredients  Apple Juice (made in Germany), Fructose -glucose Syrup, 
Fructose/Acidifier, Vitamin C  
Net 500ml  
Expiration date  September 30, 2017  
How to store  Store in a cool dry place away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
 
Name  Dorayaki  
Ingredients  Pancake (Domestically Produced) (Eggs, Flour, Sugar), Tsubuan 
(Sugar, Azuki Beans, Malt Syrup, Agar) / Raising Agent  
Net 1 Piece  
Use by  March 31, 2017  
How to store  Store in a cool dry place away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
 
Name  Sliced Bread  
Ingredients  Flour (Domestic), Sugar, Margarine, Yeast, Salt (partially contains 
Wheat and Dairy Product)  
Net 6 Slices  
Use by  Written in the front  
How to store  Store in a cool dry place away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo  
 
 
  - 27 - 
 <<Example 2: Production country labeling for semi -processed ingredients (Labeling by adding a category of 
Country of Origin for Ingredients)>>  
Name  Non-alcoholic beverage  
Ingredients  Apple Juice, Fructose -glucose Syrup, Fructose/Acidifier, Vitamin C  
Country of Origin 
for Ingredients  Produced in Germany (Apple Juice)  
Net 500ml  
Expiration date  September 30, 2017  
How to store  Store in a cool dry place away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
 
<<Example 3: Labeling by tracing back the country of origin for semi -processed ingredients>>  
Name  Non-alcoholic beverage  
Ingredients  Apple Juice (Apples (Germany, Hungary)), Fructose -glucose Syrup, 
Fructose/Acidifier, Vitamin C  
Net 500ml  
Expiration date  September 30, 2017  
How to store  Store in a cool dry place away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
 
Name  Non-alcoholic beverage  
Ingredients  Apple Juice (Apples (produced in Germany, produced in Hungary)), 
Fructose -glucose Syrup, Fructose/Acidifier, Vitamin C  
Net 500ml  
Expiration date  September 30, 2017  
How to store  Store in a cool dry place away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
 
  ×  - 28 - 
 <<Example 4: Labeling by tracing back the country of origin for semi -processed ingredients (Labeling by adding 
a category of Country of Origin for Ingredients)>>  
Name  Non-alcoholic beverage  
Ingredients  Apple Juice, Fructose -glucose Syrup, Fructose/Acidifier, Vitamin C  
Country of Origin 
for Ingredients  Germany (Apples), Hungary (Apples)  
Net 500ml  
Expiration date  September 30, 2017  
How to store  Store in a cool dry place away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
 
 
17  What types of processed work are not being considered as “domestically produced” among 
processing work performed domestically for imported semi -processed ingredients?  
 
1  For imported semi -processed ingredients, if there have been any “acts resulting in substantial changes to the 
contents of a product” at another domestic company and in the case where such ingredients are purchased and 
used as semi -processed ingredients, this is conside red as “domestically produced.”  
 
2  A notice “Unjustifiable Labeling on Countries of Origin of Products (Fair Trade Commission Notice No. 34 
of 1973)” published in accordance with the Act against Unjustifiable Premiums and Misleading Representations 
(Premi ums and Representations Act) states that the following acts are not considered as the “acts resulting in 
substantial changes to the contents of a product.”   
① To attach a label or other display onto a product  
② To pack a product in a container or package  
③ To simply assort products or combine them  
④ To assemble simple parts  
In addition, the Directive on Customs Act (Notice of the Customs and Tariff Bureau of Ministry of Finance 
No. 100 of 1972) specifies that the following acts are not considered as acts affecting  the change of countries 
of origin:  
⑤ Simple cutting  
⑥ Drying, freezing, soaking in brine or any other acts equivalent for transportation or preservation  
⑦ Simple mixing  
. 
 - 29 - 
 3  This is the same concept as applied for products being considered as “imported produ cts” or not, which is 
specified in Article 3, Paragraph 2 of the Food Labeling Standards. “Imported products” in this case means:  
① Any product, which is put in the container or package and sold to consumers as is (Products -as-imported)  
② Any products, which are imported in bulk and are subdivided in the container or package in Japan  
③ Any products -as-imported, which are assorted  in Japan  
④ Any other imported products, where there have been no “acts resulting in substantial changes to the 
contents of a product” in Japan  
 
4  Any cases of 2 and 3 above will not be considered as “domestically produced.”  
Even in the case of acts other than those mentioned above, there may be acts such as sterilization, coloring, 
and flavoring, which do not fall into the category of any “acts resulting in substantial changes to the contents of 
a product.” (Specific judgment  should be individually made.)  
 
 
18  Are the “possible suppliers labeling” and “all inclusive labeling, etc .” permitted for the 
production country labeling for semi -processed ingredients?  
 
1  For the purpose of providing information to consumers, the labe ling of supplying countries in descending 
order by weight is required as a general rule for the production country labeling for semi -processed ingredients.  
However, if the labeling of supplying countries in descending order by weight in the case of labeli ng 
production countries proves to be difficult, the “labeling of possible suppliers,” “all inclusive labeling” and the 
combination of these two types of labeling would be permitted under certain conditions.  
The conditions permitted for such labeling are e xactly the same as those for the perishable ingredients 
labeling. (See Sections 5 to 13 above)  
 
2  For the “all inclusive labeling,” the labeling of “foreign produced” and “produced in overseas” is permitted 
but “imports produced” or “produced outside Japa n” is not permitted as they do not clearly describe their 
meaning.  
  - 30 - 
 <<Example 1: “labeling of possible suppliers” for the labeling of production country>>  
Name  Non-alcoholic beverage  
Ingredients  Apple Juice (produced in Germany or domestic ally made), 
Fructose -glucose Syrup, Fructose/Acidifier, Vitamin C  
Net 500ml  
Expiration date  September 30, 2017  
How to store  Store in a cool dry place away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
*Production places  for apple juice and the order are based on the  past records  on ingredients use  in 2015  
 
<<Example 2: “All inclusive labeling” for the labeling of production country>>  
Name  Non-alcoholic beverage  
Ingredients  Apple Juice (produced  overseas), Fructose -glucose Syrup, 
Fructose/Acidifier, Vitamin C  
Net 500ml  
Expiration date  September 30, 2017  
How to store  Store in a cool dry place away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
 
 
19  There are rules provided for labeling methods of ingredients for each item in Appendix 4 in the 
Food Labeling Standards. Following these rules and in the case of labeling the names of 
ingredients classified as perishable food by tracing them back instead o f labeling the names of 
semi -processed ingredients, how shall we label countries of origin for ingredients?  
 
1  Ingredients subject to the mandatory labeling of country of origin for ingredients are the ingredients 
individually specified in Appendix 4 in the Food Labeling Standards and are the most predominant ingredient 
by weight.  
 
2  The labeling methods should b e in accordance with  Appendix  20 or Appended Form 1 in the Food Labeling 
Standards and any of the following will be labeled, as a general rule, by adding an itemized column for the 
country of origin for ingredient.  
① To label the country of origin correspon ding to the name of ingredient, which is labeled based on the - 31 - 
 individual provisions.  
 
<<Example 1: A case of using imported concentrated apple juice>>  
Name  Apple Juice (from concentrate)  
Ingredients  Apples /Flavoring  
Country of Origin 
for Ingredient  Germany, Hungary  
Net 500ml  
Expiration date  July 31, 2017  
How to store  Store in a cool dry place away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
 
② To label the name of ingredient and its country of origin corresponding to the state when it was used as 
the ingredient (when a product was produced).  
In this case, in accordance with the individual provisions, please label all ingredients and their count ries of 
origin specified in the ingredients labeled in the names of ingredients column.  
 
<<Example 2: A case of using concentrated apple juice which is imported and juice which is squeezed at the own 
company>>  
Name  Apple Juice (from concentrate)  
Ingredients  Apples /Flavoring  
Country of Origin 
for Ingredient  Produced in Germany (Apple Juice), Domestic (Apples)  
Net 500ml  
Expiration date  July 31, 2017  
How to store  Store in a cool dry place away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
 
 
3  Without adding an itemized column, the country of origin can be labeled in the ingredients column by 
placing the brackets after the name of the ingredient, which corresponds to the said name of the ingredient.  
In this case, the name of ingredient corresponding to the state, for which the ingredient was used, cannot also 
be labeled as the ingredient (for example, labeling such as “Ingredients: Apples (Apple juice (Produced in - 32 - 
 XX)”).  
 
<<Example 3: A case of using imported concentrated apple juice>>  
Name  Apple Juice (from concentrate)  
Ingredients  Apples (Germany, Hungary) /Flavoring  
Net 500ml  
Expiration date  July 31, 2017  
How to store  Store in a cool dry place away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
  
 
 
20  What are the labeling requirements for processed food products for professional use in relation 
to the country of origin labeling for ingredients?  
 
1  For any products sold to consumers, in order to properly label countries of origin for ingredients, it is 
mandatory to appropriately communicate information on countries of origin for processed food products for 
professional use such as semi -processed ingr edients.  
On the other hand, any matters, which are not related to the labeling of countries of origin for ingredients of 
the final products, have no mandatory labeling requirements.  
 
2  In order to ensure the accuracy of the country of origin labeling fo r ingredients of the final products, the 
following must be labeled:  
① Countries of origin for the processed food product for professional use, if the said processed food 
product for professional use is used in the final product as an ingredient (the most pr edominant 
ingredient by weight in the final product) subject to the mandatory production country labeling  
② Countries of origin for the ingredient (the most predominant ingredient by weight in the processed food 
product for professional use) subject to the mandatory labeling for the country of origin for the ingredient 
in the final product, if the said processed food product for professional use within the processed food 
other than imported products will be a final product by simple cutting or subdivision, e tc., which are not 
considered as "production"  
 
3  Businesses selling any processed food products for professional use must thoroughly check whether their 
food products fall under any of categories ① or ② above or neither of them. Businesses buying any 
processed food products for professional use must be aware that if, for example, any products lacking the - 33 - 
 country of origin labeling for ingredients since they were bought for the purpose of ① above have been sold 
for general consumers at a supermarket for pr ofessional use, this will be a violation of the Food Labeling 
Standards.   
 
4  If there is an agreement between food businesses and the products have the country of origin labeling for 
ingredients by tracing back to perishable foods, the labeling of ① or ② above is not required since this does 
not affect the labeling of countries of origin for ingredients for a final product.  
 
5  Separately from the above, for any processed food products for professional use, which are imported but in 
which there have been  no acts of modifying their natural state after being imported, the country of origin 
labeling for the said processed food products for professional use is required since it is required to label the 
country of origin as an imported product in the final pro duct. (See “Processing - 153, 154 of Q&A of the Food 
Labeling Standards”)  
 
 
21  How do we label <1> the country of origin and <2> the country of origin for ingredients for 
processed food products for professional use?  
 
<1> Country of Origin Labeling  
 
1  Please label (communicate information) the country of origin.  
 
2  In this case, if the “production country labeling for semi -processed ingredients” for processed foods for 
general use is "expected to be labeled as domestically produced," it is required to  have a label "indicating that it 
is domestically produced" as production country information. The labeling of "domestically produced" or 
"made in Japan" can be acceptable in addition to "domestic" so long as it is not misleading to producers, etc. of 
processed foods for general use so that the country of origin is known.  
 
<2> Country of Origin Labeling for Ingredients  
 
1  This is the same labeling method as applied for supplying countries for ingredients of processed food for 
general use. “Indicating that  it is domestically produced” for domestically produced products and a “Country of 
Origin” for imported products, both corresponding to the name of the ingredient, should be labeled 
(communicated the information). In the case of domestically produced produ cts, in addition to the labeling 
noting that they are domestically produced, the following names of places can be labeled.  
① For agricultural products: any names of prefectures or other names of places generally known  - 34 - 
 ② For livestock products: any names of pr efectures or other names of places generally known, where main 
feeding facility is located  
③ For fishery products, any names of waters, landing ports, or names of prefectures or other names of 
places generally known, where the landing port or the main culti vation site is located  
 
2  For imported fishery products, the names of the waters can also be labeled with the name of the country of 
origin.  
 
3  In the case of 2 or more countries of origin, the order by greatest weight in the ingredient should be clearly  
labeled. If the percentages are labeled so that the order by greatest weight is evident, labeling the order by 
greatest weight is not necessarily required.  
 
4  If the said ingredient is a semi -processed ingredient, the labeling of a production country (l abel as “Produced 
in XX”) is required.  
 
5  It is permissible to label as “Others” “Country A or Country B” or “Import” for the country of origin labeling 
for the ingredient in a final product, if such labeling for the specific supplying country is clearly  agreed 
contractually, etc. between the businesses. However, if such labeling is not clearly agreed, this is not permitted 
as the appropriate labeling.  
 
 
22  Where shall we label the country of origin and the country of origin for ingredients for 
processed food products for professional use?  
 
1  Countries of origin and countries of origin for ingredients, when trading processed food products for 
professional use, can be labeled not only on the container or package but also in invoices, delivery sta tements, 
etc., or specifications, etc.  
 
2  In the case of labeling them in specifications, etc., it is necessary to be able to refer that the shipped and 
delivered products are based on which specifications, etc., in the container or package, invoices or delivery 
statements, etc.   
 
3  As noted in the above, it is permitted to specify the mandatory labeling items for processed food products for 
professional use not only on the container or package but also in invoices, delivery statements, etc. or 
specific ations, etc. However, any matters provided in Article 13, Paragraph 1, Item (ii) of the Food Labeling 
Standards are required to label the container or package, thus, these provisions must be followed for labeling.  - 35 - 
  
 
23  What are the labeling requirements for perishable food for professional use in relation to the 
country of origin labeling for ingredients?  
 
1  In order to ensure the accuracy of the country of origin labeling for ingredients within the final products, it is 
required to label countries of or igin for the perishable foods for professional use, if the said perishable food is 
used as an ingredient (the most predominant ingredient by weight), which is subject to the mandatory labeling 
of a country of origin for an ingredient.  
If the perishable fo od for professional use will be used in the final product as an ingredient, whose country of 
origin is not required to be label ed, the above labeling can be omitted.  
 
2  If it is uncertain whether or not the country of origin labeling for ingredients is r equired in a final product, the 
above labeling cannot be omitted.  
 
 
24  How shall we label the country of origin for perishable food for professional use?  
 
1  The country of origin labeling for a perishable food for professional use will be the labeling source for the 
country of origin for the ingredient used for a processed food. Its labeling method is the same as that of the 
country of origin for the ingredient used for a processed food. “Domestically produced” indication is labeled for 
any domestically  produced products and a “Country of Origin” is labeled for any imported products. In the case 
of domestically produced products, in addition to the labeling indicating that they are domestically produced, 
the following names of places can be labeled.  
① For agricultural products: any names of prefectures or other names of places generally known  
② For livestock products: any names of prefectures or other names of places generally known, where main 
feeding facility is located  
③ For fishery products, any names of waters, landing ports, or names of prefectures or other names of 
places generally known, where the landing port or the main cultivation site is located  
 
2  For imported fishery products, the names of the waters can also b e labeled with the country of origin.  
 
3  In the case of 2 or more countries of origin, the order by greatest weight in the ingredient should be clearly 
labeled. If the percentages are labeled so that the order by greatest weight is evident, labeling the o rder by 
greatest weight is not necessarily required.  
 - 36 - 
  
25  Where shall we label the country of origin for perishable food for professional use?  
 
1  Countries of origin, when trading perishable foods for professional use, can be labeled not only on the 
container or package but also in invoices, delivery statements, etc., or specifications, etc.  
 
2  In the case of labeling them in specifications, etc., it is necessary to be able to refer that the shipped and 
delivered products are based on which specificat ions, etc., on the container or package, or in invoices or 
delivery statements, etc.   
 
 
26  “Nori for Rice Balls” is individually subject to the country of origin labeling requirements for 
ingredients. What is the scope of the “Rice  Balls” and how shall w e label the country of origin 
for ingredients?  
 
1  For the purpose of providing information to consumers, “Nori for Rice Balls” is individually subject to the 
country of origin labeling for ingredients. “Rice Balls” in this case includes anything that con sumers generally 
recognize as rice balls such as “products that have already been wrapped with Nori when sold” or “products 
that are sold in the form allowing consumers to wrap Nori by themselves before eating,” which can be found at 
a convenience store, e tc.    
 
2  The following products are not in the scope of the requirements.  
① Products that are packed with “side dishes” such as fried food in a container or package.  
② Rolled products rolling fillings with vinegared rice, which is categorized as sushi.  
 
3  When selling rice balls at a place, where such rice balls are made or processed (so called in -store processed 
foods), such rice balls are outside of the scope of such requirement. This is the same condition as applied to 
other products subject to the count ry of origin labeling for ingredients.  
 
4  For rice balls, the country of origin labeling for ingredients is required for Nori, regardless of the order by 
weight, in addition to the greatest ingredient by weight in the ingredients (the most predominant ing redient by 
weight).  
Labeling supplying countries in descending order by weight is required and the possible suppliers labeling and all 
inclusive labeling are not permitted.  
 
*It is required to label a supplying country for rice for general rice balls, in  accordance with the provisions of - 37 - 
 the Act on Information Records on Transactions, etc. and Relay of Information on Origin of Rice, etc. (Rice 
Traceability Act).  
 
 
27  In the case of voluntary labeling ingredients of products, where the country of origin labeling 
for ingredients is not required, how shall we label them on the container or package?  
 
1  Countries of origin for the greatest ingredient by weight in the ingredients (the most predominant ingredient 
by weight) are only subject to mandatory labeli ng of the country of origin for ingredients for processed food. It 
is, however, desirable to voluntary label countries of origin for the second or third greatest ingredients by 
weight.  
 
2  In the case of the voluntary country of origin labeling for ingred ients, labeling supplying countries in 
descending order by weight is to be followed as a general rule. However, for the purpose of providing as much 
information as possible so providing consumers’ opportunities for autonomous and rational choice of foods, the 
“possible suppliers labeling,” “all inclusive labeling” or “production country labeling for semi -processed 
ingredients” can be utilized under certain conditions, which have been permitted for the mandatory labeling.  
 
3  Even when labeling voluntar ily, if there is any conflict with the laws relating to labeling such as the Food 
Labeling Act, such labeling is subject to supervision and penalties. Please label as clearly as possible based on 
the facts.  
 
 
28  Is it ok to voluntarily provide information regarding the countries of origin for ingredients on 
websites, etc.?  
 
1  It is desirable to voluntarily and proactively provide information to consumers using internet platforms 
regarding detailed information on supplying countries for any ingredients not  being subject to the mandatory 
country of origin labeling for ingredients or when adopted the “possible suppliers labeling,” “all inclusive 
labeling” or “production country labeling for semi -processed ingredients” to the container or package.  
 
2  Even wh en labeling voluntarily, if there is any conflict with the laws relating to labeling such as the 
Premiums and Representations Act, such labeling is subject to supervision and penalties. Please label as clearly 
as possible based on the facts.  
 
 - 38 - 
 29  What ar e the transitional measures applied for the expansion of the country of origin labeling 
for ingredients for all processed foods?  
 
1  There will be a period for transitional measures, which will allow promotion to raise consumer awareness 
and preparation f or switching labeling by businesses.  
 
2  The period for transitional measures will be from the effective date of the Amended Food Labeling Standards 
(MM DD , 2017) until the end of March  2020. Any processed foods for general use produced during this period  
can be labeled in accordance with the provisions set either before or after the Amended Act.  
Any processed foods for professional use with labels under the Food Labeling Standards before the 
amendment cannot be sold after the period for transitional meas ures. Once any of the following arrangement has 
been completed, those foods are allowed to be sold after the period for transitional measures.  
① If labeled on the container or package of the food, the labeling that meets the requirements under the 
Amended Food Labeling Standards is created in the form of a sticker, which is then attached to the 
container or package.  
② If stated in the specifications , etc., those specifications, etc. that meet the requirements under the 
Amended Food Labeling Standards are submitted to the distributor after collecting (or making 
arrangement to dispose of) old specifications, etc.  
(See “Supplementary Provision -4 of the Food Labeling Standards”)  
(The same expiration date as the period for transitional measures set for the Food Labeling Standards, 
which has been enacted in 2015.)   
 
2  The labeling can be switched to the labeling compatible with the new labeling requir ements for the country 
of origin for ingredients after the effective date of the Amended Act, without waiting until April 2020. Please 
plan ahead so that the transition will be completed within the period for transitional measures.  
 
 
 
30  How do you plan to work on public awareness for consumers on the introduction of this new 
country of origin labeling for ingredients?  
 
The system for the country of origin labeling for ingredients for processed food has been significantly 
changed this time. There are som e new labeling methods such as the “possible suppliers labeling” in addition to 
the labeling of “supplying countries in descending order by weight” being as a general rule. It is acknowledged 
that government together with related organizations must coopera te from now on to engage in dissemination 
activities from multiple angles so that consumers have better understanding of such labeling methods.  - 39 - 
 It is expected that the same named products with the country of origin labeling for ingredients as the 
“labelin g of supplying countries in descending order by weight,” “possible suppliers labeling,” “all inclusive 
labeling” and “production country labeling” could possibly be sold through shops.  
It is important to engage in activities to disseminate this new system  to relevant parties so that consumers can 
properly understand the new labeling. It is expected that we, together with relevant organizations, will 
proactively engage in dissemination activities by making brochures and holding information seminars.  
It is expected that businesses will comply with the labeling of “supplying countries in descending order by 
weight” as a general rule. It is also expected that consumers would self -study this new system for the country of 
origin labeling for ingredients for proc essed foods so that consumers themselves can improve their food labeling 
literacy.  
 
(Envisaged Specific Activities)  
○ Create brochures/leaflets for consumers and businesses  
○ Disseminate the intention for the system review through various governmental public relation media  
○ Disseminate and promote public awareness of the new system by sending speakers to various study groups 
hosted by consumer groups, etc.  
○ Promote nation -wide public awareness by sending speakers to seminars requested by prefectural 
governments  
○ Hold training sessions, etc. for prefectural government officials in order to promote public awareness 
activities by local governments  
○ Hold nation -wide information sessions on the Amended Food Labeling Standards in order to disseminate and 
promote public awareness at the national level