*Additional Q&As since the previous notification (Jun 29, 2017 version) are highlighted yellow.   
 
New Country of Origin Label ling 
System for Ingredients  Q&A * 
(excerpted from the Food Labelling Standard 
Q&A ( Notice No.410, September 1, 2017) ) 
 
 
 
 
September, 2017  
Food Labelling Division  
Consumer Affairs Agency  - 1 - 
 Table of Contents  
 
I  Ingredients Subject to Labelling  
Q 1 What types of  processed foods would be subject to the country of origin labelling  for ingredients?  
Q 2 What types of ingredients would be subject to the country of  origin labelling for ingredients ? 
Q 3    Are liquors subject to country of origin labelling for ingredients? If they are, what types of ingredients 
would be subject to country of origin labelling for ingredients?  
Q 4    Are ingredients of so -called “ingredient -name -labelled” foods subject to country of origin labelling for 
ingredients?  
Q 5    Is water also subject to country of origin labelling for ingredients?  
Q 6    Are food additives subject to the country of origin labelling  for ingredients?   
Q 7    Under the provisions of 1- (iii) of the name of ingredients column in the chart in Article 3, Paragraph 1 of 
the Food Labelling Standards, in the case where composite ingredients (ingredients consisting of two or more 
kinds of ingredients) are labelled by separating the ingredients in the space for name of ingredients, since there 
is not such a major change in nature of ingredients in that they are merely being mixed, which the ingredient's 
country of origin should be labelled?  
Q 8    Under the provisions of 1- (iii) of the name of ingredients column in the chart in Article 3, Paragraph 1 of 
the Food Labelling Standards, in the case where composite ingredients (ingredients consisting of two or more kinds of ingredients) are labelled by aggregating multiple ident ical ingredients included in the products after 
separating those in the space for name of ingredients, since there is not such a major change in the nature of the ingredients in that they are merely being mixed, how should the ingredient's country of origi n be 
considered? 
Q 9    Under the provisions of 2- (i) in the name of ingredients column in the chart in Article 3, Paragraph 1 of the 
Food Labelling Standards, in the case where the same types of ingredients are summarized and indicated, such as (“vegetabl es (○○, △△)”), for which ingredients should the country of origin be labelled?  
Q 10   Under the provisions of 2- (i) in the name of ingredients column in the chart in Article 3, Paragraph 1 of the 
Food Labelling Standards, in the case where the same types of ingredients are summarized and labelled, if all of the vegetables are domestic, w hat kind of labelling may be used?  
Q 11    Under the provisions of 2- (ii) in the name of ingredients column in the chart in Article 3, Paragraph 1 of 
the Food Labelling Standards, in the case where multiple processed foods A and B are separated such as by being wrapped individually, and then one product is constituted by combining those, if the ingredients are 
labelled by separating those constituent factor processed food A and B, for which ingredient is country of 
origin labelling obligatory?  
Q 12    Under t he provisions of 3 in the name of ingredients column in the chart in Article 3, Paragraph 1 of the 
Food Labelling Standards, in the case where ingredients are labelled by grouping, such as “Vegetable Oil” or “Starch,” how should the country of origin of ingredients be considered?  
Q 13    Under the provisions of 3 in the name of ingredients column in the chart in Article 3, Paragraph 1 of the 
Food Labelling Standards, in the case where ingredients are labelled by grouping, such as “Fish,” etc., how - 2 - 
 should the  country of origin of ingredients be handled?  
Q 14    If there are two or more predominant ingredients by weight, which ingredients need country of origin 
labelling?  
 
II  Labelling  Methods  
Q 15    Where shall we label country of origin for ingredients?  
Q 16   What is a basic labelling  method used for ingredients classified as perishable food, f or which supplying 
countries  are labelled in descending order by weight?   
Q 17    What is labelling method used for the case where ingredients from multiple countries of origin are mixed?  
Q 18    Allergy labelling or genetic recombination labelling is sometimes included in the column for name of 
ingredients, so is there any priority order for country of origin labelling, allergy labelling or genetic 
recombination labelling?  
Q 19    Is it possible to label country of origin for ingredients other than with name of country?  
Q 20    Is it possible to label country name using “abbreviation,” etc., for country of origin labelling for 
ingredients? Is it possible to label America as USA or US?  
Q 21    Is it possible to label country of origin for ingredients using marks that indicate the country of origin?  
Q 22    For largest ingredient by weight i n the ingredients (the most predominant ingredient by weight), under the 
provisions of Article 7 of the Food Labelling Standards, specific country of origin name and ingredient ratio used are labelled by stressing those, but is the country of origin labell ing necessary separately within the 
collective labelling column?  
Q 23    In the case of labelling the country of origin for ingredients within the collective labelling column, is it 
necessary to write ingredient ratio used as well, under the provisions of A rticle 7 of the Food Labelling 
Standards?  
Q 24   In addition to the most predominant ingredient by weight subject to country of origin labelling, if labelling 
of country of origin name is desired for the fifth most predominant ingredient as an option, is i t possible not to 
label country of origin for the second, third and fourth most predominant ingredients?  
Q 25    In the case where there is one ingredient and labelling of the ingredient name is omitted, how should the 
country of origin be labelled?  
 
III  A nd/Or Labelling  
Q 26   Which case is permitted for the “And/Or L abelling ” (labelling  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 Labelling  Standards)?  
How long can source documents for the And/Or Labelling be used as evidence?  
Q 27  What is a basic labelling  method used for the And/Or L abelling ?   
Q 28    Is “And/Or Labelling” possible to use in country of origin labelling using the name of prefectures?  
Q 29    When the And/Or  Labelling  is conducted based on the past records or  the future plans on ingredients use  
by supplying country  for a defined period of time , how can we list a supplying country , whose ingredient ratio 
used in the specific product is significantly small, to prevent information from misleading  consumers ?  - 3 - 
 Q 30   In the case where ingredients from multiple countries of origin are added to the tank to manufacture 
products, in calculation the ratio of once -used country of origin will never be zero, so how should those be 
labelled?  
 
IV  All Inclusive Labelling  
Q 31    Which case is permitted for the “All Inclusive Labelling”  (labelling  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 Labelling  Standards)?  
How long can source documents for the All Inclusive Labelling  be used as evidence?  
Q 32 What is a basic labelling  method used for the All Inclusive Labelling ?   
Q 33   In All Inclusive Labelling, is labelling in smaller category than “imported,” such as “Produced in EU” 
“Produced in South America” accepted? 
 V  All Inclusive Labelling  + And/Or Labelling  
Q 34    Which case is permitted to use  both All Inclusive Labelling  and And/Or Labelling in combination (“import 
or domestic” or “domestic or import”)  (labelling prescribed in 1- (v)(c) of the processed food other than 
imported food column in the chart in Article 3, Paragraph 2 of the Food Labelling Standards) ? 
Q 35    What is a basic labelling  method used for a case using both All Inclusive Labelling  and And/Or Labelling  
in combination (“import or dome stic” or “domestic or import”)?  
 
VI  Past records on ingredients use , etc.  
Q 36    In the And/Or Labelling and All  Inclusive Labelling + And/Or Labelling, w hat expression is acceptable for 
a warning to indicate that the  labelling  is based on the past records or the future plans on ingredients use  by 
supplying country for a defined period of time ? 
       How long does  the defined period of time  have to be?    
Q 37    What types of documents should be retained for the And/Or Labelling , All Inclusive Labelling , or All 
Inclusive Labelling  + And/Or Labelling?    
Q 38    In the case that labelling is conducted based on the past records or the future plans on ingredients use  by 
supplying country for a certain period of time, what level of legitimacy is required for the past record or the 
usage  plan?      
Q 39     How long should the  source documents  be retained for the And/Or Labelling and All Inclusive Labelling, 
etc.?     
Q 40    When using And/Or Labelling or All Inclusive Labelling, etc., what kind of unit can be used for past 
records or future plans on ingredient use by  supplying country for a defined period of time?  
 
VII  Production Country Labelling  for Semi -Proce ssed Ingredients 
Q 41     What is a labelling method used for the  case that the ingredient subject to  the country of origin labelling is 
semi-processed ingredient ?  
Q 42    How is the production country for semi -processed ingredients determined?  - 4 - 
 Q 43   What are the examples of acts conducted domestically for imported semi -processed ingredients which 
cannot  be considered “domestic production?”  
Q 44    For semi -processed ingredients produced via several production process stages, for which stage should the 
production country be labelled?  
Q 45   In the case where semi -processed ingredients subject to country of  origin labelling are composite 
ingredients and not “Production Country Labelling for Semi -Processed Ingredients,” but where labelling 
should be done by tracing back to country of origin of perishable ingredients, which of the composite 
ingredients should be labelled with the country of origin?  
Q 46   On which step of processing should be labelled for the county of origin about the semi -processed 
ingredient internally produced domestically?                                                                
Q 47    Are the And/Or Labelling  and All Inclusive Labelling , etc. permitted for  the production country labelling  
for semi -processed ingredients?    
Q 48    There are rules provided for labelling  methods of ingredients for each item in Appendix 4 in the Food 
Labelling  Standards. Following these rules and in the case of labelling  the names of ingredients classified as 
perishable food by tracing them back instead of labelling  the names of semi -processed ingredients, how shall 
we label countries of origin for ingredients?    
 
VIII  For Professional Use  
Q 49     What are the labelling  requirements for processed food products for professional use in relation to the 
country of origin labelling  for ingredients?                                     
Q 50  How do we label the country of origin for processed food products for professional use?  
Q 51   How do we label the country of origin for ingredients for processed foo d products for professional use?  
Q 52   Where shall we label the country of origin and the country of origin for ingredients for processed food 
products for professional use?    
Q 53     What are the labelling  requirements for perishable food for professional use in relation to the country of 
origin labelling  for ingredients?                                            
Q 54 How shall we label the country of origin for perishable food for professional use?   
Q 55 Where shall we label the country of origin for perishable food for professional use?  
 IX  Others 
Q 56   For processed food in Appendix 15- 1 to 5 (so -called “22 food groups and 4 items”), can And/Or Labelling, 
All Inclusive Labelling or “Production Country Labelling for Semi -Processed Ingredients” be used?  
Q 57   Among the so- called 22 food groups (processed food in Appendix 15- 1), if there are no perishable foods 
whose weight percentage in ingredients and food additives is 50% or greater, how should such food be 
labelled?  
Q 58   “Nori for Rice Balls” is individually subject to the country of origin labelling  requirements for ingredients. 
What is the scope of the “Rice Balls” and how shall we label the country of origin for ingredients?    
Q 59    In the case of voluntary labelling  ingredients of products, where the country of origin labelling  for - 5 - 
 ingredients is  not required, how shall we label them on the container or package?   
Q 60   Is it acceptable to voluntarily provide information regarding the countries of origin for ingredients on 
websites, etc.?                                                                     
Q 61   How should a sudden change of country of origin for ingredients due to natural disaster or bad crop, etc., 
be handled?  
Q 62    What are the transitional measures applied for the expansion of the country of origin labelling  for 
ingredients for all processed foods?    
Q 63    Is product that is in the process of production at the production place or processing place when the Food 
Labelling Standards are in effect and then completed after the transitional measures period also s ubject to this 
labelling?  
Q 64   How do you plan to work on public awareness for consumers on the introduction of this new country of 
origin labelling  for ingredients?    
  - 6 - 
 I   Ingredients Subject to Labelling  
 
Q 1  What types of processed foods would be subject to the country of origin labelling for 
ingredients?  
 
Answer 
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 labelling  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 labelled  
as imported products. The country of origin labelling  for ingredients is not required.  
 
2  The following cases do not require the country of origin labelling  for ingredients, which is the same procedure 
for labelling  requirements, etc. for ingredients.  
(1)   When setting up a facility to provide food and drinks (eating out)  
(2)   When selling food products at a place, where such products are made or processed (so called in -store 
processing)  
(3)   When assigning to an unspecified or a large number of people ( excluding selling ) 
(4)   When selling food without containers or packages  
 
In addition, when the area on the container or package where labelling could be placed is 30cm2 or less,  
labelling  the country of origin for ingredients can be avoided.  
 
Q 2  What types of ingredients would be subject to the country of origin labelling for ingredients?  
 
Answer 
1   The largest ingredient by weight in the ingredients (the most predominant ingredient by weight) is subject to 
mandatory labelling  (which is referred as “subject ingredient”), and the name of that  ingredient and its country of 
origin are required to be labelled  correspondingly .  
However,  though having considered the feasibility of implementation by businesses  the subject item is limited 
as above, it is desirable to include as many ingre dients as possible for mandatory labelling  with respect to 
providing information to consumers .  
Provided, however, the 22 food groups in Appendix 15 -1 and the following items have separate standards, 
which provide with the ingredients that are subject to m andatory labelling .  
(1)   For pickled agricult ural products, top four (or three ) predominant ingredients, which constitute 5% or more  
(2)   For frozen vegetable products, top three  predominant ingredients, which constitute 5% or more  
(3)   For processed eel products, eel  - 7 - 
 (4)   For dried bonito flakes, dried bonito  
(5)   For rice balls, nori  
 
2  In the case where the country of origin of the most predominant ingredient by weight is labelled  (or the 
information transmitted ) under the following laws, the provisions for the country of origin labelling  for 
ingredients in the Food Labelling  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. (Ric e 
Traceability Act) (Act No. 26 of 2009)  (excluding rice cakes described in the Food Labelling Standard 
Appendix 15- 1, (6))   
(2)   Act Concerning Liquor Business Associations and Measures for securing Revenue from Liquor Tax   (Act 
No. 7 of 1953)  
As of September , 2017, the Production Method and Quality Labelling  Standards for Fruit Alcoholic Beverages, 
etc. (National Tax Agency Notice No. 18 of 2015) have been adopted as labelling  standards under  (2). 
 
Q 3  Are liquors subject to country of origin labelling for ingredients? If they are, what types of 
ingredients would be subject to country of origin labelling for ingredients?  
 
Answer  
1   For liquors, name of ingredient labelling is not obligatory under the Food Labelling Standards, but they are 
subject to country of origin labelling. 
 
2   Specifically, any of the following should be used.  
(1)   Make country of origin column, and corresponding to the largest ingredient by weight in the ingredients 
(the most predominant ingredient by weight), the country of origin should be labelled.  
(2)   If names of ingredients labelled optionally, it is also possible to label the country of origin using bracket 
after the name of the corresponding ingredient without making country of origin column.  
 3   In the case o f 2(2) above, as labelling of name of ingredients is not obligatory for liquors, the order of 
labelling is not necessarily descending order of weight, however, regardless of the order of labelling of ingredients in the column for name of the ingredients, t he country of origin must be labelled for the largest 
ingredient by weight in the ingredients (the most predominant ingredient by weight).  
 4   For sake, rice shochu (single type distillation), mirin and fruit wine, under the labelling standards under Act on 
Information Records on Transactions, etc. and Relay of Information on Origin of Rice, etc. or Article 86- 6, 
paragraph 1 of the Act on Securing of Liquor Tax and Liquor Business Associations, country of origin of 
ingredients is labelled (information tran smission), therefore the provisions on country of origin labelling under 
the Food Labelling Standards are not applicable.  
 - 8 - 
 Q 4  Are ingredients of so -called “ingredient -name -labelled” foods subject to country of origin 
labelling for ingredients?  
 
Answer  
“Ingredient -name -labelling” generally indicates the labelling method for food that uses the name of a specific 
ingredient as the name of the product or a part of the product, and there is no definition under the Food Labelling 
Standards, so ingredient -name -labelling itself is not subject to country of origin labelling.  
However, if the specific ingredient which is used in the product name is the most predominant ingredient by 
weight, it is subject to country of origin labelling. 
 
Q 5  Is water also subject to  country of origin labelling for ingredients?  
 
Answer  
Currently, as water is not labelled in many cases customarily, even if water is labelled at the top of the 
ingredients column, it is not subject to country of origin labelling. Other than water, for the largest ingredient by 
weight in the ingredients (the most predominant ingredient by weight), the country of origin must be labelled. 
 
Q 6  Are food additives subject to the country of origin labelling for ingredients?  
 
Answer  
1  In the Food Labelling  Standards, ingredients and food additives  are explicitly distinguished.  
Only ingredients are subject to the country of origin labelling  for ingredients and  food additives are not 
subject to labelling  requirements.  
 
2  Therefore, in the case that a food additive is the most predominant ingredient by weight in a particular food, 
the said food additive is not required for the country of origin labelling for ingredients . The largest ingredient by 
weight in the ingredients (the most predominant ingredient by weight) is subject to the labelling  requirements.  
Any food consisting of only food additives is not required to have  the country of origin labelling for 
ingredients .  
 
3  Countries of origin for diluents (lactose, flour, starch, etc.), which had originall y been included in those 
additives, are not required to be labelled .  
 
Q 7  Under the provisions of 1- (iii) of the name of ingredients column in the chart in Article 3, 
Paragraph 1 of the Food Labelling Standards, in the case where composite ingredients 
(ingredients consisting of two or more kinds of ingredients) are labelled by s eparating the 
ingredients in the space for name of ingredients, since there is not such a major change in 
nature of ingredients in that they are merely being mixed, which the ingredient's country of - 9 - 
 origin should be labelled?  
 
Answer  
1    When a composite ingredient is used in producing food, a general name for the composite ingredient is used 
for country of origin labelling. 
 
2    However, under the provisions of 1- (iii) in the name of ingredients column in the chart in Article 3, 
Paragraph 1 of the Food Labelling Standards, in the case where there is not such a major change in the nature of 
ingredients in that they are merely being mixed, all the ingredients of the composite ingredients can be 
separated and labelled.  
 
3    In such instance, based on the l abelling of ingredients after separation, for the largest ingredient by weight 
in the ingredients (the most predominant ingredient by weight), the country of origin must be labelled.  
<< Example 1: Method by composite ingredient labelling>>  
Name  Soda pop  
Ingredients  Sugar preparation (produced in Korea (Sugar, Corn 
Starch)), Lemon Juice/Citric Acid, Baking Soda, Flavoring   
Net 10 g 
Expiration date  October 1, 2017  
How to store  Store away from direct sunlight  
Producer  XX Co., Ltd.  
 X-Y-Z Nagata- cho, Chiyoda -ku, Tokyo 
 
Name  Soda pop  
Ingredients  Sugar preparation (Sugar, Corn Starch) (produced in Korea), Lemon Juice/Citric Acid, Baking Soda, Flavoring  
 
Net 10 g 
Expiration date  October 1, 2017  
How to store  Store away from direct sunlight  
Producer  XX Co., Ltd.  
 X-Y-Z Nagata- cho, Chiyoda -ku, Tokyo 
 
<<Example 2: Method of labelling by separation>>  
Name  Soda pop  
Ingredients  Sugar (produced in Korea), Corn Starch, Lemon Juice/Citric 
Acid, Baking Soda, Flavoring   
Net 10 g 
Expiration date  October 1, 2017  - 10 - 
 How to store  Store away from direct sunlight  
Producer  XX Co., Ltd.  
 X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
 
Q 8  Under the provisions of 1- (iii) in the name of ingredients column in the chart in Article 3, 
Paragraph 1 of the Food Labelling Standards, in the case where composite ingredients 
(ingredients consisting of two or more kinds of ingredients) are labelled by aggregating 
multiple identical ingredients included in the products after separating those in the space for 
name of ingredients, since there is not such a major change in the nature of ingredients in that 
they are merely being mixed, how should the ingredient's country of origin be considered?  
 
Answer  
Under the provisions of 1- (iii) of the name of ingredients column in the chart i n Article 3, Paragraph 1 of the 
Food Labelling Standards, in the case where multiple identical ingredients are aggregated and labelled, for the most 
predominant ingredient by weight from looking at the ingredient units labelled after aggregation, country of origin 
must be labelled.  
 
Q 9  Under the provisions of 2 -(i) in the name of ingredients column in the chart in Article 3, 
Paragraph 1 of the Food Labelling Standards, in the case where the same types of ingredients 
are summarized and indicated, (such as “Vegetables (○○ 、△△)”), for which ingredients 
should the country of origin be labelled?  
 
Answer  
1   In the case where the same types of ingredients are summarized and indicated in such a way as “Vegetable (○○ 、
△△),” for easier understanding by consumers or other reasons, for the most predominant ingredient by weight by 
ingredient unit, country of origin labelling is required.  
 
2   Therefore, even if it is labelled as “Vegetables (○○, △△)” at the very top of the name of ingredients column, 
due to summarization, when comparing by units of ingredients used, if the ingredient labelled the second or later in the name of ingredients column is the largest by weight among the ingredients, regardless of the order of 
labelling, the relevant most predominant ingredient by weight should be labelled with the country of origin. 
 Example) When the weight of Vegetable is greater than Pork, but the weight of Pork is greater than Onion, 
Ingredients: Vegetable (Onion, Cabbage, Tomato), Pork (Produced in Country A)  
↑  
obligatory  
  - 11 - 
 Q 10   Under the provisions of 2- (i) in the name of ingredients column in the chart in Article 3, 
Paragraph 1 of the Food Labelling Standards, in the case where the same types of ingredients 
are summarized and  indicated, if all of the vegetables are domestic, what kind of indication 
may be used?  
 
Answer  
Labelling as in the following example may be used. It does not mean that labelling other than in the following 
example is not allowed. It is required to u se labelling that is easy to understand for consumers.  
 
Example s) When the weight of onion is greater than pork,  
Ingredients: Vegetable (Onion (Domestic), Cabbage, Tomato), Pork  
Ingredients: Vegetables (Onion (Domestic), Cabbage (Domestic), Tomato (Domestic)) , Pork  
Ingredients: Vegetables (Domestic (Onion, Cabbage, Tomato)), Pork  
Ingredients: Vegetables (Onion, Cabbage, Tomato) (Domestic), Pork  
Ingredients: Vegetables (Domestic) (Onion, Cabbage, Tomato), Pork  
 
Q 11   Under the provisions of 2- (ii) in the name o f ingredients column in the chart in Article 3, 
Paragraph 1 of the Food Labelling Standards, in the case where multiple processed foods A 
and B are separated such as by being wrapped individually, and then one product is 
constituted by combining those, if the ingredients are labelled by separating those constituent factor processed food A and B, for which ingredient is country of origin labelling obligatory?  
 Answer  
1   Among the most predominant ingredients by weight for constituent factor processed foods  A and B 
respectively, for the most predominant ingredient by weight for the overall product, country of origin labelling is 
required.  
 2   If the same ingredient is labelled multiple times for the product as a whole such as in the case where the same 
ingredient is used for A and B respectively, aggregation is not conducted.  
 
3   As such products,  
(1)   Product for consumption in the form of A and B being added together by cooking, etc.  
(example: noodle with soup)  
(2)   Both are independent and separate consumption 
(example: chocolate and cookies assort)  
etc. can be considered, and in the case like (2) and if the ingredients are labelled for each constituent factor, it is 
desirable to label country of origin for all of the most predominant ingredients by weight for each constituent 
factor.  - 12 - 
  
Example)  A: Chocolate (Cacao Mass 40g, Sugar 25g....)  
↑  
obligatory  
B: Cookie  (Flour 35g, Sugar 25g....)  
↑ 
option 
*1   In aggregate, Sugar will be the most predominant ingredient by weight, however country of origin 
labelling for sugar is not required. 
*2   It is desirable to label production country (country of origin) of Flour in B.  
 
4   However, if food that can be sold individually is made into an assortment as assorted food for seasonal gifts, it 
is necessary to label individual food as constituent factors. For each individual food, the most predominant ingredient by weight must be labelled for country of origin. 
 
Q 12   Under the provisions of 3 in the name of ingredients column in the chart in Article 3, 
Paragraph 1 of the Food Labelling Standards, in the case where ingredients are labelled by 
grouping, such as “Vegetable Oil” or “Starch,” how should the country of origin of 
ingredients be considered?  
 
Answer  
1   In the case where multiple ingredients are labelled by grouping under the relevant provisions, the country of 
origin (production center) should be labelled corresponding to labelling of ingredients that are properly labelled 
(such as “Vegetable oil” or “Starch”)  
 2   In such instance, for the country of origin (production center) of the original multiple ingredients grouped, 
label the ingredients from the largest ingredient by weight in the grouped labelled ingredients (such as “Vegetable oil” or “Starch”) in descending order.  
 
Q 13   Under the prov isions of 3 of the name of ingredients column in the chart in Article 3, 
Paragraph 1 of the Food Labelling Standards, in the case where ingredients are labelled by 
grouping, such as “Fish,” etc., how should the country of origin of ingredients be handled?  
 Answer  
1   Fish jelly product, etc. is manufactured with frozen fish paste and fresh fish as main ingredients. In the case 
where frozen fish paste and fresh fish are used and labelled as “Fish,” etc., labelling method is as follows. 
 
2   In the case of fish jelly product manufactured only with fresh fish  - 13 - 
 <<Example 1: In the case of labelling using a name of country of origin of ingredients column>>  
(When all fish is domestic)  
Name  Fish sausage  
Ingredients  Fish, Starch, Salt …  
Name of country 
of origin  of 
ingredients   Domestic (Fish)  
Net 200 g  
Expiration date  December 31, 2017  
How to store  Store at room temperature away from direct sunlight.  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo  
 
<<Example  2: In the case of labelling together with names of ingredients>>  
(When all fish is domestic)  
Name  Fish sausage  
Ingredients  Fish (Domestic), Starch, Salt …. 
Net 200 g  
Expiration date  December 31, 2017  
How to store  Store at room temperature away from direct sunlight.  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 <<Example 3: When a type of fish is specified>>  
Name  Special type boiled fish paste packed in casing  
Ingredients  Fish (Cod (Domes tic), White Croaker, Lizardfish ), Toppings 
(Cheese), Starch, Salt …  
Net 100 g  
Expiration date  December 31, 2017  
How to store  Store at room temperature away from direct sunlight.  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 <<Example 4: When all of specified fish ingredients are domestic >>  
Name Steamed fish paste  
Ingredients  Fish ((Domestic) (Cod, White Croaker, Lizardfish)), Starch, 
Salt … 
Net 100 g  
Expiration date  December 31, 2017  
How to store  Store at room temperature away from direct sunlight.  - 14 - 
 Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 
3   In the case of fish jelly product, etc. manufactured only from frozen fish paste  
<<Example 5: When production center of fish paste is labelled>>  
(In the case where fish paste produced in three or more foreign countries, for which the order of 
predominant ingredients by weight is changed in a certain period, is greater than domestically -produced 
fish paste)  
Name  Fish sausage  
Ingredients  Fish, Starch, Salt …  
Name of country 
of origin of 
ingredients  Foreign Produced, Domestically Produced (Fish Paste)  
Net 200 g  
Expiration date  December 31, 2017  
How to store  Store at room temperature away from direct sunlight.  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 
<< Example 6: When production center of fresh fish used for fish paste is labelled>>  
(In the case where fish paste produced in three or more foreign countries, for which the order of 
predominant ingredients by weight is changed in a certain period, is greater than 
domestically -produced fish paste)  
Name  Fish sausage  
Ingredients  Fish (Import, Domestic), Starch, Salt …  
Net 200 g  
Expiration date  December 31, 2017  
How to store   Store at room temperature away from direct sunlight.  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo  
 
<<Example  7: When ingredient is labelled not “Fish” but “Fish Paste”>>  
(In the case of fish paste produced in three or more foreign countries for which the order of predominant ingredients by weight is used)  
Name Fish sausage  
Ingredients  Fish Paste (Foreign Produced), Starch, Salt …  
Net 200 g  
Expiration date  December 31, 2017  
How to store  Store at room temperature away from direct sunlight.  
Producer  XX Co., Ltd.  - 15 - 
  X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo  
 
<< Example 8: When production center of fresh fish used for fish paste is labelled>>  
(In the case of Example 7, and when production center tracing back to fresh fish is labelled)  
Name Fish sausage  
Ingredients  Fish Paste (Fish (Import)), Starch, Salt …  
Net 200 g  
Expiration date  December 31, 2017  
How to store  Store at room temperature away from direct sunlight.  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 4   In the case of fish jelly product, etc. manufactured by mixing f rozen fish paste and fresh fish  
<< Example 9: When production center of fish paste and fresh fish are labelled>>  
(In the case where fish paste produced in America is more predominant ingredient than domestic fresh 
fish) 
Name  Fish sausage  
Ingredients  Fish, Starch, Salt …  
Name of 
country of 
origin of 
ingredients  Produced in America (Fish Paste), Domestic (Cod)  
Net 200 g  
Expiration date  December 31, 2017  
How to store  Store at room temperature away from direct sunlight.  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 
<< Example 10: In the case where production center is labelled tracing back to fresh fish >>  
(In the case of example 9 and production center is labelled tracing back to fresh fish)  
Name  Fish sausage  
Ingredients  Fish (America, Japan), Starch, Salt …  
Net 200 g 
Expiration date  December 31, 2017  
How to store  Store at room temperature away from direct sunlight.  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo  
 
Q 14   If there are two or more predominant ingredients by weight, which ingredients need 
country of origin labelling?  
 - 16 - 
 Answer  
It is necessary to label country of origin for all ingredients that are predominant by weight. 
 
II   Labelling Methods  
 
Q 15   Where shall we label country of origin for ingredients?  
 
Answer  
For general processed food, the country of origin must be labelled either by making a column for name of the 
country of origin of ingredients in bulk in package or container in accordance with Appended Form 1 in the Food 
Labelling Standards, or in a manner likewise easy to unde rstand, and then labelling the country of origin 
corresponding to the name of the ingredients, or by placing brackets corresponding to the name of the labelled ingredients in the column for the name of ingredients, and labelling the country of origin. 
 
Q 16   What is a basic labelling method used for ingredients classified as perishable food, for 
which supplying countries are labelled in descending order by weight?  
 
Answer  
1  Any ingredients domestically produced are to be labelled as domestically produced and any imported 
ingredients  are to be labelled  of the  “countries of origin.”   
 
2  In the case of ingredients being domestically produced, in addition to indicating that they are domestically 
produced  (domestic product , Japan, made in Japan, etc.)  the following labelling  is accepted.  
 
(1) If the ingredients are agricultural products:  
Any names of prefectures or other names of places generally known can be labelled . The labelling  of 
“domestic” is a general rule for the country of origin labelling  for ingredients. If a name of a place is an area 
that is more restricted than “domestic,” it can be labelled .   
For example, the name of a region that is wider than a prefecture (such as “Made in Kyushu” and “Made  in 
Kanto”) can be used 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, where  main feeding facility is located, 
can be labelled .   
(3) If ingredient s are 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, can be labelled .  
 
3  If ingredients are imported fishery products , the name of the waters can also be labelled  with the country of - 17 - 
 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 labelled  as “France,” this may  mislead consumers 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 labelled . For example, “Ingredients: Patagonian Toothfish (France (Indian Ocean)).  
However, it 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 labelling  examples.  
<<Example 1: Labelling 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 (pork)  
Net 150 g  
Expiration date  December 31, 2017  
How to store  Store at 10ºC or below  
Producer  XX Co., Ltd.  
X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 <<Example 2: Labelling  in brackets in the ingredients column (Remarks 3: Appended Form 1 in the Food 
Labelling Standards)> > 
Name Pork sausage (wiener)  
Ingredients  Pork (Canada ), 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 December 31, 2017  
How to store  Store at 10ºC or below  
Producer  XX Co., Ltd.  
X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 
 
  - 18 - 
 <<Example 3: If labelling  in the collective labelling  column is not possible, the labelling can be additionally 
shown somewhere else describing where it is >> 
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  December  31, 2017  
How to store  Store at 10ºC or below  
Producer  XX Co., Ltd.  
X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 
<<Inappropriate Labelling 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 origin since labelling  only the country of 
origin in the country of origin column may confuse 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  
Net 150 g  
Expiration date  December  31, 2017  
How to store  Store at 10ºC or below  
Producer  XX Co., Ltd.  
X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 
Q 17   What is labelling method used for the case where ingredients from multiple countries of 
origin are mixed?  
 
Answer  
1   When ingredients from two or more countries are mixed, the country of origin must be labelled in descending Product Name 
XX sausage  
 
Country of Origin of 
Pork  
Canada  
 
inappropriate  - 19 - 
 order from the heaviest ingredient by weight in the ingredients. 
<<Example 1: The country of origin is labelled in descending order from the heaviest ingredient by weight 
in the ingredients>>  
Name Pork sausage (wiener)  
Ingredients  Pork (Canada, America), 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  December 31, 2017  
How to store  Store at 10 deg. C or below  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo  
 
2   When mixing ingredients from three or more countries, the major ingredients can also be labeled by weight in 
the ingredients for two or more countries, and then the other country of origin can be labelled as  “Other.”  
<<Example 2: When there are three or more countries of origin and all are labelled>>  
Name Pork sausage (wiener)  
Ingredients  Pork (Canada, America, Denmark, Japan), 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 December 31, 2017  
How to store  Store at 10 deg. C or below  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 
<<Example 3: When two or more countries of origin are labelled and others are labelled “Other”>>  
Name  Pork sausage (wiener)  
Ingredients  Pork (Canada, America, 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  December 31, 2017  
How to store  Store at 10 deg. C or below  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 
3   When domestic ingredients and foreign ingredients are mixed as well, calculation is done in country units. In - 20 - 
 other words, when ingredients of three or more countries are mixed and then two or more countries are labelled, 
other countries of ori gin may be labelled as “Other.”  
<<Example 4: When ingredients from Kagoshima Prefecture (50%), and Miyazaki Prefecture (30%) are mixed with ingredients of Canada (20%) and used >>  
 
 
Name Pork sausage (wiener)  
Ingredients  Pork (Domestic (Kagoshima Pref., Miyazaki Pref.), 
Canada), 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  December 31, 2017  
How to store  Store at 10 deg. C or below  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 
Name  Pork sausage (wiener)  
Ingredients  Pork (Kagoshima Pref., Miyazaki Pref., Canada), 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  December 31, 2017  
How to store  Store at 10 deg. C or below  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 
 
  Name Pork sausage (wiener)  
Ingredients  Pork (Domestic, Canada), Lard, Hydrolyzed Protein 
(contains Soybeans, Pork, Gelatin), Reducing Sugar 
Syrup, Salt, Spice (contains Soybeans)/Seasoning (Amino 
Acid, etc.), Phosphoric Salt (N a, K), …  
Net 150 g  
Expiration date  December 31, 2017  
How to store  Store at 10 deg. C or below  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
appropriate  
appropriate  
appropriate  - 21 - 
 <<Inappropriate Labelling Example>>  
* Even if ingredients from Kagoshima Prefecture, Miyazaki Prefecture, Canada and America are mixed 
and used, labelling “Kagoshima Pref., Miyazaki Pref., Other” is not acceptable as only one country 
(Japan) is labelled from the viewpoint of country units.  
Name Pork sausage (wiener)  
Ingredients  Pork (Kagoshima Pref., Miyazaki Pref., Other), 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  December 31, 2017  
How to store  Store at 10 deg. C or below  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo  
 
Q 18   Allergy labelling or genetic recombination labelling is sometimes included in the column 
for name of ingredients, so is there any priority order for country of origin labelling, allergy 
labelling or genetic recombination labelling?  
 
Answer  
1   In Food Labelling Standards, there is no special provision about order of country of origin labelling, allergy 
labelling or genetic recombination labelling, however, we consider that allergy labelling that prevents occurrence 
of health hazards for consumer s who have specific food allergies should be labelled first, with priority over other 
labelling.    
Moreover, it is desirable to increase visibility of labelling relating to specific ingredients, etc. subject to allergy 
labelling, so that consumers who hav e specific allergies can judge properly.  
 
2   Specific example of labelling is as follows. ( xx is allergy labelling, xx is genetic recombination labelling, xx is 
the country of origin labelling)  
<<Example 1: When the country of origin is labelled for tofu salad>>  
Name Tofu Salad 
Ingredients  Tofu ( contains soybeans : non-genetic recombinant ) 
(Domestically Produced ), Lettuce, Tomato, Cucumber, ...  
Net 300 g  
Expiration date  December 31, 2017  
How to store  Store at 10 deg. C or below  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 
 
inappropriate  - 22 - 
 << Example 2: When the country of origin is labelled for tsukudani>>  
Name Tsukudani  
Ingredients  Soy Sauce ( contains Soybeans, Wheat , Domestically 
Produced ), Sea Cabbage, Vegetable Fat and Oil, Red 
Pepper, Sugars (Sugar, Malt Syrup), ...  
Net 100 g  
Expiration date  December 31, 2017  
How to store  Store at 10 deg. C or below  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 
<< Example 3: When the country of origin is labelled for macaroni salad>>  
Name Macaroni Salad  
Ingredients  Macaroni ( produced in Italy ), Mayonnaise, Cucumber, 
Carrot, Onion …. ( partially contains Wheat, Dairy Product, 
Egg, Soybeans ) 
Net 100 g  
Expiration date  December 31, 2017  
How to store  Store at 10 deg. C or below  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 << Example 4: When the country of origin is labelled for corn snack>>  
Name Corn snack  
Ingredients  Corn Grits (Corn ( America , genetic recombination not 
separated )), Sugar, Salt/Emulsifier, Calcium Carbonate …  
Net 300 g  
Expiration date  December 31, 2017  
How to store  Store at 10 deg. C or below  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 
Q 19   Is it possible to label country of origin for ingredients other than with name of country?  
 
Answer  
1   For domestic products, in place of labelling as domestically produced, the name of prefecture or other 
widely -known place name may be used for labelling as a more -limited and specific area.  
Specifically,  
(1) Name of county (e.g., Chichibu County)  
(2) Name of island (e.g., Yakushima Island)  - 23 - 
 (3) Widely known historic name of region (e.g., Tamba, Tosa, etc.)  
(4) Another widely -known historic name of region (e.g., Shinshu, Koshu, etc.)  
(5) Other widely -known place name (e.g., Kyushu, Kanto, Boso (region name))), etc. can be considered.  
In addition, in the case of fishery products, name of waters or landing ports can be labelled. 
 
2   In the case of imported products, as it is prescribed that the “country of origin” must be labelled, therefore 
except for the case where “All Inclusive Labelling” is permitted (see Q&A 31), other labelling cannot be used. 
The area name can be stated together with the name of the country of origin.  
In addition, in the case of imported fishery products, the name of the waters together with the country of origin 
can be added.  
 
Q 20   Is it possible to label country name using “abbreviation,” etc., for country of origin 
labelling for ingredients? Is it possible to label America as USA or US?  
 
Answer  
1   As food labelling is for the purpose of provision of information contributing to choice of products by 
consumers, labelling must be conducted accurately in Japanese, using easily understandable terms.  
 
2   Therefore, to label “produced in America” as USA or US is not permitted as a general rule. (except for in the 
case of Q21 or Q33).  
 
[Examples of permitted labels for country of origin labelling]  
America, United States of America, Australia, China, People’s Republic of China  
 
Q 21  Is it possible to label country of origin for ingredients using marks that indicate the country 
of origin?  
 
Answer  
1   Country of origin labelling with marks can be done in a way that is easy to understand for consumers, to 
prevent misunderstanding, by s uch methods as labelling  outside the collective labelling column upon specifying:  
(1) ingredients for country of origin labelling ,  
(2) the fact of labelling, with a mark,  
(3) and the labelling location with a mark  
in the country of origin column inside the collective labelling column, after labelling mark and country of origin 
corresponding to the relevant mark on container or package. 
 
2   In such instance, for marks, the “3- letter country name codes,” etc. in “Country Name Code” under JIS X 
0304:2011 ( ISO 3166- 1:2006) could be cons idered.  - 24 - 
 <<Example: Labelling with mark>>  
Name Wiener sausage 
Ingredients  Pork, Lard, Hydrolyzed Protein (contains Soybeans, Pork, 
Gelatin), Reducing Sugar Syrup, Salt, Spice (contains 
Soybeans)/Seasoning (Amino Acid, etc.), Phosphoric Salt 
(Na, K) …  
 
Name of 
country of 
origin of 
ingredients  Production center of Pork is stated at the right of expiration 
date at the bottom of the container, using the mark shown 
under this collective labelling column.  
Solid content  150 g  
Expiration date  Stated at the bottom of container  
How to store  Store away from direct sunlight  
Producer  XX Co., Ltd.  
 X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 
(Outside the column, lower part)  
 
(bottom of container)  
20191231/JPN  
 
Q 22   For largest ingredient by weight in the ingredients (the most predominant ingredient by 
weight), under the provisions of Article 7 of the Food Labelling Standards, specific country of 
origin name and ingredient ratio used are labelled b y stressing those, but is the country of 
origin labelling necessary separately within the collective labelling column?  
 Answer  
Even in the case where country of origin is stressed and indicated outside the collective labelling column, for 
country of origin labelling, it is necessary to indicate in the column of country of origin inside collective labelling 
or next to the name of t he corresponding ingredients using brackets in accordance with the labelling method.  
When it is difficult to indicate country of origin inside collective labelling, label can be another place, if the 
place for labelling is indicated in the country of origin column. 
 
Q 23   In the case of labelling the country of origin for ingredients within the collective labelling 
column, is it necessary to write ingredient ratio used as well, under the provisions of Article 7 
of the Food Labelling Standards?  
 JPN: Japan  
USA: America  
CAN: Canada  - 25 - 
 Name…  
Ingredients xx (Domestic), yy, (70% 
Domestic used)  Name…  
Ingredients xx (Domestic) yy,  
(Domestic used)  Answer  
1   In the case of country of origin labelling under the provisions of the chart in Article 3, Paragraph 2 of the Food 
Labelling Standards (in other words, by the method of labelling shown in Q16 and afterward), including the case 
where the second largest ing redient by weight and below is labelled optionally, labelling of percentage of use is 
not necessary.  
 
2   In the case of labelling  only the name of production center that is desired to be stressed optionally inside 
collective labelling, or in the case of emphasizing the label of a specific production center outside collective labelling, due to applicability of labelling  on use of spe cific ingredients under Article 7 of the Food Labelling 
Standards, it is necessary to label the percentage in a place nearby the relevant emphatic label or with the name of the ingredient in collective labelling. However, if the percentage is 100%, the labelling of the percentage may be 
omitted.  
 
<<Example: When, for ingredient XX, a domestic ingredient makes 70%, ingredients produced in Canada 
account for 20%, and ingredients in America account for 10%>>  
 
(1)   Under the provisions of Article 3, labelling for all production centers of ingredients = outside the 
application of Article 7  
(In common with ingredients for which labelling  is obligatory, and ingredients not subject to labelling)  
 
 
(2)   In addition to ingredients for which labelling inside collective labelling is obligatory, where only the 
country of origin of a specific ingredient is optionally emphasized = Article 7 is applicable.  
(In the case of ingredients for which labelling is not obligatory)  
 
 
 
  In the case of labelling only the country 
of origin of ingredients for emphasis, 
Article 7 is applicable and percentage 
labelling is required .  
f all countries of origin are 
labelled, Article 7 i s not 
applicable  
Name…  
Ingredients  Xx (Japan, Canada, America), 
yy (Australia, Denmark)  
inappropriate  
appropriate  
appropriate  - 26 - 
 Domestically -produced xx is used  
Name…  
Ingredient xx (Domestic, Canada, America) …70% Domestic used  Name…  
Ingredient xx (Domestic, Canada, America) …(3)  Outside collective labelling, country of origin of specific ingredient is emphasized = Article 7 is 
applicable.  
(In common with ingredients for which labelling  is obligatory, and ingredients not subject to labelling)  
[Emphasis on labelling part]             [Collective labelling column]   
 
 
Q 24   In addition to the most predominant ingredient by weight subject to country of origin 
labelling, if labelling of country of origin name is desired for the fifth most predominant 
ingredient as an option, is it possible not to label country of origin for the second, third and 
fourth most predominant ingredients?  
 Answer  
In the case of labelling the country of origin optionally for ingredients other than the most predominant 
ingredient by weight, for consumers not to misunderstand that relevant country of origin labelling is for the 
ingredients between the most predominant one and the specified one (in the case of this question, the second, thir d 
and fourth most predominant ingredients), we consider it more desirable to have country of origin labelling for those ingredients as well, however, if the labelling is done in the proper position, there is no problem with labelling 
only the specific ingr edient (in the case of this question, only for the fifth most predominant ingredient). 
 
Q 25   In the case where there is one ingredient and labelling of the ingredient name is omitted, 
how should the country of origin be labelled?  
 
Answer  
It is necessary to label the country of origin corresponding to the name of ingredient.  
Specifically, please label the country of origin corresponding to the name of the ingredient by such means as 
creating a country of origin name column and labelling the names of ingre dients by adding brackets after the name 
of the country of origin, etc. 
In addition, it is also possible to label the country of origin without creating a country of origin name column, Name…  
Ingredient xx (70% Domestic, Canada, America) …
In the case of emphasized labelling outside 
collective labelling, Article 7 is applicable.  
appropriate  
inappropriate  - 27 - 
 but by adding brackets after the names of ingredients in the ingredient name column. 
<<Example 1: When ingredient name column is omitted>>  
Name Flour  
Name of country of origin 
of ingredients  Domestic (wheat)  
Net 1kg 
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 
 <<Example 2: When ingredient name column is not omitted>>  
Name  Flour  
Ingredients  Wheat (domestic)  
Net 1kg 
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  
 
III   And/Or Labelling   
 
Q 26  Which case is permitted for the “And/Or Labelling” (labelling 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 Labelling Standards)?  
How long can source documents for the And/Or Labelling be used as evidence?  
 
Answer  
1   And/Or Labelling is a method listing potential supplying countries as countries of origin of  ingredients in 
descending order by weight based on the past records or the future plans on ingredients use for a defined period of 
time in the past or in the future , whose country names will be connected with “or.”  
 
2   For the purpose of providing information to consumers, the labelling of supplying countries in descending 
order by weight is a general rule. The And/Or Labelling is, however, permitted only if the order by weight and supplying countries of a product are expected to be changed within a  year from the labelling (date of production) 
and it is going to be difficult to label supplying countries in descending order by weight based on the supplying countries in descending order by weight in the past records over a defined period of time (or ba sed on the 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).  
In addition to the above, retention of the following documents is a required condition.  - 28 - 
 (1)   Documents indicating the following periods are from when to when (defined by a business operator) .  
(i)   One year period (such as year of production and fiscal year of production) in which a product is labelled 
(date of  production)   
(ii)   A defined period of time for the past records on ingredients use by supplying country or a defined period 
of time in the future for usage plans by supplying country (referred as a “defined period of time in the past 
or in the future ” hereafter)  
(2)   Documents indicating that the changes of the order of supplying countries by weight and t he changes of 
supplying countries over a defined period of time in the past or in the future .  
(3)   Documents indicating the calculation units (per one product, common unit for controlling ingr edients, etc.) 
used in the past records on ingredients use by supplying country over a defined period of time in the past.  
(4)   Documents indicating the order of the ingredient ratio by country of origin over a defined per iod of time in 
the past or in the future .  
 
3   The past records on ingredients use by supplying country  over a defined period of time  must cover at least a 
period of one year within three years prior to the year (year of production, fiscal year of production, etc.) in which 
a product is labelled (date of production). (See Example 1). 
 
4   As a general rule, the And/Or Labelling is based on the past records on ingredients use by supplying country 
over a defined period of time. In the cases of a new product or of the change of the supplying countries for the ingredients being very likely, where the past records on ingredients use by supply ing country cannot be used, the  
And/Or Labelling should be used based on the future usage plans for ingredients by supplying country over a 
defined period of time.  
The future usage plan over a defined period of time by supplying country must be a plan set one year or less 
from the scheduled start date of production based on the said plan. The And/Or Labelling based on the said plan is 
not permitted for a product made outside the planning period (See Example 2). 
 5   The And/Or Labelling is one of the except ions. Even if a supplying country is expected to be changed, if it is 
not considered difficult 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 easi ly changed, the And/Or Labelling is 
not applicable.  
 
6   Site inspections to businesses by government or local government will confirm whether or not the labelling  is 
properly implemented for the country of origin labelling  for ingredients. Interviews will be conducted to check the 
reasons for the And/Or Labelling , etc. Source documents, which should be retained as a required condition, are 
also inspected.  
 
 
 - 29 - 
 (Example 1: Concept of “ the past records on ingredients use,” which can be used as evidence for And/Or 
Labelling)  
2013 2014 2015 2016 2017  
Production 
Year 2018 
 
 
 
 
 
 
 
 
 
 
 
  
 
(Example 2: Labelling using Usage Plans)  
2016 2017 2018 2019 
  
 
 
 
           Tracing back 3 years  
2–3 years ago  
V oluntary 1 year  3 years ago  Concept of evidence of 
the past records on 
ingredients use  for a 
period exceeding one  year 
Planning Period  
And/Or Labelling permitted 
for any products produced 
during this period  
Starting from the 
middle of the year  Starting from the 
beginning  of the year  1–2 years ago  
V oluntary 1 and a half years  
2 years ago  
1 year ago  
Planning Period  Concept of evidence of 
the past records on 
ingredients use  for a 
period of one  year 
And/Or Labelling permitted 
for any products produced 
during thi s period  - 30 - 
 Q 27  What is a basic labelling method used for the And/Or Labelling?  
 
Answer  
1   The  And/Or Labelling  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)   It means the following four  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 labelling means the use of the ingredient can only be supplied from within the scope of labelled 
countries. It is not permitted to use an ingredient whose supplying country is not labelled. Therefore, if the actual product includes an ingredient supplied by Country C, the labelling of “Country A or C ountry 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 labelling can only  be the order based on the past records on ingredients use for periods 
illustrated in Q 26 of this Q&A. For example, if it is considered difficult to label supplying countries in 
descending order by weight based on the future usage plan on ingredients use, the order of countries should be 
listed based on the most similar past records on ingredients to the situation of the future usage plans  
 
2   If there are three or more countries of origin for an ingredient, the third country and beyond can be labelled  
as “others,” which is the same procedure for labelling  supplying countries in descending order by weight.  
For example, if labelling  “Country A or Country B or Others,” this indicates that there are 3 or 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   In order to avoid misleading consumers, it is always required to inc lude a warning to indicate that such 
labelling is based on the past records on ingredients use on the container or package, together with the country of origin labelling. (See Q 36 of this Q&A)  
<<Example 1: A case of two  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 December 31, 2017  - 31 - 
 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  
 
<<Example 2: A case of two  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  December  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 three supplying countries>>  
Name Pork sausage (wiener)  
Ingredients  Pork (Canada or USA or  Denmark), 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  December 31, 2017  
How to store  Store at 10ºC or below  
Producer  XX Co., Ltd.  
X-Y-Z Nagata- cho, Chiyoda -ku, Tokyo  
*Countries of origin for pork and the order are based on the past records on ingredients use of last year  
 
<<Example 4: A cas e of three 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.) , - 32 - 
 Phosphoric Salt (Na, K), ...  
Net 150 g  
Expiration date  December 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  
 
Q 28   “Is And/Or Labelling” possible to use  in country of origin labelling using name of 
prefectures?  
 
Answer  
1   In the case where the ingredients are solely domestic, And/Or Labelling using prefectural name, etc., such as 
“X Pref. or Y Pref” may be used. About conditions for permitting And/Or Labelling, concept of country unit in 
Q26 and Q27 is applicable.       
 2   However, when Country A -produced ingredients and domestic ingredients are used together, and use volume 
of Country A -produced ingredients is always greater than the domestic ingredients, and besides it cannot be 
judged that labelling  by country in descending order of weight is difficult, And/Or Labelling such as “Country A 
or X Pref. or Y Pref.” cannot be used based on the fact that the order by weight for X Pref. and Y Pref. changes for domestic ingredients.  
Labelling as “Country A, Domestic (Pref. X or Pref. Y)” is possible. However, in such instance, a warning to 
the effect that the labelling is based on past records or future plans for ingredient use by the production center for 
a defined period of time, and storage of source documents in which are des cribed the past records or the future 
plans for ingredients use by production center for a defined period of time for ingredients for each prefecture is 
required.  
 
Q 29   When the And/Or Labelling is conducted based on the pas t records or the future plans on  
ingredients use by supplying country for a defined period of time, how can we list a supplying 
country, whose ingredient ratio used in the specific product is significantly small, to prevent information from misleading consumers?  
    
Answer  
1   The And/Or Labelling is conducted based on the past records or the future plans on ingredients use by 
supplying country for a defined period of time . It is, thus, necessary to prevent consumers from any - 33 - 
 misunderstanding, in the case of the ingredient ratio use d in the specific product being significantly small.  
For that purpose when obtaining an ingredient ratio based on the past records or the future plans on ingredients 
use, it is mandatory to label as follows 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)   I t is required to label “less than 5%” by adding the brackets after the country of or igin for any country of 
origin, whose usage percentage per  past records on ingredients use  is less than 5%  , which is applied to the 
And/Or Label ling used in the All Inclusive Labelling + And/Or Labelling,  and “production country labelling 
for semi -processed ingredients.”   
(3)   A warning is required to be shown that the percentage composition is based on the past records or the future 
plans on ingredients use by supplying country for a defined period of time . 
<<Example: A case of And/Or Labelling 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  March 30, 2018  
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 records on ingredients use in 
2015  
 
2   In addition,  
(1)   Regarding to the All Inclusive Labelling (such as “import”) in the All Inclusive Labelling + And/Or 
Labelling, it is mandatory to label “less than 5%” when the total ratio of bundled ingr edients  is less than 5%.   
(2)   The “less than 5%” labelling is not required for the “others” in the And/Or Labelling. (3)   The “less than 5%” description is not necessary  to the  label of  countries of origin of ingredients in 
descending order by weight . 
 
Q 30  In the case where ingredients from multiple countries of origin are added to the tank to 
manufacture products, in calculation the ratio of once -used country of origin will never be zero, so 
how should those be labelled?  
 
Answer  
1   For example, in the ca se of manufacturing products by adding a new ingredient to products manufactured in 
the past such as “mother“ for vinegar, it is thought that in some cases the ingredients of the country of origin used - 34 - 
 in the past will never be calculated to be zero.  
 
2   As it is considered that there is no great need to continue labelling the country of origin because it will not be 
zero in calculation, as in the example in 1, labelling of the relevant country of origin can be omitted as of the time when the percentage of  the ingredient becomes “less than 5%.”  
It must be noted that, for the country of origin for which the ingredient percentage comes to less than 5% at 
one time, if ingredients from the same country of origin are added again and then the aggregate total perc entage 
becomes 5% or greater, labelling may not be omitted.  
 
IV   All Inclusive Labelling  
 
Q 31  Which case is permitted for the “ All Inclusive Labelling ” (labelling 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 Labelling Standards)?  
How long can source documents for the All Inclusive Labelling be used as evidence?  
  
 Answer   
1   The All Inclusive Labelling is a labelling method for bundling foreign supplying countries together in a 
category classed as “import.” 
 
2   For the purpose of providing information to consumers, the labelling  of supplying countries in descending 
order by weight is a general rule. The All Inclusive Labelling  is, however, permitted only if the order by weight 
and supplying countries of a product are expected to be changed for the labelling  of the ingredient originating 
from three or more foreign countries within a year  from the labelling  (date of production) and it is going to be 
difficult to list supplying countrie s in descending order by weight based on the  supplying countries i n 
descending order by weight in the past records over a defined period of time ( or based on the 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) .  
In addition to the above, retention of the following documents  is required.   
(1)   Documents indicating the following periods are from when to when (defined by a business operator).  
(i)   One year period (such as year of production and fiscal year of production) in which a product is labelled 
(date of  production)  
(ii)   A defined period of time in the past or in the future   
(2)   Documents indicating that the changes of the order of supplying countries by weight and t he changes of 
supplying countries over a defined period of time in the past or in the future .  
(3)   Documents indicating the calculation units (per one product, common unit for controlling ingredients, etc.) 
used in the past records on ingredients use by supplying country over a defined period of time in the past.  
 - 35 - 
 3   The past records on ingredients use by supplying country over a defined period of time must cover at least a 
period of one year within three years prior to the year (year of production, fisc al year of production, etc.) in which 
a product is labelled (date of production). (See Example 1). 
 
4   As a general rule, the  All Inclusive Labelling is based on the past records on ingredients use by supplying 
country over a defined period of time. In the cases of a new product or of the change of the supplying countries for 
the ingredients being very likely, where the past records on ingredients use by supplying country cannot be used, 
the All Inclusive Labelling should be used based on the future usage plans for ingredients by supplying country 
over a defined period of time. 
The future usage plan over a defined period of time by supplying country must be a plan set one year or less 
from the scheduled start date of production based on the said plan. The A ll Inclusive Labelling based on the said 
plan is not permitted for a product made outside the planning period (See Example 2). 
 
5   The All Inclusive Labelling  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 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 labelling  is not 
applicable.   
 
6   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 assumed 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 difficult to list the names of supplying countries in descending order by weight, in 
the case where ingredients are intentionally procured from s everal countries only for a short period of time in 
order to switch or combine countries of origin only for the purpose of the All Inclusive Labelling  even though the 
procurement circumstances for the ingredients allow listing of the names of supplying countries in descending order. (See Example 3)  
 
7   Site inspections to businesses by government or local government will confirm whether or not the labelling  is 
properly implemented for the country of origin labelling  for ingredients. Interviews will be c onducted to check 
the reasons for the All Inclusive Labelling , etc. Source documents, which should be retained as a required 
condition, are also inspected.  
  
 
 
 - 36 - 
 (Example 1: Concept of “ the past records on ingredients use,” which can be used as evidence of All 
Inclusive Labelling)  
2013 2014 2015 2016 2017  
Produc tion 
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 one  year 
Concept of evidence of 
the past records on 
ingredients use  for a 
period of one  year - 37 - 
  
(Example 2: Labelling using Usage Plans)  
2016 2017 2018 2019 
  
 
 
 
 
 
 
 
   
  
 
 (Example 3)  
Jan Feb Mar Apr May June July Aug Sep Oct Nov Dec 
 
 
 
 
 
 
(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)  Planning Period  
All Inclusiv  Labelling 
permitted for any products 
produced during this period  
Starting from the 
middle of the year  Starting from the 
beginning of the 
year 
Planning Period  
All Inclusive Labelling 
permitted for any products 
produced during thi s period  - 38 - 
 Q 32   What is a basic labelling method used for the All Inclusive Labelling?  
 
Answer  
1   The All Inclusive Labelling  is a labelling  method for bundling foreign supplying countries together in a 
category classed as “import.” 
The labelling  as "import" indicates that, based on the past records or the future plans on ingredients use by 
supplying country for a defined period of time , the order by weight and supplying countries of three or more 
foreign countries are expected to b e changed or switched within a  year from the labelling  (date of production).  
The labelling  as “import, domestic” indicates that, according to the actual coun tries 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,” etc.  
<<Example  1: A case of the ingredient originating from three or more foreign countries>>  
Name Dark Soy  Sauce (Naturally Brewed)  
Ingredients  Soybeans (Import), Wheat, Salt  
Net 400ml  
Expiration date  March 30, 2018  
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  March 30, 2018  
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  March 30, 2018  
How to store  Store at room temperature away from direct sunlight.  - 39 - 
 Producer  XX Co., Ltd.  
X-Y-Z Nagata- cho, Chiyoda -ku, Tokyo  
 
 
Q33  In All Inclusive Labelling, is labelling in smaller category than “imported,” such as 
“Produced in EU” “Produced in South America” accepted?  
 
Answer  
1   “Produced in EU” or “Produced in South America,” etc. may be acceptable as this is a smaller category than 
“Import.”  
However, as for the conditions for permitting “Import” labelling , only if the order by weight and supplying 
countries of a product are expected to be changed for the labelling of an ingredient originating from three or more 
foreign countries in EU or South America, etc. within a year, including the time when new labelling is expected 
(date of production), and it is going to be difficult to list the supplying countries in descending order by weight based on the past records or the fut ure plans on ingredients use by production center for a defined period of time, 
as All Inclusive Labelling, Produced in EU, Produced in NAFTA, Produced in ASEAN, Produced in Africa, or Produced in South America, etc. may be labelled.  
 2   In the case of us ing multiple production centers in a smaller category than “Imported,” it is also possible to 
label the production center in a smaller category than “imported” together, such as “Imported (Produced in EU, Produced in South America),” “Imported (Produced in EU or South America).”  
In the case of labelling as “Imported (Produced in EU or South America),”) a warning to the effect that the 
labelling is based on past records or future plans for ingredients used by the production center for a defined period 
of time, and storage of source documents in which are described past records or future plans for ingredients use by 
the production center for a defined period of time for ingredients for each category is required.  
 
V  All Inclusive Labelling + And/Or Labelling  
 
Q 34  Which case is permitted to use both All Inclusive Labelling and And/Or Labelling in 
combination (“import or domestic” or “domestic or import”) (labelling prescribed in 1 -(v)(c) 
of the processed food other than imported food column in the chart in Ar ticle 3, Paragraph 2 
of the Food Labelling Standards)?  
 
Answer  
That combination is allowed in addition to meeting the conditions permitting the All Inclusive Labelling (see 
Q 31), and when t here is a change for the order by weight for the imported ingredients (total) and domestic 
ingredients , which make it  difficult to display such labels with “import, domestic,” or “domestic, import ,” and the 
conditions for And/Or Labelling are met too (see Q 26).   - 40 - 
 (Example: A case, where the combined application of All Inclusive Labelling and And/Or Labelling is 
permitted)  
 
 
Q 35  What is a basic labelling method used for a case using both All Inclusive Labelling and 
And/Or Labelling in combination (“import or domestic” or “domestic or import”)?  
 
Answer  
1   The combination of the All Inclusive Labelling  and And/Or Labelling  is a method listing “import” and 
“domestic” in descending order by weight based on the past records or the future plans on ingredients use by 
supplying country for a defined period of time , which are connected with “or.”  
For example, when labelling  “Import or Domestic ,”  
(1)   They mean the following four  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 or in the future plans on ingredients use by supplying country for a 
defined period of time , the usage percentage of ingredients supplied by imported products (total) is greater than 
the usage percentage of ingredients supplied by domestic products.  
 
2  In order to prevent information being misleading consumers, it is always required to include a warning on the 
container or  package that such labelling  is based on the past records or the future plans on ingredients use by 
supplying country for a defined pe riod of time  (See  Q 36) . 
<<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  December 31, 2017  
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  - 41 - 
 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 
 
VI   Past records on ingredients use, etc.  
 
Q 36  In the And/Or Labelling and All Inclusive Lab elling + And/Or Labelling, what expression is 
acceptable for a warning to indicate that the labelling is based on the past records or the future 
plans on ingredients use  by supplying country for a defined period of time?  
           How long does the defined period of time have to be?  
 Answer  
1   When  And/Or Labelling  and  All Inclusive Labelling + And/Or Labelling,  are used, a warning is needed for 
consumers understanding that  the labelling  is showing the order based on the past records or the future plans on 
ingredients use by supplying country over a defined period of time.  
 
2   Regarding the warning note based on the past records on ingredients use by supplying country for a defined 
period of time , some examples would be l ike below:   
(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  
of the production year   
(4)   Countries of origin for XX and the order are based on the past records on ingredients use of two  years - 42 - 
 before the production year  
(5)   Countries of origin for XX and the order are based on the past records on ingredients use of  last year  
(6)   Countries of origin for XX and the order are based on the past records on ingredients use of the year before 
last  
(7)   Countrie s of origin for XX and the order are based on the past records on ingredients use of past one year  
(8)   Countries of origin for XX and the order are based on the past records on ingredients use during the past 
two years  
(9)   Countries of origin for XX a nd the order are based on the past records on ingredients use  that date back X 
years from  the expiration  date  
(10)   Countries of origin for XX and the order are based on the past records on ingredients use that date back X  
to X years from the expiration date  
(11)   Countries of origin for XX and the order are based on the past records on ingredients use for X  years since 
dating back X years from the expiration date  
(12)   Countries of origin for XX and the order are based on the  past records of the period from September 2015  
to August 2016  
(13)   Countries of origin for XX and the order are based on the past records on ingredients use that date back X 
years from the production  
(14)   Countries of origin for XX and the order are based on average of the past records on ingredients use last X 
years.  
As noted in  Q 26 , the period that  can be tracked back is within three  years prior to the year (year of production, 
fiscal year of production, etc.) in which a product is labelled (date of  production) . For example, if the production 
year is 2017,  the past record (s) on ingredients use  of more than a year 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  or omitted to label.   
 
3   The followings are examples of notes for labelling  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 labelled  based on the usage  plans of 2017  
(2)   Countries of origin for XX and the order are labelled based on the usage plans of this fiscal year  
(3)   Countries of origin for XX and the order are labelled based on the assumption from the contracted farming 
from June 2017 to May 2018  
(4)   Countries of origin for XX and the order are labelled based on the usage plans of production year  
(5)   Countries of origin for XX and the order are labelled  based on the usage plans of 2017. Continuous 
labelling , if there is no change for the usage plans for 2018 
In any of the above cases, it is permitted to use t hem as a note if a product is produced within the said usage 
plans.  
 - 43 - 
 4   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 Japanese year ) 
In cases where operations  that differ from the above mentioned such as fiscal years set for each agricultural 
crop are applied,  the scope of the said year should be noted.  
Labelling  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 labelling  is continued, plea se check 
whether or not it becomes false labelling .  
 
5   The  notes described  above are just labelling  examples  and it does not mean other descriptions are 
unacceptable. Please make a note easy to understand for consumers.  
 
Q 37  What types of documents should be retained for the And/Or Labelling, All Inclusive 
Labelling or All Inclusive Labelling + And/Or Labelling, ? 
 
Answer  
1   In the case of the And/Or Labelling , All Inclusive Labelling  or All Inclusive Labelling + And/Or Labelling, 
documents should be retained as evidence confirming that such labelling  is permitted for the ingredients.  
(1)   Documents indicating the following periods are from when to when (defined by a business operator).  
(i)   One year period (such as year of production and fiscal year of production) in which a product is labelled 
(date of production)  
(ii)  A defined period of time in the past or in the future  
(2)   Documents indicating that the changes of the order of supplying countries by weight and t he changes of 
supplying countries of ingredients over a defined period of time in the past or in the future  based on the 
methods of Q 26 and Q 31.  
(3)   Documents indicating the calculation units (per one product, common unit for controlling ingredients, etc.) 
used in the past records on ingredients use by supplying country over a defined period of time in the past.  
(4)   Regarding the note in And/Or Labelling or All I nclusive Labelling + And/Or Labelling, documents 
indicating the order of supplying countries of ingredients (total imported ingredients and domestic ingredients 
for All Inclusive Labelling + And/Or Labelling,) by weight  during the specified period of time described in the 
note. 
 
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 statemen ts, etc. listing the country of origin 
(2)   Specifications, etc. listing the country of origin and the container or package, invoices or delivery - 44 - 
 statements, 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 origin in the ingredients is not easily determined from 
documents (1) to (3), 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.  
 
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 clearly defining the one -year period (production year, production fiscal 
year, etc.) in which a product is labelled (date of production) and a certain period of time  in the past or in the 
future and that are considered reasonable as evidence for labelling  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 wi th the details of the label. Please retain any documents that show the 
records on ingredients use at the time of producing the products.  
 
Q 38  In the case that labelling is conducted based on the past records or the future plans on 
ingredients use  by supplying country for a certain period of time, what level of legitimacy is 
required for the past record or the usage plan?  
 
Answer  
1   When labelling  based on the future plans on ingredients use  by supplying country , and if (1) the actual usage 
results are significantly different and no legitima te explanation is given; and (2) no legitimate explanation is given 
for the basis of setting the plan, the said usage plan is not considered as a source for labelling .  
 
(1)   A case of the actual usage results  being significantly different from the labelling especially  when labelling  
the third country and beyond among three or more supplying countries as "others," and the majority of 
ingredients ended up being supplied by countries being categorized as "ot hers."  
 
(Examples of the actual usage results being significantly different)  
i) If originally labelling  “Country A or Country B or Others,” it has resulted, during the planning period, that 
ingredients from neither Country A nor Country B were  merely  used and only ingredients from countries - 45 - 
 included in “Others” were used.  
ii) If originally labelling  “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 at all.  
 
(2)   Cases of no legitimate explanation being given can be as follows.   
However, in the event of unexpected circumstances such as natural disaster, outbreak of a diseases 
epidemic in domestic animals, or suspension of shipping freight due to a port strik e, etc., which is likely to 
cause significant strains on the stable supply of food, it is deemed that legitimate explanations are possible.  
i) A case, which is significantly different from the original usage plan without any clear reason , 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 suppliers and contractors listed in the original plan were fabricated, as a result, ingredients 
from the labelled  countries of or igin have not been received.  
iii) Any other cases, where evidence of  the plan is ambiguous. (A case  where the period for the usage  plan is 
not specified , or a case  where the names of the supply countries  are listed vaguely.)  
 
2    When labelling  based on the  past records on ingredients use  for a defined period of time are significantly 
different from actual usage such as a case, where the predominant supplying countr y became, in fact, in the 
“Others,”  with no legitimate explanation given for such labelling , wh ich is the same circumstance as 1, such 
records on ingredients use  are not regarded as evidence for the labelling .  
 
Q 39  How long should the source documents be retained for the And/Or Labelling and All 
Inclusive Labelling, etc.?  
 
Answer  
1   As shown in Q 26, Q 31, and Q 37, besides the effort obligation provision, Article 41, of the Food Labelling 
Standards, as one of the conditions for the And/Or Labelling  and All Inclusive Labelling , it is required to retain 
documents indicating that the chan ges of the order of supplying countries by weight and changes of supplying 
countries over a defined period of time  in the past or in  the future 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)   One year from the expiration (best-before ) date on the product, whose label is written based on such 
evidence   
(2)   Five  years from the production date, if the expiration  date is not displayed or omitted.  
 
3   If continuing with the And/Or Labelling and All Inclusive Labelling  the current ly used percentages, etc. by 
supplying countr y will be used as the previously used records. Please retain these documents considering this - 46 - 
 factor.  
 
Q 40   When using And/Or Labelling or All Inclusive Labelling, etc., what kind of unit can be 
used for past records or future plans on ingredient use by supplying country for a defined 
period of time?  
 
Answer  
1   As methods of recording past records or future plans for ingredients use by the production center for a defined 
period of time when using And/Or Labelling or All Inclusive Labelling, etc., in addition to the method of product 
in factory, the following concepts may also be used. 
(1)   In the case of producing in multiple factories in efforts to standardize packaging materials for everything, 
recording in units of products that use the common packaging material may be used.  
(2)   When looking product units, management of ingredients for multiple products is sta ndardized, such as in 
the case where process of ingredient purchasing or processing the same, or ingredient tank is the same, etc., recording in product units for which management of ingredients are standardized.  
 2   Past records or future plans for ingre dient use by production centers for a defined period of time for the entire 
company or entire factory tallied without separation of products for which management of ingredients is not standardized may not be used. 
 
VII   Production Country Labelling for Se mi-Processed Ingredients  
 
Q 41  What is a labelling method used for the case that the ingredient subject to  the country of 
origin labelling is semi- processed ingredient?  
 
Answer  
1   When the ingredient subject to  the country of origin labelling is semi -processed ingredient , the production 
place of the product is to be labelled corresponding to the name of the ingredient labelled.  
 
2   Production methods for processed foods can vary. They can be produced from peris hable ingredients or 
produced using semi -processed ingredients manufactured at a factory of a different company, and thus it may be 
difficult to identify the country of origin of semi -processed ingredients trac ing back the countries of origin of  their 
perishable ingredients  in some cases.  
Since it has always been the case that labelling  ingredients are shown by the most general name s regardless of 
whether they are perishable ingredients or semi -processed ingredients , the production place corresponding t o the 
name of semi -processed ingredients  is to be labelled  as the country of origin of  the ingredient  
On the other hand, in the case of the ingredient being a semi -processed ingredient, if a country of origin is 
labelled , this may mislead consumers as though the  said country of origin is for  perishable ingredient s used in the - 47 - 
 semi-processed ingredient . Thus, the country of origin for the semi -processed  ingredient should be labelled  as 
“produced in XX ”（“Processed in XX” labelling  is not permitted ). 
 
3   If there are several countries to label as production countries, supplying countries in descending order by 
weight is to be labelled  as a general rule and the words “produced in” must always be added for each country. 
(The labelling  of “Produced in Germany , Brazil” is not permitted.) “Produced in XX” in brackets needs to be 
shown after the name of a semi -processed ingredient, which corresponds individually with the name of the semi - 
processed ingredient. That means, labelling “Produced in XX” corresponds to the perishable ingredients  is not 
acceptable, such as  “Apples (Pro duced  in Germany)” for example.  
 
4   If countries  of origin for ingredients used for a semi -processed in gredient can be traced back to  perishable 
ingredient s and that can be objectively confirmed , instead of labelling  “Produced in XX,” the said country of 
origin can be labelled  together with the said perishable ingredient.  
 
5   The other labelling  methods are the same as perishable ingredients. That means that “Produced in XX 
Prefecture” can be used for labelling  instead of “Domestically Produce ” as shown in Q19.   
<<Example 1: Production country labelling  for semi -processed ingredients>>  
(Purchase apple juice and use it as ingredient)  
Name Non- alcoholic beverage  
Ingredients  Apple Juice ( Produced in Germany), Fructose- glucose Syrup, 
Fructose/Acidifier, Vitamin C  
Net 500ml  
Expiration date  December 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  
 
(Purchase baked cake and use it as ingredient)  
Name Dorayaki  
Ingredients  Pancake (Domestically Produce d) (Eggs, Flour, Sugar), Bean 
Jam (Sugar, Azuki Beans, Malt Syrup, Agar) / Raising Agent  
Net 1 Piece  
Use by  December 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  
 - 48 - 
 (Purchase wheat flour  and use it as ingredient)  
Name Sliced Bread 
Ingredients  Flour ( Domestically Produced ), Sugar, Margarine, Yeast, Salt 
(partially contains Wheat and Dairy Product)  
Net 6 Slices 
Use by  Written on  the front  of package  
How to store  Store in a cool dry place away from direct sunlight.  
Producer  XX Co., Ltd.  
X-Y-Z Kasumigaseki, Chiyoda -ku, Tokyo 
 
<<Example 2: Production country labelling for semi -processed ingredients ( Labelling by adding a 
category of Country of Origin for Ingredients)>>  
(Purchase apple juice and use it as ingredient)  
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  December 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  
 <<Example 3: Labelling by tracing back the country of origin to perishable ingredients 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  December 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  
  
 
appropriate  - 49 - 
 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  December 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  
 
<<Example 4: Labelling by tracing back the country of origin of perishable ingredients for semi -processed 
ingredients ( Labelling 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  December 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 Non- alcoholic beverage  
Ingredients  Apple Juice, Fructose- glucose Syrup, Fructose/Acidifier, Vitamin 
C  
Country of Origin    Germany, Hungary (Apples)  
for Ingredients   
Net 500ml  
Expiration date  December 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  
 
<<Example 5: When l abelling the country of origin of perishable ingredients for semi -processed 
ingredients by adding a category of Country of Origin for Ingredients, and the same perishable ingredient 
is used in a few semi -processed ingredients >> 
 * It must be clearly described which semi -processed ingredient contains the perishable ingredient 
labelled with the origin of the country.  
inappropriate  - 50 - 
 Name Non- alcoholic beverage  
Ingredients  Apple Juice, Apple Grains, Fructose -glucose Syrup, 
Fructose/Acidifier, Vitamin C  
Country of Origin 
for Ingredients  Hungary (Apples  (Apple Juice) ) 
Net 500ml  
Expiration date  December 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  
 
Q 42   How is the production country for semi -processed ingredients determined?  
 
Answer  
1   When semi -processed ingredients are domestic, and when manufactured in Japan, “domestically produced” 
shall be labelled, and in the case of imported goods, “produced in xx” shall be labelled to indicate production in a 
foreign country.  
 2   For imported semi -processed ingredients, normally the production center on the Import Permission at customs 
clearance is regarded as the production center. 
 
3   In addition, in the case of purchasing imported processed foods for which some kind of actions are added by 
other companies inside Japan and using those as semi -processed ingredients, see 43 in this Q&A.  
 
4   Supposing “manufacturing” or “processing” is conducted, the fact that the name of an items such as 
manufacturer or processor is changed, and the fact that Semi -Processed Ingredients become “domestically 
produced” after substantial changes inside Japan are sep arate issues, so please make judge appropriately in the 
respective cases.  
 
Q 43  What are the examples of acts conducted domestically for imported semi -processed 
ingredients which cannot be considered “domestic production?”  
 
Answer  
1   When semi -processed  ingredients are domestically produced, it is necessary to label “domestically -produced” 
to indicate they are manufactured in Japan, and when they are imported, it is necessary to label “produced in xx” 
to indicate that they are manufactured in foreign countries.  
 2   Therefore, for imported semi -processed ingredients, if “action to cause substantial changes in specifics of - 51 - 
 products” are made by other domestic companies, and then they are purchased and used as semi -processed 
ingredients, they are labelled “domestically produced.”  
 
3   “Action to cause substantial change in specifics of products” is under the same concept as in “country of 
origin” labelling, to show the fact that they are imported items as product. (See Food Labelling Standards Q&A Processing -154, 155)  
 4   Primary examples of not being “action to cause substantial changes in specifics of products” and so not being 
“domestically produced” are as follows:  Primary examples of not being “action to cause substantial changes in specifics of 
products” and so not being “domestically produced”  
Attaching stickers, 
modifications, or 
replacement of stickers on containers or packages  Attaching Japanese stickers for  use in Japan on containers or 
packages  
Creating assortments  Creating assortments among external decorations for sales  
Subdivision  Subdivision after purchase in bulk  
Example: Purchasing broiled eel and subdivision, purchasing pasta 
in bulk and subdivision  
Cutting  Simple cutting such as slicing  
Example: Slicing ham  
Shaping  Forming in shape  
Example: Shaping in sha pe of block bacon  
Screening  Screening by shape or size  
Example: Screen dried anchovy by size  
Crushing  Slight crushing (except for powdered items)  
Example: cracked soybeans  
Mixing  Mixing the same type of food  
Example: Mixed tea leaf  
Combination  Creating assortment of different types of food for easier separation, 
etc. 
Example: Assortment for easier separation by individual packaging or partition, etc.  
Deboning  Only removing bones  
Example: removing bones from salted mackerel  
Freezing  Freezing for transportation or storage  
Defrosting  By natural defrosting, etc., defrost simply -frozen food to the state of 
cooling or room temperature 
Example: Defrost frozen boiled octopus  
Drying  Drying for transportation or storage  
Salt water soaking  Soaking in salt water for transportation or preservation  
Salt addition  Adding salt to already salted food, etc.  
Example: Add salt to lightly -salted salmon to make heavily -salted 
salmon - 52 - 
  
Q 44   For semi -processed ingredients produced via several production process stages, for which 
stage should the production country be labelled?  
 
Answer  
In the case where ingredients subject to country of origin labelling are semi -processed ingredients, the 
production center or the country of origin by tracking back to fresh ingredients must be labelled, and the production 
place labelling at an optional st age other than this cannot be accepted as country of origin labelling .  
<<Appropriate Example>>  
Name Bread roll filled with bean jam  
Name of country of 
origin of ingredients  Bean Jam (produced in country A), Flour, Sugar, 
Margarine, Eggs, Skim Milk ...  
Net 1 piece  
Expiration date  December 31, 2017  
How to store  Store away from direct sunlight.  
Producer  XX Co., Ltd.  
 X-Y-Z Nagata -cho, Chiyoda -ku, Tokyo  
 
<< Inappropriate example of not tracing back to fresh ingredients>>  
Name Bread roll  filled with bean jam  
Ingredients  Bean Jam (Sugar (domestically produced), Azuki Beans, 
Malt Syrup, Other), Flour, Sugar, Margarine, Egg, Skim 
Milk, ...  
Net 1 piece  
Expiration date  December 31, 2017  
How to store  Store away from direct sunlight.  
Producer  XX Co., Ltd.  
 X-Y-Z Nagata- cho, Chiyoda -ku, Tokyo Minor addition of seasoning, 
etc. Adding small amount of seasoning, etc.  
Example: Adding very small amount of soy sauce to 
plain boiled food  
Addition of small amount of relish  
Example: Sprinkle sesame seeds on candied sweet potatoes  
Addition of additives  Add additives  
Example: Adding Vitamin E to grapeseed oil for the purpose of 
nutritional enhancement, coloring dried small shrimp, adding flavor 
to orange juice  
Disinfection  Disinfecting before and after packaging  
Example: heat disinfection of dried small fish, disinfection upon subdivision of concentrated fruit juice  
Binding prevention  Coating with vegetable oil to prevent binding  
Example: Coating raisins with vegetable oil  
Reheating  Simple heating such as re-frying, re -broiling, re -steaming, etc.  
appropriate  
inappropriate  - 53 - 
  
Q 45   In the case where semi -processed ingredients subject to country of origin labelling are 
composite ingredients and not “Production Country Labelling for Semi -Processed 
Ingredients,” but where labelling should be done by tracing back to country of origin of 
perishable ingredients, which of the composite ingredients should be labelled with the 
country of origin?  
 
Answer  
1   In the case where country of origin for composite ingredients is labelled by tracking back to country of origin 
of perishable ingredients, labelling of country of origin of the heaviest ingredients by weight in the composite 
ingredients (the most predominant ingredient by weight) is required. 
 2   Even though the most predominant ingredient by weight in the composite ingredients is lighter than the second 
predominant ingredient by weight in the entire product, still the most predominant ingredient by weight in the composite ingredients is subject  to the country of origin labelling obligation. 
 3   In such instance, for country of origin labelling of composite ingredients, not only the name of the ingredient 
for which to label the country of origin, in accordance with the labelling  method of the ingredients in the 
composite ingredients, by adding brackets after the name of the composite ingredients, all of the names of 
ingredients for the relevant composite ingredients must be labelled in descending order from the heaviest ingredient by weight  
In ad dition, if there are three or more types of ingredients for the relevant composite ingredient, ingredients of 
which percentage of weight to the ingredients of the relevant composite ingredients ranks third or lower, and the 
ratio thereof is less than 5%, m ay be labelled as Other. (See Food Labelling Standards Q&A Processing —52)  
 
4   In addition, not only the most predominant ingredients by weight in composite ingredients, it is desirable to 
label the country of origin for the second and third most predomina nt ingredients by weight in composite 
ingredients. 
<< Example 1: Labelling by tracing back the ingredients for the Semi -Processed Ingredients>>  
Name Dorayaki  
Ingredients  Pancake (Egg (Domestic), Flour, Sugar), Bean Jam (Sugar, 
Azuki Beans, Malt Syrup) /Raising Agent  
Net 1 piece  
Expiration date  December 31, 2017  
How to store  Store away from direct sunlight.  
Producer  XX Co., Ltd.  
 X-Y-Z Nagata- cho, Chiyoda -ku, Tokyo 
 
 - 54 - 
 << Example 2: Labelling by tracing back the ingredients for the Semi -Processed Ingredients>>  
Name Dorayaki  
Ingredients  Pancake (Egg, Flour, Sugar), Bean Jam (Sugar, Azuki 
Beans, Malt Syrup)/Raising Agent  
Name of country of origin 
of ingredients  Domestic (Eggs)  
Net 1 piece  
Expiration date  December 31, 2017  
How to store  Store away  from direct sunlight in a cool dry place  
Producer  XX Co., Ltd.  
 X-Y-Z Nagata- cho, Chiyoda -ku, Tokyo 
 
Q 46   On which step of processing should be labelled for the county of origin about the 
semi -processed ingredient internally produced domestically?   
 
Answer  
1   It is supposed that the  country of origin is to be labelled in accordance with the name of ingredient. Therefore, 
label the country of origin of the ingredient which is appropriately labelled under the Food Labelling Standard.  
  
2   For example, as often happened in vegetable fat and oil, purification is processed after mixing crude oil  
produced from oil seed  internally and another crude oil from external company, production place of the fat and oil 
(semi -processed ingredient) is to be labelled in principle as far as the  ingredient  is shown by the name of fat and 
oil.   
 
Q 47   Are the And/Or Labelling and All Inclusive Labelling, etc. permitted for the production 
country labelling for semi -processed ingredients?  
 
Answer  
1   For the purpose of providing information to consumers, the labelling  of su pplying countries in descending 
order by weight is required as a general rule for the production country labelling  for semi -processed ingredients.  
However, if the labelling  of suppl ying countries in descending order by weight , even  in the case of labelling  
production countries , proves to be difficult, the And/Or Labelling, All Inclusive Labelling , and the combination of 
these two types of labelling  would be permitted under certain conditions.  
The conditions permitted for such labelling  are exactly the same as those for the perishable ingredients 
labelling . (See  Q 26 to Q 37 ) 
 
2   For the All Inclusive Labelling  the labelling  of “foreign produced” is permitted but “imported and  produced” 
or “produced outside Japan” is not permitted as they do not clearly describe their meaning.  
 - 55 - 
 <<Example 1: And/Or Labelling for the labelling of production country>>  
Name Non- alcoholic beverage  
Ingredients  Apple Juice (produced in Germany or produced domestically ), 
Fructose- glucose Syrup, Fructose/Acidifier, Vitamin C  
Net 500ml  
Expiration date  December 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  
*Production places for apple juice and the order are based on the past records  on ingredients use in 2015  
 
<<Example 2: All Inclusive Labelling for the labelling  of production country>>  
Name Non- alcoholic beverage  
Ingredients  Apple Juice ( foreign produced), Fructose -glucose Syrup, 
Fructose/Acidifier, Vitamin C  
Net 500ml  
Expiration date  December 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  
 
 
Answer  
1   Ingredients subject to the mandatory labelling  of country of origin for ingredients are the ingredients 
individually specified in Appendix 4 in the Food Labelling  Standards and are the most predominant ingredient by 
weight.  
 
2   The labelling  methods should be in accordance with Appendix 20 or Appended Form 1 in the Food Labelling  
Standards and any of the following will be labelled , as a general rule, by adding an itemized column for the 
country of origin for ingredient.  
(1)   To label the country of origin corresponding to the name of ingredient, which is labelled  based on the 
individual provisions. 
 Q 48  There are rules provided for labelling methods of ingredients for each item in Appendix 4 
in the Food Labelling Standards. Following these rules and in the case of labelling the names 
of ingredients classified as perishable food by tracing them back instead of labe lling the 
names of semi -processed ingredients, how shall we label countries of origin for ingredients?  - 56 - 
 <<Example 1: A case of using concentrated apple juice and showing the countries of origin of it >> 
Name Apple Juice (from concentrate)  
Ingredients  Apples /Flavoring  
Country of Origin 
for Ingredient  Germany, Japan  
Net 500ml  
Expiration date  December 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)   L abel 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 countries  of 
origin specified in the ingredients labelled  in the names of ingredients column.  
<<Example 2: A case of using concentrated apple juice produced in Germany and squeezed apple juice 
produced domestically, and showing the countries of origin for concentr ated apple juice and apple >>  
Name Apple Juice (from concentrate)  
Ingredients  Apples /Flavoring  
Country of Origin 
for Ingredient  Produced in Germany (Apple Juice), Domestic (Apples)  
Net 500ml  
Expiration date  December 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  
 <<Example 3: A case of And/Or Labelling using concentrated apple juice produced in Germany and 
squeezed apple juice produced domestically, and showing the countries of origin for concentrated apple 
juice and apple s >>  
Name Apple Juice (from concentrate)  
Ingredients  Apples /Flavoring  
Country of Origin 
for Ingredient  Produced in Germany (Apple Juice) or Domestic (Apples)  
Net 500ml  
Expiration date  December 31, 2017  
How to store  Store in a cool dry place away from direct sunlight.  - 57 - 
 Producer  XX Co., Ltd.  
X-Y-Z Nagata- cho, Chiyoda -ku, Tokyo  
*Production places for apple juice and apples and the order are based on the record of 2015.  
 
3   Without adding a category of Country of Origin for Ingredients , the country of origin can be labelled  in the 
ingredients column by placing brackets after the name of the corresponding ingredient.  
In this case, if the ingredient  is labelled with the name of perishable food, it is not permitted to label 
semi-processed ingredient together with it (for example, “Ingredients: Apples (Apple juice (Produced in XX) )”). 
<<Example 4 : A case of using concentrated apple juice produced in Germany and concentrated apple 
juice produced domestically, and showing the countries of origin for apples >> 
Name Apple Juice (from concentrate)  
Ingredients  Apples (Germany, Japan) /Flavoring  
Net 500ml  
Expiration date  December 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  
 
 
VIII    For Professional Use  
Q 49   What are the labelling requirements for processed food products for professional use in 
relation to the country of origin labelling for ingredients?  
 
Answer  
1   For any products sold to consumers, in order to properly label countries of origin for ingredients, it is needed 
to appropriately inform  on countries of origin for processed food products for professional use such as 
semi-processed ingredients.  
On the other hand, any matters, which are not related to the labelling  of countries of origin for ingredients of 
the final products, have no manda tory labelling  (or the information transmission) requirements.  
 
2   In order to ensure the accuracy of the country of origin labelling  for ingredients of the final products, the 
following must be labelled  (or the information  transmitted ):  
(1)   Countries  of origin for the processed food product for professional use, if the said processed food product 
for professional use in the final product  is subject to the mandatory production country labelling  (as the most 
predominant ingredient by weight in the final  product , etc. )   
(2)   Countries of origin for the ingredient subject to the mandatory labelling  for the country of origin for the 
ingredient in the final product (such as the most predominant ingredient by weight in the processed food 
product for professional use, etc.) , if the said processed food product for professional use other than imported - 58 - 
 products will be a final product only by simple cutting or subdivision, etc., which are not considered as 
"practical modification "  
 
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 country of origin 
labelling  for ingredients since they were bought for the purpose of (1)  above have been sold for general 
consumers at a supermarket, this will be a violation of the Food Labelling  Standards.   
 
4   If  there is an agreement between food businesses and the products have the country of origin labelling  for 
ingredients by tracing back to perishable foods, the labelling  of (1) or (2) above (or the information transmission) 
is not required since this does not affect the labelling  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 practically modifying their contents” domestically after being imported, the 
country of origin labelling  is required for the said processed food products for professional use . (See “Processing -  
154, 155 of Q&A of the Food Labelling  Standards”)  
 
Q 50  How do we label the country of origin for processed food products for professional use?  
 
Answer  
1   Please label ( or transmit information ) the country of origin for processed food products for professional use .  
 
2   For imported products “country of origin: Country A” is labelled.  For processed food products for 
professional use in which there have been “acts of practically modifying their contents” domestically “domestically produced” or “made in Japan” in addition to “ country of origin: domestic  " are to be labelled 
(information transmitted) so that it does not mislead producers, etc. of processed foods for general use.   
 
3   It is considered that indicating “domestically produced” is labelled ( the information transmitted) if the 
production place and the producer are labelled with the same manner of general processed food and required items 
are filled for the “production place ,” as long as the businesses do not misunderstanding the labelling.    
 
Q 51  How do we label the country of origin for ingredients for processed food products for 
professional use?  
 
Answer  
1   This is the same labelling  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 - 59 - 
 Origin” for imported products, both corresponding to the name of the ingredient, should be labelled  (information 
transmitted ). In the case of domestically pr oduced products, in addition to the labelling  that they are domestically 
produced, the following names of places can be labelled .  
(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 kn own, where the landing port or the main cultivation site is located  
 
2   For imported fishery products, the names of the waters can also be labelled  with the name of the country of 
origin. 
 
3   In the case of two or more countries of origin, the descending order by weight in the ingredient should be 
clearly labelled. If the percentages are labelled so that the order by greater weight is evident, labelling the 
descending order by weight is not necessarily required.  
 
4   If the said ingredient is a semi -processed ingredient, the labelling  of a production country (label as “Produced 
in XX”) is required.  
 
Q 52  Where shall we label the country of origin and the country of origin for ingredients for 
processed food products f or professional use?     
 
Answer  
1   Countries of origin and countries of origin for ingredients, when trading processed food products for 
professional use, can be labelled  not only on the container or package but also in invoices, delivery statements, 
etc., or specifications, etc.  
 
2   In the case of labelling  them in specifications, etc., it is necessary to be able to refer to that the shipped and 
delivered products are based on which specifications, etc. on the container or package, or in invoice s, or delivery 
statement s, etc.  
 
3   As noted in the above, it is permitted to specify the mandatory labelling  items for processed food products for 
professional use not only on the container or package but also in invoices, delivery statements, etc. or 
specifi cations, etc. However, any matters provided in Article 13, Item (ii) of the Food Labelling  Standards are 
required to label on the container or package, thus, these provisions must be followed for labelling .  
 
Q 53   What are the labelling requirements for p erishable food for professional use in relation to 
the country of origin labelling for ingredients?   - 60 - 
  
Answer  
1   In order to ensure the accuracy of the country of origin labelling  for ingredients in the final products, it is 
required to label countries of origin 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 labelling  of 
a country of origin for an ingredient.  
For the p erishable food for professional use, whose country of origin labelling for ingredients is certainly not 
required in the final product, the above labelling  can be omitted.  
 2  If it is uncertain whether o r not the country of origin labelling  for ingredients is required in a final product, the 
above labelling  cannot be omitted.  
 
Q 54  How shall we label the country of origin for perishable food for professional use?  
 
Answer  
1   The country of origin labelling  for a perishable food for professional use will be the labelling  source for the 
country of origin for the ingredient used for a processed food. Its labelling  method is the same as that of the 
country of origin for the ingredient used for a proces sed food. “Domestically produced” indication is labelled  for 
any domestically produced products and a “Country of Origin” is labelled  for any imported products. In the case 
of domestically produced products, in addition to the labelling  indicating that the y are domestically produced, the 
following names of places can be labelled .  
(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   F or imported fishery products, the names of the waters can also be labelled  with the country of origin.  
 
3   In the case of two  or more countries of origin, the descending order by weight in the ingredient should be 
clearly labelled . If the percentages are labelled  so that the order by greater  weight is evident, labelling  the 
descending order by weight is not necessarily required.  
 
Q 55   Where shall we label the country of origin for perishable food for professional use?  
 
Answer  
1   Countries of origin, when trading perishable foods for professional use, can be labelled  not only on the 
container or package but also in invoices, delivery statements, etc., or specifications, etc.  - 61 - 
  
2   In the case of labelling  them in specifications, etc., it is necessary to be able to refer that the shipped and 
delivered products are based on which specifications, etc., on the container or package, or in invoices or delivery 
statements, etc.   
 
IX Others  
 
Q 56   For processed f ood in Appendix 15- 1 to 5 (so- called “22 food groups and 4 items”), can 
And/Or Labelling, All Inclusive Labelling or “Production Country Labelling for 
Semi -Processed Ingredients” be used?  
 
Answer  
1   For the so -called “22 food groups and 4 items” that are  required to be labelled for the country of origin prior 
to expansion of country of origin labelling to all processed foods, the supplying countries should be labelled in 
descending order by weight, as per the status quo. (except for the cases shown in Labelling Method -10 of Country 
of Origin Labelling (Appendix 15- 1 to 6) attached to the Food Labelling Standards Q&A)  
 
2   In addition, for “dried bonito flakes,” the production center of dried bonito has been labelled as the country of 
origin, and as a resul t of introduction of production country labelling of Semi -Processed Ingredients, it is changed 
to the term “Produced in xx.”  
 
Q 57   Among the so- called 22 food groups (processed food in Appendix 15- 1), if there are no 
perishable foods whose weight percenta ge in ingredients and food additives is 50% or greater, 
how should such food be labelled?  
 
Answer  
1   Label in the same way as for those not shown in Appendix 15.  
 
2   Specifically, for the heaviest ingredient by weight in ingredients (the most predominant ingredient by weight), 
descending order of the supplying countries by weight is the general rule, and if it is difficult to do so, under fixed conditions, And/Or Labelling or All Inclusive Labelling, or labelling of the production country for Semi -Proces sed 
Ingredients will be permitted. 
 
Q 58   “Nori for Rice Balls” is individually subject to the country of origin labelling requirements 
for ingredients. What is the scope of the “Rice Balls” and how shall we label the country of 
origin for ingredients?  
 
Answer  - 62 - 
 1   For the purpose of providing information to consumers, “Nori for Rice Balls” is individually subject to the 
country of origin labelling  for ingredients. “Rice Balls” in this case  means cooked rice or cooked rice with other 
filling s are wrapped w ith nori (including the ones with the f orm allowing consumers to wrap nori by themselves ).   
  
2   For example, anything that consumers generally recognize as rice balls are included 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  convenience store s, etc.    
 
3   The following products are not in the scope of the requirements.  
(1)   Products that are packed with “side dishes  (accompanying dishes) ” such as fried food or pickled radish in a 
container or package.  
(2)   Rolled sushi, gunkan- maki, or self -wrapping sushi , etc. which are categorized as sushi.  
 
4   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 the  requirement s. This is the same condition as applied to other 
products subject to the country of origin labelling  for ingredients. 
 
5   For rice balls, the country of origin labelling  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 ingredient by 
weight).  
Labelling  supplying countries in descending order by weight is required and the And/Or L abelling  and All 
Inclusive Labelling  are not permitted.  
In practice, since the country of origin of nori and algae are the same, countries of origin for ingredient of nori, 
that is algae,  are to be labelled with bracket s after the name of nori, such as ”Nori (Domestic)” or “Nori (Algae 
(Domestic))”  
 
*It is required to label a supplying country for rice for general rice balls, in accordance with the provisions of the 
Rice Traceability Act .  
 
Q 59  In the case of voluntary labelling ingredients of produc ts, where the country of origin 
labelling for ingredients is not required, how shall we label them on the container or package?  
 
Answer  
1   Countries of origin for the greatest ingredient by weight in the ingredients (the most predominant ingredient 
by weight) are only subject to l abelling  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 labelling of countries  of origin for ingredients, labelling  supplying countries in - 63 - 
 descending order by weight is to be followed as a general rul e. However, for the purpose of providing as much 
information as possible so providing consumers’ opportunities for autonomous and rational choice of foods, the 
And/Or Labelling, All Inclusive Labelling , or “production country labelling  for semi -processed i ngredients” are 
acceptable under certain conditions, with the same manner  as the mandatory labelling .  
 
3   Even when labelling  voluntar ily, if there is any conflict with the laws relating to labelling  such as the Food 
Labelling  Act, such labelling  is subject to supervision and penalties. Please label as clearly as possible based on 
the facts.  
 
Q 60   Is it acceptable to voluntarily provide information regarding the countries of origin for 
ingredients on websites, etc.?  
  
Answer  
1   It is desirable  to voluntarily and proactively provide information to consumers using the internet platforms 
regarding detailed information on supplying countries for any ingredients not  being subject to the mandatory 
labelling , or when the And/Or Labelling , All Inclusiv e Labelling , or “production country labelling  for 
semi-processed ingredients” to the container or package  is adopted.  
 
2   Even when labelling  voluntarily, if there is any conflict with the laws relating to labelling  such as the 
Premiums and Representations Act, such labelling  is subject to supervision and penalties. Please label as clearly 
as possible based on the facts.  
 
Q 61   How should a sudden change of country of origin for ingredients due to natural disaster or 
bad crop, etc., be handled?  
 
Answer  
1   At the time of the Great East Japan Earthquake in 2011 or the Kumamoto Earthquake in 2016, for labelling not 
according to the Food Labelling Standards, we handled matters so that it would not be subject to controls, except 
for sanitation matters, and the same kind of handling is expected for the similar cases in the future as well.  
Also, as similar examples, import suspension measures, etc., due to outbreak of infectious disease of livestock 
can be considered but we consider it difficult to explain how this will be handled in advance with examples.  
However, we will not exclude placing controls on malicious violations to cause misunderstandings in 
consumers.  
 
2   When production center to be used is different from t he labelling details as a result of change of suppliers of 
ingredients due to bad crop of agricultural products or fluctuation of exchange, etc., handle the matter by changing 
the country of origin labelling. 
 - 64 - 
 Q 62   What are the transitional measures applied for the expansion of the country of origin 
labelling for ingredients for all processed foods?  
 
Answer  
1   There will be a period for transitional measures, which will allow promotion to raise consumer awareness and 
preparation for switching labelling  by businesses.  
 
2   The period for transitional measures will be from the effective date of the Amended Food L abelling  Standards 
(September 1 , 2017) until the end of March  2022. Any processed foods for general use produced and perishable 
foods or processed foods  for professional use  sold during this period can be labelled  in accordance with the 
provisions set either before or  after the Amended Act, though those after this period may not be labelled in 
accordance with the provisions set before amendment.   
Once any of the following arrangement has been completed, processed foods  for professional use  labelled in 
accordance with the Food Labelling Standards before amendment  are allowed to be sold after the period for 
transitional measures.  
(1)   If labelled  on the container or package of the food, the labelling  that meets the  requirements under the 
Amended Food Labelling  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 Labelling  Standards are submitted to the distributor after collecting (or making arrangement to dispose 
of) old specifications, etc.  
(See S upplementary Provision - 4 of the Food Labelling  Standards ) 
 
3   Please quickly switch  to the  labelling  compatible with the new labelling  requirements for the country of origin 
for ingredients after the effective date of the Amended Act  (September 1, 2017) .  
 
Q 63   Is product that is in the process of production at the production place or processing place 
when the Food Labelling Standards are in effect and then completed after the transitional 
measures period also subject to this labelling?  
 
Answer  
1   As the Cabinet Order to Revise a Part of the Food Labelling Standards (Cabinet Order No. 43 of September 1, 
2017) is in effect, products that are in the process of manufacturing at the manufacturing place or processing place 
for processed foods and will be completed and sold after April 1, 2022 are not covered, and labelling may be done 
under any of the provisions before or after revision. Specifically, liquors and fruit vinegars, etc. are viewed thusly.  
 2   For example, for whiskey aged at a distillery at th e time of enforcement, the country of origin labelling  is 
unnecessary.  - 65 - 
 In addition, even if this whiskey is blended with other whiskeys, country of origin labelling is unnecessary. 
 
Q 64   How do you plan to work on public awareness for consumers on the introduction of this 
new country of origin labelling for ingredients?  
 
Answer  
The system of  the country of origin labelling  for ingredients for processed food has been significantly changed 
this time. There are some new labelling  methods such as the And/Or Labelling in addition to the labelling  of 
“supplying countries in descending order by weight” being as a general rule. It is acknowledged that government 
together with related organizations must cooperate from now on to engage in dissemination activities from multiple 
angles so that consumers have better understanding of  such labelling  methods.  
It is expected that the same n amed products with the country of origin labelling  for ingredients as the “ labelling  
of supplying countries in descending order by weight,” And/Or Labelling , All Inclusive Labelling , and “ production 
country labelling for semi -processed ingredients ” could p ossibly 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 labelling , and 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  “labelling  of supplying countries in descending order by 
weight” as a general rule, as well as  that consumers would make ef forts for better understanding of the new system 
for country of origin labelling for ingredients of processed foods.