Tariffs. YEARLY STATUS REPORT: No Progress. Import duty rates for many foods and food ingredients remain far too high.

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2 TARIFFS

3 Tariffs YEARLY STATUS REPORT: No Progress Import duty rates for many foods and food ingredients remain far too high. Severe inflation in the cost of ingredients and transport, coupled with high import duties, make some imported foods prohibitively expensive Butter (with an import duty rate of 35% +1,159 yen/kg) Cheese (26 40%) Chocolate for professional use (29.8%) Confectionery (25%) Syrup (24% + sugar tax) Fruit juice and fruit puree for babies (21.3%) Herbal tea (15%) RECOMMENDATION The Government of Japan and the EU should abolish tariffs on food products as part of an EU-Japan Economic Integration Agreement.

4 FOOD ADDITIVES

5 Food Additives YEARLY STATUS REPORT: Slow Progress In December 2002, the Ministry of Health, Labour and Welfare (MHLW) prepared a list of 46 food additives not approved in Japan that have been proven safe and are widely used in the world. At the time of writing, more than one-third of these 46 additives have still not been approved. Moreover, the list has now increased to 73 entries (with the addition of many new flavouring agents), including six substances whose evaluation by the expert committee of the Food Safety Commission was stopped around We note that eight entries have been dropped from the initial list, but see no reason for their removal.

6 Food Additives YEARLY STATUS REPORT: Slow Progress The total number of additives listed now demonstrates that there is still a need to approve more additives without delay. The EBC must also point out that, relative to the EU, some widely used additives (especially preservatives), such as sulphur dioxide (SO2) and sorbic acid (potassium sorbate), have significantly different allowed usage levels in Japan, based on food category. For sulphur dioxide, the allowed usage level can be as high as 0.35 g/kg for alcoholic beverage categories, or as low as 0.03 g/kg for other foods.

7 Food Additives YEARLY STATUS REPORT: Slow Progress Many European foods with reasonable levels of sulphur dioxide cannot be imported into Japan simply because they do not fit into any existing category. The situation is worse for sorbic acid as for this substance, the other foods category does not exist, meaning that even a trace (possibly even a carry-over) of sorbic acid found, would result in the total recall of that food, despite there being absolutely no health risk whatsoever.

8 Food Additives RECOMMENDATIONS The Food Safety Commission should start to process the eight additives dropped from the initial list, and approve as soon as possible the six additives for which the evaluation process started in 2007 and stopped in The complete list as of September 2010 should therefore have 81 entries and work on the additives not yet processed should start without delay. Beyond this list, the EBC strongly recommends a review of the standards of use for food additives. Standards of use for common preservatives, such as sulphur dioxide (SO2) and sorbic acid (potassium sorbate), should be modified to allow usage levels in line with European standards and international best practice.

9 PRODUCTS OF BOVINE ORIGIN (MEAT, GELATINE, ETC.)

10 Products of Bovine Origin (Meat, Gelatine, Etc.) YEARLY STATUS REPORT: Some Progress In May 2005, the Food Safety Commission recommended that meat from animals younger than 20 months should be considered safe for import, a recommendation that was also endorsed by MAFF. The European beef industry is perfectly capable of tracing and guaranteeing the age of individual animals, yet the ban on imports of European beef remains in place. Several interested Member States are currently working on technical questionnaires received from MAFF and MHLW and have already submitted data. The process is extremely slow and still remains only at the discussion level.

11 Products of Bovine Origin (Meat, Gelatine, Etc.) YEARLY STATUS REPORT: Some Progress Consequently, imports of all products from the EU using ingredients of bovine origin (such as meat, any sausage made with bovine gelatine, cosmetic products, etc.) are completely banned in Japan. RECOMMENDATION Considering the high level of safety and traceability in the beef industry in the EU, and also given the fact that the ban on US beef was lifted more than 3 years ago, the EBC recommends that MAFF and MHLW give the green light to authorise the resumption of imports of products of bovine origin from the EU.

12 LISTERIA MONOCYTOGENES IN READY-TO-EAT FOOD PRODUCTS

13 Listeria Monocytogenes In Ready-To-Eat Food Products YEARLY STATUS REPORT: Some Progress Listeria monocytogenes is a pathogenic bacterium widespread in the environment. It can contaminate foods causing a mild illness, called Listerial Gastroenteritis, or in certain cases, a potentially lethal disease called Invasive Listeriosis. The EU standard, fully taking into account consumer safety, stipulates zero tolerance for ready-to-eat (RTE) foods that support the growth of the bacteria, whilst accepting minute levels of L. monocytogenes (less than or equal to 100 cfu/g) in RTE foods that are scientifically proven to not support the growth of the bacteria due to particular characteristics (e.g. ph, water activity, certain processes or treatment).

14 Listeria Monocytogenes In Ready-To-Eat Food Products RECOMMENDATION Japan should review its position regarding L. monocytogenes, and consider aligning its regulations with the double approach adopted by the EU, Canada and other countries, and also supported by the principles of Codex Alimentarius and the US Food and Drug Administration (FDA). This would improve food safety by focusing attention and action only on those products that pose a health risk.

15 SUPPLEMENTARY EMBASSY CERTIFICATES FOR ORGANIC PRODUCTS TO BE LABELLED IN JAPAN

16 Supplementary Embassy Certificates for Organic Products to be Labelled in Japan YEARLY STATUS REPORT: No Progress Products that have the Japanese label (Organic-JAS) affixed in Japan (which is often the case when small quantities are imported) are subject to a time-consuming, costly, wasteful bureaucratic process. Every single shipment has to be accompanied by a specific organic certificate from the supplier s certifying body, containing details of the order (products, quantities and best before date). This process alone is already a burden, but then the importer must send that original certificate to the relevant embassy of the country from which the products were imported, together with the invoice, packing list and waybill. The embassy must then issue a supplementary certificate to the importer in order to have the products labelled Organic-JAS in Japan.

17 Supplementary Embassy Certificates for Organic Products to be Labelled in Japan RECOMMENDATION The Government of Japan should abolish the need for issuing all these certificates. It should be sufficient for the importer to be Organic-JAS certified (and as such inspected once a year), as well as to keep a file copy of annual organic certificates or imported products.

18 FOOD SAFETY

19 Food Safety YEARLY STATUS REPORT: No Progress In 2009, there was a public debate about the possibility of adding labels to foods listing the origin of all ingredients, in the name of consumer safety. In today s global world, it would be near impossible for most food manufacturers (Japanese especially) to abide by such a rule, and in no way would it increase consumer safety.

20 Food Safety RECOMMENDATIONS In the field of Food Safety, EU legislation has made significant progress in recent years. We urge the Government of Japan to liaise as much as possible with relevant bodies in the EU. In particular, the EBC recommends that Japan s Food Safety Commission liaises with the EFSA (European Food Safety Authority). The newly created Consumer Agency of Japan should interact with the Food Safety Commission when considering the most effective actions to ensure consumer safety and to reduce the incidence of accidents and fraud in the food sector.