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Selling food in Japan

In Japan, food safety standards are set under the Food Sanitation Act and labelling under the Food Labelling Act, both now run by the Consumer Affairs Agency. Imported food is notified to an MHLW quarantine station each time it arrives. Labels are in Japanese, and recalls are notified to the prefecture or the Agency.

Updated · Each section links to the official source it comes from

Safety standards
Food Sanitation Act (食品衛生法)
Labelling
Food Labelling Act (食品表示法) and the Food Labelling Standards
Who sets the standards
The Consumer Affairs Agency, since 1 April 2024
Import
Notification to an MHLW quarantine station for each import
Label language
Japanese
Allergens
8 mandatory, 20 recommended

Before a product goes on sale

The questions to answer, in the order they usually come up.

  1. 1Are the additives on Japan's lists, and used within their standards? Read more
  2. 2Are residues of pesticides and veterinary drugs within the limits? Read more
  3. 3What must the Japanese label show, including allergens, dates and nutrition? Read more
  4. 4Can the claims you want to make be made at all? Read more
  5. 5Who files the import notification, and does the product need a health certificate? Read more
  6. 6Does the business that makes or handles it in Japan need a licence? Read more
  7. 7What happens if it has to be recalled? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

Labelling

What a label on food sold in Japan has to show, and in which language.

  • The Food Labelling Act has the Prime Minister set Food Labelling Standards (食品表示基準) covering the name, allergens, storage method, expiry date, ingredients, additives, nutrition and energy, country of origin and other information (Article 4).
  • Businesses must not sell food that is not labelled according to the Food Labelling Standards (Article 5).
  • The Consumer Affairs Agency states that food labelling must be in Japanese when food is sold in Japan.
  • Eight specified ingredients must be labelled as allergens: shrimp, crab, walnut, wheat, buckwheat, egg, dairy products and peanut. Twenty more, from almond to gelatin, are recommended.
  • Food carries a use-by date (消費期限) where it may become unsafe after the date, or a best-before date (賞味期限) where quality declines slowly.
  • The nutrition label lists energy, protein, fat, carbohydrates and sodium, the last shown as salt equivalent.
  • Processed foods made in Japan list the country of origin of the main ingredient by weight; imported processed foods show the country of origin.

How we help: Compliant Always sets the Japanese label beside the particulars the Food Labelling Standards ask for, with the source for each, so the gaps are visible before a retailer or an inspector finds them. Ask about this

Additives, residues and standards

What may go into food, and the limits it has to meet.

  • Only additives designated by the Prime Minister as unlikely to harm human health may be used, besides existing food additives, natural flavouring agents and ordinary foods used as additives (Article 12 and the CAA's additives page).
  • Use standards, such as target foods and maximum use levels, apply to additives in each of those categories.
  • Since 29 May 2006 a positive list system has prohibited the distribution of food containing pesticides, feed additives or veterinary drugs above set levels where no maximum residue limit has been set.
  • Food or additives that do not meet standards set under Article 13 must not be produced, imported, processed or sold.
  • The Minister of Health, Labour and Welfare may prohibit the sale of things not generally eaten before that have not been shown to be unlikely to harm health (Article 7).
  • Responsibility for setting and evaluating food safety standards moved from MHLW to the Consumer Affairs Agency on 1 April 2024.

How we help: Compliant Always reads your recipe and specifications against the additive lists and use standards, and keeps the evidence for each ingredient with the product. Ask about this

Import notification and inspection

How food is checked when it comes into Japan.

  • Anyone importing food, additives, apparatus or containers and packaging for sale or business use must notify the Minister of Health, Labour and Welfare each time they import (Article 27).
  • The notification form goes to the MHLW quarantine station for the port of import; it can also be filed electronically once the importer's terminal is registered.
  • Food sanitation inspectors check the notification against the manufacturing standards, additive use, harmful substances and the manufacturer's past record, and may order an inspection of the cargo.
  • Meat and poultry products, milk and milk products, oysters for raw consumption and pufferfish need a health certificate issued by the exporting country's government.
  • Cargo that passes receives a certificate of notification; cargo that fails cannot be imported into Japan.
  • MHLW inspects imported food at quarantine stations at 32 airports and seaports under its yearly Imported Foods Monitoring and Guidance Plan.

How we help: Compliant Always keeps the specifications, ingredient lists and certificates an import notification draws on with the product, and shows what expires before the next shipment. Ask about this

Hygiene control and business licences

Who must hold a licence or notify, and the hygiene rules they work under.

  • Food business operators must endeavour to secure the safety of the food they handle on their own responsibility, including the safety of raw materials and voluntary inspections (Article 3).
  • Businesses follow criteria for general hygiene management and for controlling the processes particularly important for preventing food sanitation hazards (Article 51).
  • Businesses of a type listed by Cabinet Order, such as confectionery, soft drink, dairy product and ready-made dish production, need a licence from the prefectural governor (Article 55).
  • Other food businesses notify the prefectural governor in advance (Article 57); importing food or additives is listed as a business with minor impact on public health and is excluded.

How we help: Compliant Always keeps each manufacturer's licence and hygiene records with the products made there, dated, so a buyer's question is answered from the record. Ask about this

Claims and advertising

What a label or an advert may say about the food.

  • False or exaggerated labelling or advertising that is likely to harm public health may not be used for food (Food Sanitation Act, Article 20).
  • Representations about health effects that are significantly contrary to fact or misleading are prohibited when advertising food (Health Promotion Act, Article 65).
  • Only Foods for Specified Health Uses, Foods with Nutrient Function Claims and Foods with Function Claims may state a function of the food.
  • Representations that make goods look significantly better than they are are prohibited under the Act against Unjustifiable Premiums and Misleading Representations (Article 5).

How we help: Compliant Always reads your claims and marketing copy against the rules that apply, and keeps the evidence for each claim with the product. Ask about this

Recalls

What a business must report when it recalls food.

  • A business that recalls food because it breaches, or may breach, the Food Sanitation Act notifies the prefectural governor without delay of the recall and its progress (Article 58).
  • A business that recalls food because its labelling of allergens, expiry dates or other safety information is wrong notifies the Prime Minister without delay, and the recall is made public (Food Labelling Act, Article 10-2).
  • The CAA's recall site opened on 1 June 2021, and businesses notify voluntary recalls through the Food Sanitation Application System.

How we help: Compliant Always ties each document to the lot and supplier it came from, so the scope of a recall can be read from the record. Ask about this

Who answers for what

WhoWhat they answer forHow we help
ImporterThe import notification for each shipment, and food that meets the standards on arrival.Suppliers' specifications and certificates read and dated before the goods ship.
ManufacturerHygiene control, any licence its type of business needs, and what goes into the food.Specifications, test reports and licences kept with each product.
Brand or sellerSelling food labelled according to the Food Labelling Standards, and the claims it makes.The Japanese label checked against the particulars, with the paperwork behind it.
Overseas supplierInformation on ingredients, additives and methods the importer's notification relies on.Documents collected once and shown to each importer that asks.

National law, prefectural enforcement

Product law in Japan is national. Ministries and the Consumer Affairs Agency set the standards; prefectural governors and cities with public health centres license food businesses, receive food recall notifications and carry out inspections.

Imports are checked at the border: food and food contact articles at MHLW quarantine stations, and liquor licences are granted by the tax office for each place of sale.

Shipping out of Japan?

Exporting food from Japan

Questions businesses ask

Do food labels in Japan have to be in Japanese?
Yes. The Consumer Affairs Agency states that food labelling must be in Japanese when food is sold in Japan, following the Food Labelling Standards under the Food Labelling Act.
What must a food label in Japan show?
The Food Labelling Standards cover the name, allergens, storage method, use-by or best-before date, ingredients, additives, nutrition and energy, country of origin, and the business responsible, with rules on how each is shown (Food Labelling Act, Article 4).
Which allergens must be labelled in Japan?
Eight specified ingredients are mandatory: shrimp, crab, walnut, wheat, buckwheat, egg, dairy products and peanut. Twenty more, including almond, sesame, soybean, salmon, beef and gelatin, are recommended.
Do I need to notify the government each time I import food into Japan?
Yes. Article 27 of the Food Sanitation Act requires an import notification to the Minister of Health, Labour and Welfare for each import for sale or business use, filed at the MHLW quarantine station for the port.
Which imported foods need a health certificate?
Meat and poultry products, milk and milk products, oysters for raw consumption and pufferfish need a health certificate in the agreed format from the exporting country's government.
Are all food additives allowed in Japan?
No. Designated additives, existing food additives, natural flavouring agents and ordinary foods used as additives may be used, within any use standards set for them. Other additives may not.
Who sets food safety standards in Japan?
The Consumer Affairs Agency, since 1 April 2024, when standard setting and evaluation moved from MHLW. MHLW still runs import inspection at its quarantine stations.
Does a food importer need a business licence in Japan?
Importing food or additives is listed as a business with minor impact on public health and is excluded from the advance notification under Article 57. Manufacturing businesses of listed types need a prefectural licence under Article 55.
What must a business do when it recalls food in Japan?
Notify the prefectural governor of the recall and its progress where the food breaches the Food Sanitation Act, or the Prime Minister where the recall is for wrong allergen, expiry or other safety labelling.
Can a food label make a health claim in Japan?
Only Foods for Specified Health Uses, Foods with Nutrient Function Claims and Foods with Function Claims may state a function. Other foods may not show effects or functions.
How does Compliant Always help with selling in Japan?
Our team reads the rules for the markets you sell in, including the Japanese-language sources. Compliant Always shows which apply to your product, keeps the documents behind each one ready, and watches the sources for changes. It shows what the requirements say and what your documents show; you decide.

Sources

Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

Tell us what you make, and we will show you the rules for it.

Name the product and the markets you sell in. We will come back to you with what applies in Japan and what your paperwork needs to show.

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