Allergen Labeling for Imported Food — Japan-Specific Checks
Interlink編集部What Allergen Labeling Means
Allergen labeling is a system that requires information about food ingredients that cause allergies to be displayed on packaging or containers. This important labeling helps consumers with food allergies safely select products.
The Food Labeling Act and Food Labeling Standards specify which items require allergen labeling. Although the legal term used is "allergy labeling," in actual logistics practice it is often called "allergen labeling." In this article, both terms are treated as having the same meaning.
In the import food business, simply translating overseas labels or allergen charts from foreign manufacturers into Japanese may not be sufficient. It is necessary to check Japanese-required items, labeling methods, alternative expressions, expanded labeling, composite ingredients, processing aids, and contamination information, then reorganize that for labeling targeted at the Japanese market.
Scope Covered in This Article
Allergen labeling relates to the Food Labeling Act, Food Labeling Standards, Food Sanitation Act, import food operations, advertising regulations, and EC sales labeling, among others. This article primarily focuses on practical matters for allergen labeling needed when selling imported food in Japan. Nutritional labeling, ingredient origin labeling, and efficacy claims under the Pharmaceuticals and Medical Devices Act are covered in separate articles.
| Item | Content Covered in This Article | Details Covered in Other Articles |
|---|---|---|
| Basics of Allergen Labeling | Explains the system for labeling ingredients that cause food allergies so consumers can confirm them. | The overall structure of the food labeling system is covered in detail under the Food Labeling Act. |
| Target Items | Clarifies the difference between specified ingredients and those equivalent to specified ingredients, and summarizes target items as of April 2026. | Details and revision history of the Food Labeling Standards are covered in articles related to those standards. |
| Confirmation for Imported Foods | Covers raw material lists, allergen charts, manufacturing process information, and contamination information that should be obtained from overseas manufacturers. | Import food notifications, quarantine office reviews, and Food Sanitation Act checks are covered under Import Food Notification and Food Sanitation Act articles. |
| Composite Ingredients and Additive Sources | Addresses oversight of allergens contained in sauces, seasonings, flavorings, additives, and processing aids. | Regulatory details on additives are covered thoroughly under Food Additives. |
| Labeling Methods | Outlines individual labeling, collective labeling, alternative expressions, expanded labeling, and methods to prevent omissions. | Specific label layouts and other mandatory labeling items are covered in the Food Labeling Practicalities article. |
| Relationship with Advertising and EC Labeling | Discusses the basis for claims such as allergen-free, gluten-free, or dairy-free, and advertising precautions. | Misleading claims, efficacy claims under the Pharmaceuticals and Medical Devices Act, and functional food claims are treated in their respective regulatory articles. |
Purpose and Background of the System
The purpose of allergen labeling is to help consumers with food allergies avoid foods containing causative ingredients and safely choose products. Since food allergies can cause severe health damage even from small amounts, the accuracy of this labeling is especially important within food labeling.
The food labeling system defines "specified ingredients," which require mandatory labeling, as well as "ingredients equivalent to specified ingredients" for which labeling is recommended. Specified ingredients must be labeled if present.
For imported foods, the labeling systems of overseas manufacturers may not align with Japanese requirements. Some ingredients not requiring labeling abroad may require labeling in Japan. Even if overseas labels use broad terms like "nuts," "milk," or "flavor," individual verification and labeling by item are necessary for the Japanese market.
Situations Where the System Applies
Allergen labeling is especially important for packaged processed foods at the point of sale. For imported foods, allergen information must be accurately reflected on the Japanese domestic sales label, separate from import-stage Food Sanitation Act confirmations.
| Scenario | Commonly Relevant Food Products | Main Points of Verification | Practical Notes |
|---|---|---|---|
| When importing and selling processed foods | Confectionery, beverages, seasonings, frozen foods, retort pouch foods | Allergens in raw materials, additives, and composite raw materials | Check not only translations of overseas labels but also against Japan's applicable product categories. |
| When importing confectionery and chocolate | Chocolate, cookies, nut snacks, baked goods | Milk, wheat, eggs, nuts, peanuts, cashew nuts, pistachios | Be mindful of possible contamination from composite raw materials and production on the same line. |
| When importing health foods and supplements | Tablets, capsules, powders, protein powders, nutritional supplements | Gelatin, milk, soy, wheat, nuts, ingredients derived from additives | Verify not only food labeling but also advertising expressions under the Pharmaceutical and Medical Device Act. |
| When importing food for business use | Commercial sauces, seasonings, frozen ingredients, baking ingredients | Business-use labeling, allergen information transmission to delivery destinations | Information at the raw material stage is important because it affects final product labeling. |
| When selling via e-commerce sites | All imported foods, gift foods, subscription foods | Consistency between container/packaging labeling and web display | Check for inconsistencies on product pages, advertisements, and within images. |
| When making non-use or “free-from” claims | Gluten-free, dairy-free, egg-free, nut-free foods | Supporting documentation, manufacturing process control, contamination management | Ensure expressions do not cause consumers to overestimate safety. |
Classification of Applicable Products
For allergen labeling, separate the “Specified Ingredients” that require mandatory labeling from those “Equivalent to Specified Ingredients” for which labeling is recommended. As of the revision on April 1, 2026, cashew nuts have been added to the Specified Ingredients and pistachios to those equivalent.
| Category | Status | Applicable Items | Notes for Import Practice |
|---|---|---|---|
| Specified Ingredients | Mandatory Labeling | Shrimp, crab, walnut, wheat, buckwheat, egg, milk, peanut, cashew nut | If present, missing labeling is a serious issue. Confirm under Japanese standards even if not on overseas labels. |
| Equivalent to Specified Ingredients | Recommended Labeling | Almond, abalone, squid, salmon roe, orange, kiwi fruit, beef, sesame, salmon, mackerel, soy, chicken, banana, pistachio, pork, macadamia nut, peach, yam, apple, gelatin | Labeling is not mandatory but is generally required in practice as much as possible. Importers should decide labeling policy in advance. |
| Nuts | Handle each item separately | Walnut, peanut, cashew nut, almond, macadamia nut, pistachio, etc. | Overseas documents that refer to "nuts" collectively require detailed checks against each Japanese applicable item. |
| Milk, Egg, Wheat | Frequently found in processed foods | Milk components, eggs, wheat, bread crumbs, emulsifier-derived ingredients, modified starch, etc. | Confirm not only major raw materials but also composite raw materials and processing aids. |
| Marine and Livestock Derived | Origin confirmation of raw materials is important | Shrimp, crab, squid, salmon roe, salmon, mackerel, beef, chicken, pork, gelatin | Be careful not to overlook extracts, broths, seasonings, capsule materials, and gelatin origins. |
| Fruit and Plant Derived | Attention needed for seasonings, sweets, and beverages | Orange, kiwi fruit, banana, peach, apple, yam, sesame, soy | May be included in flavorings, purees, concentrated juices, seasonings, and sauces. |
Applicable Requirements and Common Exemptions
Whether allergen labeling is required is determined by whether the applicable items are contained in the food, whether it is sold as a processed food in packaging, and whether it falls under mandatory or recommended labeling. Items to be checked include not only those used directly as raw materials, but also composite raw materials, additives, processing aids, and carryovers.
| Category | Concepts That Often Require Label Confirmation | Concepts That Are Often Excluded or Require Separate Confirmation | Documents / Information to Check |
|---|---|---|---|
| Applicable Food Products | Items sold as processed foods in containers/packaging | Items where labeling obligations differ due to the system, such as dining out, face-to-face sales, or bulk sales | Sales format, packaging format, product labels, sales web pages |
| Use as Raw Material | Raw materials include specific allergenic ingredients or those equivalent to them | Items confirmed by documentation not to include targeted ingredients | Ingredient lists, formulation sheets, allergen tables |
| Compound Raw Materials | Items such as sauces, seasonings, mixed powders, flavor preparations containing targeted ingredients | Items where the breakdown of compound raw materials confirms no targeted ingredients | Breakdown of compound raw materials, raw material specifications, manufacturer certifications |
| Derived from Additives and Processing Aids | Additives or processing aids derived from milk, wheat, soybeans, gelatin, etc. | Items that are chemically refined and confirmed not to raise issues regarding labeling of derived allergens | Additive specification sheets, origin material documents, manufacturing process charts |
| Contamination | Handling of targeted ingredients in the same factory, production line, or shared equipment | Items not included as raw materials and where the possibility of contamination is reasonably low based on management | Manufacturing line information, cleaning procedures, allergen management tables |
| Advertising / Non-use Claims | Claims stating allergen non-use, gluten-free, milk-free, etc. | Cases where targeted ingredients are simply listed as part of ingredient labeling | Test reports, manufacturing process management, contamination management materials |
Comparison with Other Systems
Allergen labeling is a labeling system based on the Food Labeling Act and Food Labeling Standards. It differs in purpose from notifications under the Food Sanitation Act, approval of food additive use, nutritional labeling, functional labeling, advertising regulations under the Act against Unjustifiable Premiums and Misleading Representations, and the Pharmaceuticals and Medical Devices Act.
| System / Area of Confirmation | Main Purpose | Relationship to Allergen Labeling | Practical Considerations |
|---|---|---|---|
| Allergen Labeling | To enable consumers with food allergies to avoid allergenic raw materials | Displays information on the presence of specified raw materials and those equivalent to them. | Omissions in labeling may lead to health hazards or product recalls. |
| Food Labeling Act | Sets labeling standards necessary for food quality, hygiene, safety, and consumer choice | The legal basis that supports allergen labeling. | Must be aligned with ingredient names, additives, nutritional labeling, etc. |
| Food Sanitation Act | Handles food safety, standards, import notifications, and inspections | Besides import checks, allergen labeling is confirmed as part of sales labeling. | Passing the food import notification does not guarantee labeling is correct. |
| Food Additive Regulations | Confirms permissibility, usage standards, and specifications of additives | Origin materials of additives and processing aids may relate to allergen confirmation. | Verify not only the additive names but also their raw material origins and compound raw materials. |
| Act against Unjustifiable Premiums and Misleading Representations (Premiums & Representations Act) | Prevents misleading labeling and advertising that could deceive consumers | Non-use claims of allergens, gluten-free, safety, and security promotions may raise issues. | Avoid non-use claims without sufficient supporting documentation. |
| Pharmaceuticals and Medical Devices Act | Regulates labeling of medicinal effects and bodily impacts | Issues arise when expressing allergy improvement, immune system benefits, etc. | Separately verify food labeling and advertising claims. |
Concepts for Labeling Methods
Allergen labeling can be done individually within the ingredient list or collectively in a grouped manner. In actual labeling practice, verify ingredient names, additives, compound raw materials, alternative notations, and expanded labeling.
For imported foods, simply translating overseas labels may not be sufficient. What is generally standard overseas may not be adequate as allergen labeling under Japanese regulations. For example, broad terms like "tree nuts," "dairy," "gluten," or "seafood" need to be broken down into the specific targeted ingredients for Japanese compliance.
When verifying labeling methods, check not only the ingredient lists and allergen tables but also the breakdown of compound raw materials, origins of additives, use status of processing aids, and potential cross-contamination during manufacturing. When specific raw materials subject to labeling are included, it is important to confirm that they are correctly reflected on the final label, as labeling is mandatory in those cases.
System Application Flow
For allergen labeling confirmation, just checking the presence of targeted items is insufficient. By sequentially verifying raw materials, compound raw materials, additives, manufacturing processes, contamination, final labels, and advertising, omissions and inconsistencies in labeling can be prevented.
| Step | Check Points | Judgment Considerations | Next Actions |
|---|---|---|---|
| 1. Confirm Target Food | Is it sold as a processed food in container packaging? | The labeling obligation treatment may vary depending on the sales format. | Check product form, sales method, and packaging type. |
| 2. Confirm Target Items | Does it include specified raw materials or items equivalent to specified raw materials? | Check against the target items as of April 2026. | Obtain ingredient lists, allergen lists, and composition tables. |
| 3. Confirm Composite Ingredients | Breakdown of sauces, seasonings, mixed powders, flavorings, etc. | The ingredient list of the final product alone may be insufficient. | Obtain specifications and breakdown materials for composite ingredients. |
| 4. Confirm Manufacturing Process & Contamination | Same factory, same line, shared equipment, cleaning management | Understand the possibility of unintended contamination. | Review manufacturing line information, allergen management sheets, and cleaning procedures. |
| 5. Reflect in Japanese Label Proposal | Consistency of individual labeling, collective labeling, alternative expressions, and enlarged labeling | Check if the label complies with Japan’s food labeling standards. | Verify label drafts, ingredient name sections, and additive sections. |
| 6. Consistency with EC & Advertising Displays | Labels on product pages, advertisements, pamphlets, and in-store POP | Check for discrepancies between container packaging and sales displays. | Organize reference materials for “not used” or “free from” claims. |
Common Misunderstandings
With allergen labeling, misunderstandings often arise such as believing it is sufficient to simply translate the information shown on overseas labels, that only major ingredients need to be checked, or that labeling “not used” ensures safety. For imported foods, reconfirmation to align with Japan’s system is necessary.
| Common Misunderstanding | Actual Consideration | Practical Points to Note |
|---|---|---|
| Translating overseas labels creates compliant Japanese labeling | Overseas and Japanese systems may differ in target items and labeling methods. | Check against Japan’s specified raw materials and equivalent items. |
| Only major ingredients need to be checked | Composite ingredients, additives, flavorings, processing aids, and carry-overs may also need checking. | Confirm the breakdown of sauces, seasonings, mixed powders, capsule materials, etc. |
| Nuts can be checked collectively | Walnuts, peanuts, cashews, almonds, macadamias, pistachios, etc., are handled individually. | Break down overseas “nuts” data by Japan’s specific items. |
| Items recommended for labeling do not need confirmation | Items equivalent to specified raw materials are not mandatory to label but practical business asks for labeling as much as possible. | Confirm importer’s labeling policy and sales destination requirements in advance. |
| If not in ingredients, contamination possibility can be ignored | Contamination may occur at same factory, line, or shared equipment. | Check manufacturing process information, cleaning management, and allergen control sheets. |
| Gluten-free or dairy-free claims can be used freely | Claims of “not used” or “free from” require supporting documents and management practices. | Unsupported safety claims may lead to issues under the Act against Unjustifiable Premiums and Misleading Representations. |
Cases Commonly Problematic in Practice
Allergen labeling often becomes problematic when overseas manufacturer materials do not align with Japan’s labeling target items. Even if importers have received overseas labels, product specifications, and allergen lists, lack of composite ingredient breakdowns or manufacturing line details can prevent creation of proper Japanese labels.
| Case | Common Issues | Documents to Check | Practical Points to Note |
|---|---|---|---|
| Imported Confectionery | Milk, wheat, eggs, nuts are included in multiple ingredients | Ingredient lists, allergen lists, composite ingredient breakdowns, manufacturing line info | Break down and check chocolate, cream, cookie dough, nut-processed items. |
| Nut-containing Foods | Overseas materials group “nuts” without individual item verification | Nut item lists, raw material specifications, composition tables, manufacturer certifications | Individually check cashews, pistachios, walnuts, peanuts, etc. |
| Commercial Seasonings | Wheat, soy, milk, seafood-derived components may be included in seasonings and flavorings | Seasoning specs, flavoring data, additive documents, origin ingredient data | The final product’s ingredient list alone is insufficient. |
| Health Foods & Supplements | Gelatin, milk, soy, wheat, capsule materials, excipients origins unknown | Composition tables, formulation sheets, capsule material documents, additive specs | Check not only food labeling but also Pharmaceutical and Medical Device Act and advertising expression. |
| Gluten-free Claims | Overseas standards used directly for Japanese labeling | Inspection reports, manufacturing process sheets, contamination control documents | Avoid free-from claims without supporting documentation. |
| EC Label and Label Discrepancies | Mismatch of allergen information between container packaging and web product pages | Label drafts, product pages, advertisement drafts, sales materials | Confirm alignment between labeling media before sales. |
4-Column Judgment Checklist
In checking allergen labeling, the parties and the points to be confirmed differ before import, when creating labels, before sales, and when preparing advertisements. It is important to organize information not only among the food labeling personnel but also among the importer, overseas manufacturer, customs broker, and sales representatives.
| Confirmation Stage | Party to Confirm With | Points to Confirm | Actions if Issues Are Found |
|---|---|---|---|
| Product Selection | Importer / Sales Representative | Target food, sales format, plan to indicate allergen non-use | If non-use labeling is planned, first confirm whether supporting documents are available. |
| Before Shipment | Overseas Manufacturer / Exporter | Ingredient list, allergen list, breakdown of compound ingredients, manufacturing process information | If documentation is insufficient, obtain additional materials before shipment. |
| When Creating Japanese Labels | Importer / Labeling Personnel | Specified ingredients, equivalent items, individual labeling, collective labeling, alternative expressions | Revise the labeling draft to comply with Japan’s food labeling standards. |
| Contamination Check | Manufacturer / Quality Control Personnel | Same factory, same production line, shared equipment, cleaning management, likelihood of contamination | Consider the need for cautionary labeling or sales policy adjustments. |
| When Creating EC or Advertising Materials | Sales Representative / Advertising Personnel | Consistency between product page, advertisements, POP displays, pamphlets, and label indications | If discrepancies exist, corrections should be made before sales. |
| When Labeling Defects Are Found | Importer / Sales Destination / Administrative Consultation Contact | Target lot, sales range, presence or absence of health damage, need for recall | Consider sales suspension, correction labeling, recall, and notifying business partners. |
Comparison Table of Forwarders’ Involvement Scope
Freight forwarders and customs brokers are not in a position to make the final judgment on the legality of allergen labeling. However, in actual import food customs clearance and delivery operations, lack of ingredient lists and allergen information required for label creation may affect delivery schedules. It is important to check early on whether necessary documents are available and alert the importer as needed.
| Category | What Can Be Supported | What Should Not Be Conclusively Determined | Practical Response |
|---|---|---|---|
| Understanding Target Foods | Identify cargos, such as processed foods, confectionery, or health foods, where allergen checks are likely needed | Independently conclude that allergen labeling is unnecessary | Confirm with the importer the status of acquiring ingredient and allergen lists. |
| Alerting About Document Acquisition | Advise obtaining ingredient lists, allergen tables, and manufacturing process information from overseas manufacturers | Guarantee that having documentation automatically ensures legal labeling | Organize labeling decisions as matters to be confirmed by importers, labeling personnel, and experts. |
| Delivery Schedule Management | Share the possibility that label revisions or additional checks may delay delivery | Promise sales according to schedule without confirming food labeling | Set a buffer schedule for initial imports or items with labeling changes. |
| Consistency with Import Documentation | Warn about discrepancies between import declaration documents and sales label materials | Finalize labeling solely based on declared documents without further verification | Confirm consistency among ingredient lists, composition tables, and labeling drafts with the importer. |
| Alerting for Advertising and EC Labels | Communicate the risk that container/packaging labels and EC labels may be managed separately | Firmly determine the legality of advertising expressions or non-use labeling | Encourage confirmation by sales and labeling personnel. |
| Logistics Response to Labeling Defects | Organize logistics information related to sales suspension, shipment suspension, inventory holds, returns, and recalls | Unilaterally decide on recall necessity or legal responsibility | Carry out logistics responses based on decisions from importers, sales destinations, and specialists. |
Typical Situations Where the Regulations Become a Problem
The typical situation where allergen labeling becomes problematic is during the process of converting overseas manufacturer information into labels for Japan. If there are discrepancies among overseas labels, product specification sheets, allergen tables, EC labels, and advertising expressions, it could lead to omissions or misrepresentations in labeling.
| Typical Situations | Common Issues | Parties / Documents to Check | Practical Actions |
|---|---|---|---|
| Overseas label lacks allergens section | Cannot verify against Japan's targeted items | Overseas manufacturer, raw material lists, allergen lists, manufacturing process charts | Specify the required targeted items for Japan and verify accordingly. |
| Unclear breakdown of composite raw materials | Overlooking allergens contained within sauces or seasonings | Composite raw material specification sheets, raw material maker data, formulation charts | Confirm not only the final product but also down to individual raw materials. |
| Generalized labeling of nuts | Cannot distinguish cashew nuts, pistachios, walnuts, peanuts, etc. | Nut raw material specifications, allergen lists, manufacturer certifications | Check separately for each Japanese targeted item. |
| Claims of non-use labeling | Confusion between non-use of raw materials and contamination risk management | Inspection certificates, manufacturing line information, cleaning procedures, control records | Avoid non-use claims when the basis for the claim is insufficient. |
| EC labeling prepared by a different department | Product pages and actual container/package labels do not match | Label drafts, product pages, advertising drafts, sales materials | Conduct centralized verification of labeling information before public release. |
| Not reflecting target items after regulatory revisions | Preparing label drafts based on outdated lists, overlooking cashews or pistachios | Latest target item lists, raw material tables, label drafts | Reconfirm based on the revised list of specified raw materials and equivalents. |
Scenario 1: Selling Imported Nut-Containing Confectionery
For overseas-made chocolates or cookies, sometimes the ingredients list only states "nuts." However, in Japan's allergen labeling, each item such as walnuts, peanuts, cashew nuts, almonds, macadamia nuts, and pistachios is treated differently for labeling purposes.
In this case, the importer confirms with the overseas manufacturer the specific types of nuts used. Cashew nuts have been added to the specified raw materials list, and walnuts and peanuts are also mandatory labeling targets. On the other hand, almonds, macadamia nuts, and pistachios are treated as materials equivalent to the specified raw materials.
In practice, simply translating "nuts" on the overseas label as "nut varieties" is insufficient. It is important to break down the items according to Japan's targeted items and correctly reflect them on Japanese labels, EC displays, and advertising.
Scenario 2: Importing Seasonings for Commercial Use
Commercial seasonings, sauces, and flavorings may only list ingredients like "seasoning," "flavor," or "seasoning mix" without showing the details of included allergens such as wheat, soy, milk, or seafood-derived ingredients.
In this case, the importer obtains from the seasoning manufacturer or raw material maker the breakdown of the composite raw materials, allergen information, origins of additives, and manufacturing process details. For commercial-use raw materials, this information is used by the final product manufacturer to create consumer-facing labeling, so accuracy in communication is critical.
Freight forwarders and customs brokers can effectively check with importers not only that seasonings are handled as mere food ingredients but also whether the necessary information for label creation is complete. If documentation is insufficient, preparation for sales may be delayed after customs clearance.
Scenario 3: Imported Food with Gluten-Free Labeling
When selling foods labeled "gluten free" overseas in Japan, the overseas gluten-free designation cannot automatically be used in Japan’s advertising. Even if the labeling complies with overseas standards, it is necessary to check how it may be perceived by consumers in Japan and whether there is supporting evidence.
Here, the importer checks ingredient lists, manufacturing process details, inspection certificates, and contamination control documents. It includes verifying not only that wheat is not an ingredient but also whether wheat is handled on the same production line or factory, and how cleaning is managed.
Labels such as "gluten free," "wheat-free," or "allergen-free" are important information consumers rely on for safety assessment. Displaying such claims without sufficient supporting documents may lead to issues under Japan’s Food Labeling Act and the Act against Unjustifiable Premiums and Misleading Representations, so organizing evidence before labeling is essential.
Relation to Advertising and Sales Displays
Allergen labeling needs attention not only on containers and packaging but also on product descriptions on e-commerce sites, brochures, in-store POP, SNS advertisements, and sales materials. Even if container and packaging labeling is correct, inconsistent expressions on product pages or advertisements could mislead consumers.
When making claims such as "allergen-free," "gluten-free," "milk-free," "egg-free," or "nut-free," it is necessary to confirm not only the absence of these ingredients but also cross-contamination risks during manufacturing, inspection certificates, control records, and supplier certifications.
Discrepancies with actual facts or exaggerating safety to consumers could cause problems under the Food Labeling Act and the Act against Unjustifiable Premiums and Misleading Representations, especially in imported foods. It is important not to directly reuse overseas manufacturer explanations or overseas labeling as Japanese advertising content.
Documents Importers and Sellers Should Prepare
To accurately display allergens, it is necessary to obtain the required documents from overseas manufacturers before import and put the information into a state usable for labeling in Japan. Incorrect labeling could lead to health damage, sales suspension, recalls, and issues with business partners, so allergen labeling demands especially careful verification within food labeling.
| Documentation | Information that can be confirmed | Main source | Impact if missing |
|---|---|---|---|
| Raw Materials List | Whether the raw materials contained in the food include the relevant items | Overseas manufacturer, exporter | Basic allergen verification cannot be performed. |
| Allergen List | Presence of raw materials corresponding to specified allergens and equivalent substances | Overseas manufacturer, quality control department | If not aligned with Japanese specified items, reconfirmation is necessary. |
| Breakdown of Composite Raw Materials | Internal composition such as sauces, seasonings, flavorings, mixed powders | Raw material manufacturer, producer | Final product alone could result in omissions in labeling. |
| Manufacturing Process Chart | Production lines, shared equipment, potential contamination during processing | Manufacturer | Verification of contamination becomes difficult. |
| Contamination Control Documents | Handling of relevant items in the same factory/line, cleaning management | Manufacturer, quality control department | Judgment of cautionary or non-use statements becomes challenging. |
| Inspection Results / Manufacturer’s Certificate | Basis for non-use or free-from declarations and the management status | Testing institution, manufacturer | Supporting evidence for advertising and sales claims may be insufficient. |
Summary
Allergen labeling is an important system designed to accurately convey to consumers whether food contains ingredients that can cause food allergies. Specified allergens are subject to mandatory labeling, while substances equivalent to specified allergens are recommended for labeling.
As of April 2026, the specified allergens are nine items: shrimp, crab, walnut, wheat, buckwheat, egg, milk, peanut, and cashew nut. The substances equivalent to specified allergens comprise 20 items: almond, abalone, squid, salmon roe, orange, kiwi fruit, beef, sesame, salmon, mackerel, soy, chicken, banana, pistachio, pork, macadamia nut, peach, yam, apple, and gelatin.
For imported foods, simply translating overseas labels is insufficient. It is necessary to check raw materials, composite raw materials, additives, processing aids, and contamination information, and create labeling that complies with Japanese food labeling standards. Inadequate allergen labeling can lead to health hazards, suspension of sales, product recalls, and advertising issues, making the verification of documentation and management of labeling consistency prior to import essential.
