5. Claim Requirements

Foods with Nutrient Function Claims (FNFC)

Japan

This section provides information on the definition of different types of claims and any restrictions or allowance of claims as well as claim registration processes.

5.1 Overview of Claims

5.1.1 Types & Definitions of Claims

Nutritional Claims

The Food Labeling Standards (Cabinet Ordinance No. 10 of 2015) allow nutrient content claims for specific nutrients as an optional labeling content [1]. When a food product meets the requirements set out by the Standards, it can bear a nutrient content claim without any submission or notification to the authority.

Health Claims

There is no legal definition for "health claims" in Japan. Article 9 (10) of the Food Labeling Standards (Cabinet Ordinance No. 10 of 2015) defines "Foods with Health Claims" as the collective term of the Foods for Specified Health Uses (FOSHU), Foods with Nutrient Function Claims (FNFC), and Foods with Function Claims (FFC) [1]. 

Additionally, "Foods with Health Claims" are generally defined as "foods that claim functions of foods according to the standards established by the Japanese government related to safety and functionality".
 
The CAA gives a general definition of FOSHU as "foods containing a functional ingredient that has physiological effects and claiming that people can expect specific effects on their health by consuming the foods". In order to market a food product as a FOSHU, pre-market approval by the CAA is required.
 
The CAA gives a general definition of FFC as “foods notified to the CAA as products whose labels bear function claims based on scientific evidence, under the responsibility of food business operators”, In order to market a food product as an FFC, completion of notification to the CAA is required. 

5.1.2 List of Prohibited Claims

General Food

It is not allowed to make any health claim (including the FNFC's claims) on foodstuff/general foods unless they fall into the categories of Foods for Specified Health Uses (FOSHU), Foods with Nutrient Function Claims (FNFC), or FFC by completing the necessary regulatory procedures.

Category

FNFC products are not allowed to bear the following claims:

• Any functional claims related to food constituents other than the 20 nutrients defined as the functional nutrients of FNFC.
• Any claims associated with FOSHU or FFC.

Product

Same as above.

5.2 Nutritional Claims

5.2.1 Permitted Claims

General Foods [1]

The following types of nutrient content claims are permitted for protein, dietary fiber, zinc, potassium, calcium, iron, copper, magnesium, niacin, pantothenic acid, biotin, vitamin A, B1, B2, B6, B12, C, D, E, and K, and folic acid:

• "High in" claims (e.g., "High in protein", "Plenty of Vitamin C")
• "Source of" claims (e.g., "Contain calcium", "Source of dietary fiber")
• "Fortified" claim (e.g., "Vitamin E 30% up", "Double calcium") 

The following types of nutrient content claims are permitted for calorie, fat, saturated fatty acids, cholesterol, sugars, and sodium:

• "Not-contained" claims (e.g. "Nonsugar", "Calorie zero")
• "Low in" claims (e.g. "Low cholesterol", "Calorie light")
• "Reduced" claims (e.g. "Calorie 30% cut", "Fat 10g off", "Calorie half")

Category

An FNFC product can bear nutrient content claims in addition to its FNFC claim when it satisfies applicable requirements. 

Product

Same as above.

5.2.2 Nutritional Claim Registration

N/A

5.3 Health Claims

5.3.1 Permitted Claims

General Foods

Health claims are not allowed on General Foods. Health claims are only allowed on one of the following 3 categories of "Food with Health Claims":

1. Foods for Specified Health Uses (FOSHU)
2. Foods with Nutrient Function Claims (FNFC)
3. Foods with Function Claims (FFC)

Category

Please refer to Table 4.1-1 in Section 4.1.

Product

Same as above.

5.3.2 Health Claim Registration

N/A

5.4 Other Notes or Requirements for Claims

N/A

5.5 References

1. Food Labelling Standards (Cabinet Ordinance No.10 of 2015)  
https://elaws.e-gov.go.jp/document?lawid=427M60000002010 (in Japanese)