Opinion on the Japanese Government’s Draft Guidelines on Non-use Labeling of Food Additives

Consumers Union of Japan (CUJ) is opposed to the “Draft Guidelines on the Non-use Labeling of Food Additives.”

Consumers are demanding foods with fewer food additives. However, due to the inadequacy of the current food additive labeling system, it is difficult to avoid food additives even if one wants to avoid eating them as much as possible. On the other hand, some companies are making efforts to produce and provide foods without additives as much as possible to respond to consumers’ voices, which is why they label their products as “additive-free” (無添加 mutenka) as well as non-use. It is admitted that there are some inappropriate labels, but one problem is that the labeling principle of listing the names of substances in order of weight is not being followed. Therefore, we would like to request the government to discuss the establishment of a food labeling system that protects consumers’ right to know and choose, rather than to formulate guidelines in a hasty manner.

(1) It is the consumer’s right to know the non-use of food additives
For consumers who seek foods with less food additives, non-use labeling is information that contributes to product selection.

(2) Guidelines that are vague and susceptible to broad interpretation are harmful
Many of the definitions of the proposed categories are vague and unfounded, and may be interpreted broadly, which may practically lead to the prohibition of all additive-free and non-use labeling. Such a situation is not what consumers want.

(3) Food additives should be discussed based on the precautionary principle, not as something safe
The guidelines are based on the assumption that food additives are safe if they are below the ADI (Acceptable Daily Intake) set by the Food Safety Commission, but the current evaluation method has its limitations. In addition to properly acknowledging these limitations, the government should instruct businesses to reduce food additives in accordance with the precautionary principle, and labeling should be able to convey the reduction of food additives.

(4) Improvement of food additive labeling system should be reconsidered from consumers’ point of view
In the recent debate on the review of food labeling, only the opinions of the industry have been respected, and the inadequate labeling system has not been improved, but it has become a setback for consumers. We strongly request that the review panel should be fundamentally reviewed and the food additive labeling system should be re-examined based on the opinions of consumers.