Category Archives: Corporate Responsibility

Open Letter Regarding Genome-edited Fish in Indonesia

Following the announcement by Regional Fish, a Japanese company that develops and markets genome-edited red sea bream and genome-edited tiger pufferfish, that it will begin a demonstration of genome-edited seafood products in Indonesia, we sent the following letter of inquiry to the company.


16 November 2022


Regional Fish Co.

Mr. Tadanori Umekawa, President


No! GMO Campaign

Representative Keisuke Amagasa

Consumers Union of Japan

Co-Chairperson: Ado Kameyama

Co-Chairperson Miyoko Sasaki

Co-Chairperson Martin Frid

Open letter of inquiry regarding the demonstration project of genome-edited fishery products in Indonesia

We are a consumer and citizens’ organization working for food safety and security.

In August 2022, your company, together with an Indonesian company PT Aruna Jaya Nuswantara (“ARUNA”), was selected for JETRO’s Asia DX Promotion Project in ASEAN-Japan and announced that it would start a demonstration project for genome-edited marine products in Indonesia with the JETRO grant. Although your company has developed genome-edited red sea bream and genome-edited tiger puffer fish and already marketed them in Japan, we, consumers, have strong concerns about these genome-edited foods and genome-editing technology. As Japanese consumers, we cannot overlook the fact that your company is promoting such genome-edited foods in Indonesia.

Therefore, we ask the following questions. Please respond in writing or by e-mail by 2 December. We will publish your response, including whether or not we have received your answer, on our website and elsewhere.

The following is a list of the questions we will ask:

1. According to your press release dated 26 August 2022, Indonesia is in the process of considering the establishment of rules for genome-edited food products.

2Please tell us the background of your decision to conduct the demonstration project for genome-edited marine products with ARUNA.

3. According to the above press release, your company is planning to collaborate with Indonesian government agencies and regulatory authorities to develop practical rules. Please provide specific details about this collaboration.

4. According to the same press release, you are aiming to develop high-growth tilapia (Tilapia) and edible portion-increasing snapper (Red Snapper) in a short period of time using genome editing technology. When will these demonstration projects start and what is the current progress of the projects?

5. Where in Indonesia will the demonstration projects be conducted? Please provide the name of the location.

6. Will the demonstration of genome-edited fish be conducted through land-based aquaculture or offshore aquaculture?

7. If land-based aquaculture, which method do you plan to use?

8. Will you conduct biodiversity impact assessments regardless of whether the fish are farmed on land or at sea?

9. Do you intend to sell the genome-edited marine products developed in this project only within Indonesia? Or do you plan to export them to other countries including Japan?

Japanese letter here

Japan Animal Welfare Scandal: The Consumer Response


Consumers Union of Japan is protesting against the lack of public access to Japan’s Animal Welfare Opinion Exchange Meetings and problems with the way the meetings are being run.

Japan has not adopted modern rules for animal welfare, especially in the chicken and egg production. A scandal erupted as LDP politician and former agriculture minister Takamori Yoshikawa was found guilty of taking bribes from Akita Foods Co., an egg producer based in Hiroshima Prefecture. At the same time, Japan had opposed globally binding rules for egg production at the United Nation’s organization for animal health, OIE, where international standards are supposed to be agreed upon. The fallout from the scandal continued to grow as Koya Nishikawa, also a former farm minister, resigned as a special Cabinet adviser amid criticism over his own intimate ties with Akita Foods.

Yoshiki Akita, the former head of Akita Foods Co., was found guilty of bribery in October 2021 and given a suspended sentence. Mr. Nishikawa said that whenever Mr. Akita gave him money, he always asked for help, not just for Akita Foods, but for the domestic egg industry as a whole. According to the Asahi Newspaper, Mr. Nishikawa set up a meeting between Mr. Akita and Mr. Yoshikawa, when he was farm minister. Mr. Akita then asked Mr. Yoshikawa to help Japan’s poultry industry by ensuring the Japanese government would oppose the proposal at the United Nation level to improve animal welfare standards.

According to the Mainichi Newspaper, at the time Mr. Yoshikawa is said to have received the money, discussions were proceeding over the formulation of animal welfare standards requiring farm animals to be raised in stress-free settings. The Japanese egg farming industry was opposed to such a plan for international standards proposed by the World Organisation for Animal Health (OIE). The former head of Akita Foods petitioned Mr. Yoshikawa for revisions to the OIE proposal and in January 2019 and again in July that year, Japan presented opinions opposing part of the OIE’s proposed standards.

Japan’s 1973 Act on Welfare and Management of Animals makes it a crime to kill, injure, or inflict cruelty on animals without due cause. But egg producers are still mainly sticking to old-fashioned methods, such as confining egg-laying hens to very cramped cages. This also involves using antibiotics and other drugs. 95.2% of eggs in Japan are from caged hens and there is little awareness of the availability of free-range eggs, according to Rob Harrison, Ethical Consumer, who has extensive knowledge of the situation in Japan.

Consumers Union of Japan was supposed to join an opinion exchange meeting about animal welfare at Japan’s Agriculture ministry (MAFF) but just days before the meeting in January 2022, it was announced that it would be closed to the public. After careful consideration, CUJ decided not to participate in such closed meetings anymore. Koketsu Michiyo, co-chairperson of CUJ writes in CUJ’s letter to the Japanese government:

As for the reason for keeping the Animal Welfare Opinion Exchange Meeting closed to the public, you say, “It is necessary to ensure a frank exchange of opinions among the committee members, and in order to hear frank opinions on issues in the field, it is also necessary to take into consideration concerns about the possibility of a ripple effect from the identification of the speakers. As the committee had decided to hold the meetings openly when it was reaching out to each committee member, the committee members would have accepted the request knowing that the meetings would be open to the public.”

The Ministry of Agriculture, Forestry and Fisheries (MAFF) bears a heavy responsibility for unilaterally declaring the meeting closed to the public just before it was to be held. The MAFF response to CUJ states that “there will be a ripple effect from the identification of the speaker.” What kind of ripple effect are they concerned about? We should understand that a ripple effect would indeed occur if the public’s interest in animal welfare is that high. In addition, a summary of the meeting is just that, a summary, without the names of each speaker, and it cannot be said that transparency is being ensured.”

The Animal Welfare Opinion Exchange Meeting was established to verify
the fairness of the poultry and egg administration in response to the
indictment of former Minister Takamori Yoshikawa on bribery charges. It
is only natural that the meeting should be open to the public,” says Michiyo Koketsu, CUJ.

On 5 July 2022 both Michiyo Koketsu, CUJ and Kaori Yamane, Shufuren Association of Consumer Organizations resigned from the Animal Welfare Opinion Exchange Meeting to protest against the lack of public access to the meetings and problems with the way the meetings are being run.

Global People’s Summit on Food Systems — Against the UN Food System Summit

In September of this year (2021), the United Nations Secretary-General António Guterres will convene the United Nations Food System Summit. In this international event with the goal of building a “healthier, more sustainable and equitable food system,” and in 2021 (in the midst of the United Nations Decade of Family Farming 2019-2028) the participation and input of people engaged in family farming and small-scale agriculture, who account for more than 80% of the world’s food production, should be a priority.

However, when concrete discussions began in 2020, the issues of human rights and land grabbing that small-scale farmer groups have been advocating were not at the center of the agenda, and corporations and related organizations that promote land concentration, monopolization of agricultural supply chains. Also the industrialization of food, including biotechnology, have had a significant influence on decision-making. In response to this, many civil society organizations have begun to take action and sent a joint letter demanding a review of the summit’s preparatory process, transparency in decision-making, and dialogue to achieve this, but no fundamental review has taken place. In March, a group of small-scale farmers from the Global South (Southeast Asia, South America, and Africa) announced their boycott of the summit and launched a counter-summit, the Global People’s Summit on Food Systems (GPS).

The following statement is the press release issued along with the declaration of this counter-summit. What is it that the world’s small-scale farmers, who hold the key to the future of agriculture, and the many civil society organizations that share their beliefs, want to address by boycotting the UN event?

Consumers Union of Japan is a member of the Stop Golden Rice Network (SGRN), one of the organizers of the Global People’s Summit on Food Systems.

In Japanese here

Facebook in English here

Statement from Hungry4Change here

Continue reading Global People’s Summit on Food Systems — Against the UN Food System Summit

Campaign to Reduce the Use of Plastics

Consumers Union of Japan is stepping up the campaign against plastic waste. We are asking major convenience stores and coffee shop chains what they are doing in Japan, as their stores in other countries appear to be moving faster to reduce the use of plastic containers and cups.

Questionnaire on Reusable Container Initiatives

To: Seven & I Holding, FamilyMart, Lawson, Starbucks Japan, Doutor Coffee

27 May 2021

According to media reports, reusable container initiatives are progressing overseas. For example, 7-Eleven in Taiwan has announced a plan to eliminate the use of all disposable plastics by 2050, and has introduced a reusable cup system in four of its stores. In addition, FamilyMart in Taiwan has also started selling lunch boxes in reusable containers. Furthermore, Starbucks in South Korea has announced that it will eliminate disposable cups by 2025. Some McDonald’s stores in London, UK have introduced reusable takeout cups that can be returned to other McDonald’s stores after the drink is finished.

We hope that Japanese companies will also promote reuse in order to reduce the use of single-use plastics. Therefore, we would like to ask you about your company’s efforts to reuse containers.

1) Please let us know the material of each of the beverage and food (lunch box, etc.) containers that you provide for both in-store and take-out.

2) Do you have any plans to change your take-out containers from one-way containers to reusable containers?

3) If the plastic recycling promotion bill currently being discussed in the Japanese Parliament is enacted, cutlery and straws may be legislated (reduced use) next year. Examples of legislation methods include charging a fee, point card promotion schemes, and switching to alternative materials. It has been shown that point card promotion schemes does not reduce the amount of plastic bags used. Also, switching to alternative materials will not reduce the amount of waste. We believe that charging a fee is the most effective way to reduce the amount of waste. Please let us know what your policy is.


Protest Against Genome Edited “GABA” Tomato in Tokyo, Japan

In what may have been the world’s first protest against a genome edited GMO food product, the GABA tomato, activists from Consumers Union of Japan and the No! GMO Campaign gathered outside Sanatech’s offices in central Tokyo, Japan on 23 December 2020.








Letter sent to Sanatech:

To: Sanatech Seed                                                                             14 December 2020

From: Consumers Union of Japan, No! GMO Campaign

Open Letter of Inquiry on Genome Edited High GABA* Tomatoes

We are a consumer organization that is working for food safety.

It has been reported that your company is distributing free of charge high GABA tomatoes produced with genome editing technology for home gardening. We believe that genome editing technology, like genetic modification technology, is potentially risky as it can cause unintentional genetic mutations and create unexpected harmful substances in crops. We are concerned that it is a big problem that genetically engineered foods, whose safety has not been fully confirmed, are being used for food.

We have some doubts about the explanatory materials that your company submitted to the Ministry of Health, Labor and Welfare (MHLW) and posted on the MHLW website, and we believe that the act of free distribution for home gardening, as announced by your company on your website, is tantamount to human experimentation.

We would like to ask you a few questions about your explanatory materials and your thinking. We will publish your response on our website.

The biggest concern about GM crops is the production of unexpected harmful substances due to unintentional genetic mutations that occur in the process of genetic engineering. In relation to this, we would like to ask the following questions:

(1) In the explanatory materials, you say that you searched for off-target candidates using two methods and investigated mutations in areas common to both methods.

(2) Instead of narrowing down the off-target candidates, you should check all the genes to see if there are any off-target cases.

(3) In the description of the allergen confirmation, there is a phrase “where mutations were identified in the target sequence and off-targets,” which contradicts the explanation in the previous section that there were no off-targets.

(4) Allergen identification was performed only for the locations where mutations were identified in the target sequences and off-targets.

(5) Tomatin was analyzed and it is stated that “Since tomatin did not increase, it is assumed that the analogues of tomatin and other alkaloids did not increase as well.”

(6) Please disclose which substances were analyzed for changes in composition compared to the pre-genetically engineered crop, and what the results were.

2. We believe that the “substantial equivalence” assessment of genetically modified crops is not a guarantee of safety because it does not confirm the production of the unexpected harmful substances mentioned above. Genome edited crops are not subjected to “substantial equivalence” review, but it is tantamount to human experimentation to use them for food without any confirmation of safety. In relation to this, we would like to ask the following questions:

(1) An antibiotic resistance gene is used as a marker gene, and a cauliflower mosaic virus gene is used as a promoter gene. What kind of research has been conducted on the effects of these genes, which may lead to unexpected genetic mutations?

(2) Do you have any plans to conduct animal experiments to confirm the safety of the product?

(3) In the explanatory materials, it is stated that the recommended intake amount will be indicated when the product is put on the market, but how do you think it will affect pregnant women, people with underlying diseases, and infants with an underdeveloped blood-brain barrier?

(4) Do you think that consumers who apply for the free distribution of genome edited crops for home and garden use will do so after learning about the risks pointed out by consumer groups? Or will they only apply based on your explanation of safety?

(5) How do you plan to understand the health effects of high GABA tomatoes?

This genome edited tomato was developed as a national project. Since the taxpayers’ money has been invested in this project, there should be social responsibility based on this. We would like to ask a few questions regarding this point:

(1) How much funding was provided by the government?

(2) Why are you rushing to market before you have a social consensus?

(3) How much of your budget is used to acquire intellectual property rights?

(4) Please stop the free distribution of high GABA tomatoes without sufficient safety confirmation.

* GABA = Gamma-AminoButyric Acid

Read more about the GABA tomato over at Citizen’s Biotechnology Information Center Japan’s first genome-edited food item, a tomato, gets green light for distribution