December 26, 2025

(Reiwa 7, December 26, 2025)

Public Comments Solicitation on the Partial Amendment of the Cabinet Order Regulating Allergens, Expiration Dates, Heating Requirements, and Other Safety-related Matters for Food Contact Materials as Defined in the Food Labeling Standards and Food Labeling Act, Article 6, Paragraph 8

The Cabinet Order regulating allergens, expiration dates, the need for heating for safe consumption of food, and other matters impacting food safety has been revised in accordance with the Food Labeling Standards (Law No. 70 of 2013) and the Food Labeling Act, Article 6, Paragraph 8. The partial amendment to the Cabinet Order (Cabinet Order No. 11 of 2015, referred to as the "6-8 Paragraph Cabinet Order") is now open for public comment. Submitted comments will be considered as a reference for further revisions of this draft.

Overview of the Amendment

(1) Allergens Labeling Matters

In the "2025 National Survey on Immediate-Type Food Allergies," it was found that the number of cases involving cashews among tree nuts, as well as the percentage of cashew cases in total tree nut cases, had increased, indicating that this is not a transient issue. Based on this, the "Food Allergy Labeling Advisory Meeting (7th session)" held in January 2026 proposed that cashews be moved from a "permitted material similar to specific allergens" to the category of specific allergens.

With the establishment of a standard testing method for cashews, the Food Labeling Standards, Appendix 14 (Specific Allergens) will be amended to include "cashews" as a specific allergen.

(2) Individual Item Labeling Rules Matters

Since the 2025 fiscal year, a "Subcommittee for Reviewing Labeling Rules for Individual Items" has been held to discuss the necessity of rules and potential amendments. Based on the discussions, amendments to the Food Labeling Standards are being implemented gradually.

(Food Labeling Standards)

Article 5 (Special Provisions for Mandatory Labeling)

Article 10 (Mandatory Labeling for Business Processed Foods)

Article 11 (Special Provisions for Business Processed Foods)

Article 15 (Mandatory Labeling for Processed Foods Sold by Non-Food Businesses)

Appendix 3 (Definition of Food)

Appendix 4 (Individual Labeling Rules – Name, Ingredients, Additives, Content)

Appendix 5 (Name Regulations)

Appendix 13 (Standards for Proper Nutritional Claims)

Appendix 19 (Specific Mandatory Labeling Items)

Appendix 20 (Labeling Methods and Individual Rules)

Appendix 22 (Prohibited Labeling Items for Specific Foods)

Appendix 23 (Labeling Requirements for Business Processed Food Containers and Packaging)

(6-8 Paragraph Cabinet Order)

Article 1 (Important Matters for Food Safety)

Article 7 (Matters Defined by the Cabinet Order under Article 7, Paragraph 1)

According to these regulations, the implementation dates of the amendments are as follows:

○ The implementation date is set for April 1, 2026.

○ Amendments regarding (1) will have a two-year transitional period from the implementation date.

○ Amendments regarding (2) will have a four-year transitional period from the implementation date.

※ Food processed, manufactured, or imported before the end of the transition period (excluding business processed foods) and business processed foods sold before the same date may still be labeled according to the previous regulations.

Public Comment Period

From December 26, 2025 (Friday) to January 30, 2026 (Friday)

(Comments sent by mail must arrive by this date)

Reference

https://www.caa.go.jp/notice/entry/044618/

https://www.caa.go.jp/notice/assets/food_labeling_cms201_251226_02.pdf