Country of Origin Labeling for Raw Materials
Interlink編集部What is Raw Material Origin Labeling
Raw material origin labeling is a system that indicates the origin or place of manufacture of the raw materials used in processed foods. This labeling allows consumers to verify the source of food ingredients and make informed product choices.
In food labeling practice, it is necessary to check which products are subject to labeling, which raw materials require labeling, and the allowable labeling methods based on the Food Labeling Act and Food Labeling Standards. For processed foods, special attention should be paid to whether the products are domestically manufactured or imported, whether the targeted raw materials are fresh foods or processed foods, and their weight ratios and labeling methods.
In import food operations, it is important not to confuse the "raw material origin labeling" required for domestically manufactured and processed foods with the "country of origin labeling" required for processed foods manufactured overseas. Different labeling requirements apply when selling imported foods as they are in Japan versus manufacturing processed foods domestically using imported raw materials.
Scope of This Article
Raw material origin labeling is related to the Food Labeling Act, Food Labeling Standards, country of origin labeling, misleading advertising regulations, import food operations, and e-commerce sales labeling. This article mainly covers raw material origin labeling for domestically manufactured processed foods. Topics such as country of origin labeling for imported processed foods, nutritional labeling, allergen labeling, and import notifications under the Food Sanitation Act are addressed in related articles.
| Item | Content Covered in This Article | Content Covered in Other Articles |
|---|---|---|
| Basics of Raw Material Origin Labeling | Organizes the system for indicating the origin or place of manufacture of targeted raw materials in processed foods manufactured and processed domestically. | The overall structure of the food labeling system is addressed in detail under the "Food Labeling Act". |
| Target Foods | Explains that processed foods manufactured or processed domestically are the target for labeling. | Country of origin labeling required for imported processed foods themselves is covered in detail under "Country of Origin Labeling". |
| Target Raw Materials | Focuses on the principle of identifying the raw material that accounts for the largest weight percentage in the product. | Specific rules and exceptions for individual items are discussed in articles related to the Food Labeling Standards. |
| Labeling Methods | Organizes information on origin labeling, place of manufacture labeling, indication by country weight order, "or" labeling, and broad category labeling. | Specific label layouts and other mandatory labeling items are dealt with in food labeling practice articles. |
| Import Food Practice | Clarifies the differences between imported processed foods and domestically manufactured products using imported raw materials. | Food import notification, quarantine inspection, and confirmation under the Food Sanitation Act are covered under "Import Food Notification" and "Food Sanitation Act". |
| Advertising and Sales Labeling | Addresses considerations when promoting domestic raw materials, specific production areas, or domestic manufacturing. | Advertising that falsely implies superior quality is covered in detail under "Misleading Advertising". |
Purpose and Background of the System
The purpose of raw material origin labeling is to enable consumers to verify the origin of major raw materials used in processed foods. Unlike fresh foods, processed foods make it difficult to judge the origin or place of manufacture of their ingredients just by appearance of the final product, so labeling provides consumers with necessary information for their choices.
In processed foods, even products with the same name may have differing raw material origins depending on the product batch or timing. Additionally, labeling content changes depending on whether the raw materials are fresh or processed foods. Therefore, accurate understanding of the nature of target raw materials and procurement conditions is essential for raw material origin labeling.
In import practice, it is important to clearly distinguish cases where processed foods are imported as finished products versus cases where foreign raw materials are processed domestically and sold. The former focuses on country of origin labeling for the product itself, while the latter involves raw material origin labeling for domestically manufactured processed foods.
Situations Where the System Applies
Raw material origin labeling applies to processed foods manufactured or processed domestically. Importers, domestic manufacturers, and sellers should first determine whether the product is domestically manufactured or an imported processed food, then confirm the target raw materials and labeling methods accordingly.
| Scenario | Typical Food Items | Main Focus of Confirmation | Practical Notes |
|---|---|---|---|
| When manufacturing processed foods domestically | Deli foods, confectionery, seasonings, beverages, frozen foods, retort pouch foods | The raw material with the highest weight ratio and its origin or place of manufacture | Identify the target raw materials at the product design stage. |
| When manufacturing domestically using imported raw materials | Beverages made with imported fruit juice, processed products made with imported meat, foods made with imported wheat | The origin of the target raw materials; for processed food raw materials, the place of manufacture | Obtain not only import documentation but also materials required for labeling after domestic manufacture. |
| When importing and selling overseas manufactured processed foods | Imported confectionery, imported beverages, imported seasonings, imported frozen foods | Country of origin labeling as the country of import, not raw material origin labeling | Be careful not to confuse raw material origin labeling with country of origin labeling. |
| When the source of raw materials fluctuates | Wheat, fruit juice, meat, seafood, vegetable paste, seasoning ingredients | Whether listing by country by weight order, or using “or” notation, or aggregated labeling is permitted | Supporting documents such as past usage records and usage plans are required. |
| When emphasizing production area in advertising | Products promoting domestic raw materials, Hokkaido origin, European raw materials, or domestic manufacture | Consistency between container/package labeling and advertising expressions | Care should be taken not to represent the origin of only some raw materials as a characteristic of the entire product. |
| When selling Private Brand (PB) or OEM products | Retail PB, outsourced manufactured products, co-developed products | Raw material information from the manufacturer, labeling responsible party, retention of supporting documents | A system is needed so that the seller can explain the basis for labeling. |
Target Foods and Raw Materials
Raw material origin labeling applies to processed foods manufactured or processed domestically. As a rule, the origin or place of manufacture of the raw material with the highest weight percentage in the product is displayed.
However, for food categories and items with existing separate rules, it is necessary to check individual labeling methods based on the Food Labeling Standards. Therefore, it is important not to oversimplify by thinking “only the top raw material by weight in domestically manufactured processed foods needs to be checked” but also to verify the labeling rules for each product classification.
On the other hand, for imported processed foods themselves, country of origin labeling as an imported product is required instead of raw material origin labeling. This is an item that can easily be confused in actual logistics practice dealing with imported foods.
Application Requirements and Items Often Exempted
When verifying raw material origin labeling, first confirm whether the target food is a processed food manufactured or processed domestically. Then clarify whether the target raw materials are fresh foods or processed foods, and whether to label origin or place of manufacture.
| Category | Typical Cases Where Raw Material Origin Labeling May Be Required | Cases Often Exempted or Requiring Separate Checks | Documents/Information to Confirm |
|---|---|---|---|
| Processed foods manufactured domestically | Products sold as processed foods manufactured or processed domestically | Processed foods manufactured overseas and imported for sale as-is | Place of manufacture, processing location, product specifications, manufacturing process |
| Imported processed foods | If additional processing and resale as different processed foods occur domestically, labeling may be required | When selling imported processed foods as-is, country of origin labeling is primary | Country of origin, country of manufacture, presence or absence of domestic processing, sales form |
| Target raw materials | As a general rule, the raw material with the highest weight proportion in the product | Foods with specific rules or where labeling omission is allowed | Formulation charts, raw material specification sheets, weight ratio data |
| Fresh food raw materials | When fresh foods such as meat, fish, vegetables, fruits, rice, wheat are target raw materials | Those to be treated as processed food raw materials | Origin certificates, supplier information, raw material specification sheets |
| Processed food raw materials | When target raw materials include fruit juice, paste, powder, sauce, seasoning ingredients | Cases where raw materials of raw materials are excluded from labeling | Place of manufacture data, manufacturer information, raw material specification sheets |
| Advertising and voluntary labeling | When emphasizing domestic raw materials, specific origins, domestic manufacture, etc. | Separately confirming advertising and voluntary labeling apart from mandatory labeling | Advertising drafts, e-commerce labeling, origin certificates, formulation ratio data |
Concepts for Labeling Methods
If the target raw material is a fresh food, indicate the origin such as “Domestic” or “Product of the USA.” If the target raw material is a processed food, display the place of manufacture such as “Manufactured in Japan” or “Manufactured in France.”
When there are multiple origins for the target raw materials, in principle, indicate the country names in descending order of weight ratio used. This is called listing by country by weight order. When the source countries of raw materials fluctuate making weight order listing difficult, under certain conditions, “or” notation or aggregated labeling may be permitted.
These labeling methods are not freely selectable. Supporting documentation such as past usage and usage plans is required. Actual labeling needs to be checked according to the Food Labeling Standards to confirm whether country by weight, “or” notation, aggregated labeling, or combined aggregated and “or” notation is allowed.
| Display Method | Meaning | Common Usage Scenes | Practical Points of Attention |
|---|---|---|---|
| Country of Origin Display | Displayed when the target raw materials are fresh foods, indicating their country of origin. | Processed foods using meat, fish, vegetables, fruits, rice, wheat, etc. | Confirm the origin of the target raw materials, such as "domestically produced" or "from the USA." |
| Manufacturing Location Display | Displayed when the target raw materials are processed foods, indicating their place of manufacture. | Processed foods using fruit juice, paste, powder, sauce, seasoning ingredients, etc. | Confirm the manufacturing location of the target raw material, not the origin of the raw material’s raw material. |
| Display by Country Weight Order | Displays country names in order of descending weight proportion used. | When there are multiple procurement countries and weight order can be identified. | Consistency is required with usage records, formulation records, and purchase records. |
| “Or” Display | Displays possible countries of origin connected by “or”. | When procurement sources for raw materials fluctuate and weight order display is difficult. | Documentation supporting possibility of use and actual use records is necessary. |
| Grouped Display | Combines three or more foreign countries of origin into “imported.” | When multiple foreign raw materials are used and individual country name display is difficult. | This is not a freely usable simplified display; conditions and supporting documentation are required. |
| Combination of Grouped Display and “Or” Display | A display combining multiple methods, such as “imported or domestic.” | When domestic raw materials and multiple foreign raw materials fluctuate. | Management of actual procurement status and correspondence to the display is necessary. |
Points of Attention in Imported Food Handling
When importing processed foods manufactured overseas to Japan for sale, the product must display the country of origin. For example, for imported confectionery, beverages, seasonings, frozen foods, etc., the origin of the product itself is confirmed rather than the origin of the raw materials.
On the other hand, when imported raw materials are processed domestically and sold as domestically manufactured processed foods, confirmation of raw material country of origin display may be necessary. For example, for foods produced domestically using imported raw materials, the country of origin or manufacturing location of the target raw materials becomes relevant.
Importers and domestic manufacturers need to obtain in advance overseas manufacturers’ specifications, raw material lists, manufacturing country information, certificates of origin, and other documentation, to confirm information required for labeling for the Japanese market. It is important to separately manage documents required under the Food Sanitation Act at import and raw material country of origin information needed for sales labeling, as their purposes differ.
Comparison with Other Systems
Raw material country of origin display indicates the origin of ingredients used in processed foods. This is different from the country of origin of the food itself, ingredient names, nutritional content, allergens, expiration dates, or origin claims in advertising, each of which serves a different verification purpose.
| System/Display | Main Purpose | Difference from Raw Material Country of Origin Display | Practical Points of Attention |
|---|---|---|---|
| Raw Material Country of Origin Display | For domestically manufactured processed foods, displays the origin or manufacturing location of the target raw materials. | Indicates the origin of the raw materials used in the processed food, not the product itself. | Separate domestically manufactured products from imports initially. |
| Country of Origin Display | For imported processed foods, indicates the country from which the product was imported. | Shows the country of the imported processed food itself. | For imported products, confirm country of origin display rather than raw material country of origin display. |
| Ingredient Name Display | Displays the names of raw materials used in the food. | Shows the names of ingredients and differs from origin or manufacturing location in purpose. | If raw material country of origin is shown alongside ingredient names, check consistency. |
| Nutritional Information Display | Displays energy, protein, fat, carbohydrates, salt equivalent, etc. | Indicates nutritional content, not raw material origin. | Do not confuse origin claims with nutritional or health benefit claims. |
| Allergen Display | Indicates presence or absence of ingredients causing food allergies. | For health hazard prevention, separate from origin information. | Confirm origin and allergen information separately even for the same raw material. |
| Misleading Superior Quality Claims | Prevents claims that misleadingly suggest superior quality. | Relevant when advertisements or sales displays overemphasize origin, domestic production, or high quality. | Even if mandatory displays are correct, advertisements may cause misunderstanding. |
Application Flow of the System
In confirming raw material country of origin display, first distinguish whether the product is a domestically manufactured processed food or an imported processed food. Then, sequentially confirm the target raw materials, nature of the raw materials, country of origin or manufacturing location, display method, and supporting documentation.
| Step | Items to Check | How to Decide | Next Actions |
|---|---|---|---|
| 1. Confirm Product Category | Whether it is domestically manufactured processed food or imported processed food | If domestically manufactured, check for raw material origin labeling; if imported processed food, check for country of origin labeling. | Verify country of manufacture, processing location, and whether there is domestic processing. |
| 2. Identify Target Raw Materials | Raw material with the highest weight ratio, presence of item-specific rules | Generally, the top raw material by weight ratio, but confirm item-specific rules as well. | Review formulation sheets, raw material specifications, product classification. |
| 3. Confirm Nature of Raw Materials | Whether the target raw materials are fresh foods or processed foods | If fresh foods, label the origin; if processed foods, label the manufacturing location. | Check raw material specification sheets, manufacturer information, procurement documents. |
| 4. Choose Labeling Method | Country-by-weight order labeling, or "or" labeling, broad categorization labeling, combined labeling | Determine labeling method based on procurement realities and supporting documents. | Organize usage records, usage plans, procurement records. |
| 5. Reflect on Label Draft | Raw material name column, raw material origin name, display position, wording | Create labeling draft in accordance with food labeling standards. | Confirm consistency with other labeling items. |
| 6. Consistency with Advertising and E-commerce Labeling | Origin expressions on product pages, ads, brochures, in-store POP | Check that container/packaging labels and advertising expressions do not contradict each other. | Adjust any excessive emphasis on origin claims. |
Common Misunderstandings
There are frequent misunderstandings such as the assumption that raw material origin labeling is required for imported processed foods, that checking only the top weight ratio raw material is always sufficient, or that "or" labeling and broad categorization labeling can be freely used. In practice, product category, target raw materials, labeling method, and supporting documents need to be checked separately.
| Common Misunderstanding | Actual Approach | Practical Notes |
|---|---|---|
| Raw material origin labeling is required even for imported processed foods | Imported processed foods themselves require country of origin labeling, not raw material origin labeling. | First, distinguish whether it is an imported product or domestically manufactured. |
| If domestically manufactured, checking only the #1 raw material by weight is always sufficient | The principle is the raw material with the highest weight ratio, but some food items have specific rules. | Check labeling rules according to product classification. |
| Display the origin of raw materials of processed raw materials as well | If the target raw material is processed food, the manufacturing location of that processed food should be labeled in principle. | Avoid confusing origin labeling with manufacturing location labeling. |
| "Or" labeling and broad categorization labeling can be freely chosen | These labeling methods have conditions, and require supporting documents such as usage records and usage plans. | Confirm procurement realities before selecting labeling methods. |
| If the label is correct, it is acceptable to emphasize origin in advertising | If advertising gives a better impression than actual, it may be considered misleading advertising. | Ensure consistency between container/packaging labels and e-commerce pages or ads. |
| Foreign manufacturer specifications are sufficient as labeling evidence | The specification content needs to explain origin, manufacturing location, and weight ratio required for Japanese labeling. | Check whether the materials can be used for labeling aimed at the Japanese market. |
Cases That Often Cause Issues in Practice
Common issues with raw material origin labeling arise when the distinction between imported and domestically manufactured products is unclear, weight ratios of target raw materials cannot be confirmed, or supporting documents for "or" labeling or broad categorization labeling are insufficient. Especially when producing processed foods domestically using imported raw materials, documents obtained at import may be insufficient for labeling creation.
| Case | Likely Issues | Documents to Check | Practical Notes |
|---|---|---|---|
| Selling imported processed foods as-is | Confusing raw material origin labeling with country of origin labeling | Country of manufacture information, import documents, product specifications, label drafts | Focus on checking country of origin labeling for imports. |
| Manufacturing domestically using imported raw materials | Insufficient origin or manufacturing location information for target raw materials | Raw material specifications, origin certificates, manufacturing location data, formulation sheets | Obtain information required for labeling after domestic manufacturing before shipment. |
| Raw material procurement country fluctuates | Country-by-weight order labeling does not match actual usage | Procurement records, usage records, usage plans, formulation records | Align labeling method with actual procurement management. |
| Target raw materials are processed foods | Misunderstanding whether to display origin of raw materials of these processed raw materials | Manufacturing location, manufacturer information, specifications of processed food raw materials | Confirm manufacturing location of target raw materials as a principle. |
| Emphasizing origin in advertising | Presenting origin of some raw materials as a characteristic of the entire product | Advertisement drafts, formulation ratios, origin certificates, container/packaging labels | Check that advertising does not mislead consumers. |
| Sales of OEM / Private Brand products | Seller unaware of labeling evidence | Manufacturer's data, labeling evidence documents, specifications, contracts | Establish a system where the person responsible for labeling can explain the evidence. |
4-Column Decision Checklist
When verifying the indication of the origin of raw materials, the parties to be checked differ at each stage of product planning, raw material procurement, manufacturing, label creation, and advertising creation. It is necessary to organize information not only among those responsible for labeling but also among importers, manufacturers, raw material suppliers, and sales personnel.
| Verification Stage | Parties to Confirm With | Points to Confirm | Actions if Issues Arise |
|---|---|---|---|
| During Product Planning | Importers, Manufacturers, Sales Personnel | Whether the product is domestically manufactured or an imported processed food, whether to appeal the origin | Confirm at the product design stage to avoid misclassification of labeling categories. |
| When Procuring Raw Materials | Raw Material Suppliers, Overseas Manufacturers | Origin of the raw materials concerned, place of manufacture, procurement country, possibility of changes | Obtain specification sheets, origin certificates, and usage plans. |
| During Blend Confirmation | Manufacturers, Quality Control Personnel | The raw material with the highest weight ratio, presence of individual rules | Confirm the blend sheet and product classification to finalize the raw materials concerned. |
| When Selecting the Labeling Method | Labeling Personnel, Quality Control Personnel | Whether to list by country in order of weight, use “Or,” or use broad category labeling | Organize usage records and usage plans as supporting documents. |
| At Label Creation | Labeling Personnel, Manufacturers, Sellers | The raw material name field, confusion with the name of the raw material origin or country of origin, consistency with other labels | Revise the label draft according to food labeling standards. |
| When Creating Advertisement and EC Display | Sales Personnel, Advertising Personnel | Expressions emphasizing domestic production, specific regions, or domestic manufacturing | Compare the container/packaging labels with advertisements to avoid exaggerated expressions. |
Comparison Table of Freight Forwarder Involvement
Freight forwarders and customs brokers are not in a position to make the final judgment on the legality of raw material origin labeling. However, when handling imported raw materials or imported processed foods, documentation such as country of origin, country of manufacture, origin certificates, and specification sheets could affect the labeling creation and sales start schedule.
| Category | Support They Can Provide | What They Should NOT Decide | Practical Response |
|---|---|---|---|
| Verification of Import Product Classification | Confirm with the shipper whether it is a finished import product or raw materials for domestic manufacturing | Unilaterally decide whether raw material origin labeling is required | Encourage the seller and labeling personnel to perform the confirmation. |
| Calling Attention to Document Acquisition | Inform that documents such as country of origin, place of manufacture, origin certificates, and specification sheets may be needed | Guarantee that labeling will definitely be legal if such documents are available | The importer side should verify whether the documents can serve as labeling evidence. |
| Checking Consistency with Import Documents | Advise caution regarding country names on invoices, packing lists, and certificates of origin | Determine the sales label solely based on the country names in import documents | Separately organize the country of manufacture, country of origin, and raw material origin. |
| Managing Sales Start Schedule | Share the possibility that label confirmation and label correction could affect delivery schedules | Promise that sales can proceed as planned without label confirmation | Account for a labeling confirmation period especially for first-time imports or private brand products. |
| Calling Attention to Advertising Claims | Inform about the potential need for supporting documents when emphasizing domestic production, specific regions, or domestic manufacturing | Judge that advertising claims do not constitute misleading or deceptive representation | Refer the matter for verification by sales personnel, labeling personnel, or specialists. |
| Logistics Response to Labeling Deficiencies | Organize logistics information related to shipment hold, inventory retention, label replacement, and returns | Unilaterally decide on product recalls or administrative measures | Handle logistics responses based on judgments from the importer and seller. |
Typical Situations Where the System Becomes an Issue
Typical situations where raw material origin labeling becomes an issue occur when label creation proceeds without clarifying whether the product is an imported processed food or domestically manufactured product. Additionally, when the origin or domestic manufacture is emphasized in advertising, consistency between container/packaging labeling and the advertisement can also be problematic.
| Typical Situation | Common Issues | Parties and Documents to Confirm | Practical Responses |
|---|---|---|---|
| Importing and Selling Finished Products from Overseas | Confusing raw material origin labeling with country of origin labeling | Importer, country of manufacture documents, product specifications, draft labels | Confirm country of origin labeling as an imported processed food. |
| Processing Imported Raw Materials Domestically | Overlooking the possibility that raw material origin labeling is necessary as a domestically manufactured product | Manufacturer, raw material specification sheets, origin certificates, blend sheets | Confirm target raw materials as domestically manufactured products. |
| Procurement Sources Fluctuate Across Multiple Countries | Mismatch between the labeling method and actual usage records | Purchase records, usage plans, procurement contracts, blend records | Confirm whether listing by country in order of weight, “Or” labeling, or broad category labeling is applicable. |
| Using Processed Food Ingredients as Target Raw Materials | Mixing up origin and place of manufacture | Manufacturing location documentation of processed food ingredients, specification sheets, manufacturer information | Confirm manufacturing place labeling such as “domestically manufactured” or “made in France.” |
| Emphasizing Specific Origins in Advertising | Giving the impression that the entire product is characterized by the origin of only some ingredients | Advertisement drafts, blend ratios, origin certificates, container and packaging labels | Clearly define the scope of statements to avoid misleading or deceptive representations. |
| Dispersed Labeling Evidence for PB/OEM Products | Information inconsistencies among seller, manufacturer, and raw material supplier | Specifications, labeling evidence documents, manufacturing outsourcing contracts, raw material documents | The person responsible for labeling centrally manages the supporting documents. |
System Application Scenario 1: Importing and Selling Overseas-Manufactured Confectionery As-Is
When confectionery manufactured overseas is imported into Japan and sold as-is, the product is treated as an imported processed food. In this case, the key point to confirm is not the origin labeling of raw materials but the country of origin labeling of the product itself.
For example, when importing chocolate confectionery manufactured in France, the basic information to be shown to consumers is which country the imported product was manufactured in. The origin of ingredients such as cocoa, sugar, and dairy used in the confectionery is not labeled under the same approach as domestic processed foods using raw material origin labeling.
In practice, it is necessary to confirm whether the exporting country on the invoice, the country name on the certificate of origin, the actual manufacturing country, and the country of origin on the label all match. Because the exporting country and the manufacturing country can differ, it is important to separately confirm "where it was shipped from" and "where it was manufactured."
System Application Scenario 2: Producing Beverages in Japan Using Imported Fruit Juice
When manufacturing soft drinks domestically in Japan using imported fruit juice, the final product is considered a domestically manufactured processed food. In principle, the raw material with the highest weight percentage in the product is the target raw material, and if that raw material is a processed food, the indication of the manufacturing location becomes an issue.
For example, if apple juice is the target raw material, and that juice is a processed food raw material manufactured in Germany, a manufacturing location indication such as "Apple Juice (Manufactured in Germany)" could be considered. The focus here is not on the country where the apples themselves were grown but on the manufacturing location of the target raw material, i.e., the apple juice.
In practice, information such as the overseas manufacturer's raw material specifications, manufacturing location details, manufacturer certifications, and formulation sheets are obtained and organized for use in labeling as domestic manufactured products. Since the documentation required for Food Sanitation Law confirmation at import differs from that necessary for raw material origin labeling, it is important to prepare for both.
System Application Scenario 3: Emphasizing Use of Domestic Raw Materials in EC Advertising
For processed foods manufactured in Japan, when emphasizing phrases such as "Using Domestic Raw Materials," "Using Hokkaido Raw Materials," or "Domestic Manufacturing" on EC sites or advertisements, it is necessary to check whether such expressions contradict the raw material origin labeling on the packaging or container.
Displaying only part of the raw materials as domestic while giving the impression that the entire product is made solely from domestic raw materials may lead to issues of misleading representations. Additionally, "Domestic Manufacturing" can refer either to the place of manufacture of the processed food raw materials or to the location where the whole product is produced; the context should be made clear.
In practice, the formulation ratio, target raw materials, certificates of origin, advertisement text, product images, EC pages, and packaging labels are cross-checked. Avoiding overemphasis of origin or quality beyond the factual scope of the labeling helps prevent post-sale disputes.
Relationship with Advertising and Sales Statements
Raw material origin labeling primarily relates to labeling on packaging, but caution is also required when emphasizing origin in sales pages and advertisements. For example, when using expressions such as "Using Domestic Raw Materials," "Hokkaido Origin," "European Raw Materials," or "Domestic Manufacture," it is necessary to confirm they do not contradict the actual raw materials, usage ratios, applicable scope, or manufacturing location labeling.
Claims that mislead consumers into believing the product is superior to reality may lead to problems under the Act Against Unjustifiable Premiums and Misleading Representations. Special care is needed for representations that imply the entire product is made from raw materials of a specific origin when only part of the raw material is from that origin.
Stronger promotional expressions than those on packaging may be used on EC sites, social media, flyers, in-store POP, and text included in product images. Before sales, it is important to verify consistency between packaging labeling and advertisement claims to ensure no gaps exist in consumer perception.
Documents Importers and Sellers Should Prepare
Accurate raw material origin labeling requires that before creating the label, relevant documentation is organized covering the target raw materials, weight ratios, origin or manufacturing location, procurement fluctuations, and the basis for labeling methods. In food import practice, overseas manufacturers' documents may not always be structured to meet Japanese labeling system requirements, so confirmation is needed whether the information can be used for labeling intended for Japan.
| Document | Confirmed Information | Main Source | Impact if Missing |
|---|---|---|---|
| Formulation Sheet / Weight Ratio Data | Confirms which raw material constitutes the highest weight percentage in the product. | Manufacturer, Quality Control Department | Cannot identify the target raw material. |
| Raw Material Specification Sheet | Confirms the name, characteristics, and whether the raw material is fresh or processed food. | Raw Material Supplier, Overseas Manufacturer | Cannot determine if origin labeling or manufacturing location labeling applies. |
| Certificate of Origin / Manufacturing Location Certificate | Confirms the origin or manufacturing location of the target raw material. | Raw Material Supplier, Manufacturer, Exporter | Insufficient basis for labeling. |
| Purchase and Usage Records | Provides basis for labeling by country weight order or broad classification. | Purchasing Department, Manufacturer, Raw Material Management | Cannot create labels accommodating fluctuating procurement sources. |
| Usage and Procurement Plans | Confirms possible future sourcing countries. | Purchasing Department, Manufacturer, Raw Material Supplier | Insufficient basis for broad or summary labeling. |
| Advertising Drafts / EC Display Drafts | Confirms consistency between packaging labeling and sales display content. | Sales Representative, Advertising Staff, EC Staff | Origin emphasis may lead to misleading representation issues. |
Summary
Raw material origin labeling is a system for processed foods manufactured or processed domestically, requiring display of the origin or manufacturing location of the target raw materials used. As a general rule, labeling is done for the raw material that accounts for the highest weight percentage in the product.
In import food operations, it is important not to confuse the country of origin labeling required for the imported processed food itself with the ingredient origin labeling needed for processed food manufactured domestically using imported raw materials. If the relevant raw materials are fresh foods, the origin should be confirmed; if they are processed foods, the manufacturing location should be verified.
“Or” labeling or broad grouping labeling may be used when procurement sources vary, but they are not simplified labels that can be chosen arbitrarily. It is essential to organize supporting documents such as usage records and usage plans, and to manage the origin indications consistently across container packaging labels, e-commerce pages, and advertising displays to avoid discrepancies.
