Japan's Consumer Affairs Agency (CAA) promulgated Cabinet Office Order No. 89 of 2026 (内閣府令第89号) on October 1, 2026, amending the Food Labeling Standards (食品表示基準) under the Food Labelling Act (Act No. 70 of 2013). Signed by Prime Minister Sanae Takaichi and taking effect from its publication date under Supplementary Provisions Article 1, the order tightens the category names permitted for dressings and revises the nutrient content limits, function-claim wording and precautionary statements for Foods with Nutrient Function Claims (FNFC).
Manufacturers and importers of dressings and FNFC fortified foods and supplements placing products on the Japanese market must reformulate and/or relabel to the amended category names and nutrient rules from October 1, 2026, or face mislabelling enforcement under the Food Labelling Act, including administrative corrective orders and refusal of non-conforming labels at market placement. A transitional measure in Supplementary Provisions Article 2 lets stock already manufactured or imported by the transitional deadline follow the previous labelling rules.
What changed in the dressing category names
The order removes the generic "dressing" (ドレッシング) label option from three dressing categories, requiring their specific category names instead. Mayonnaise, and the semi-solid, emulsified liquid and separated liquid dressing types, keep their existing permitted names. The notification "食品表示基準について" (41st amendment, 消食表第749号) and the FNFC Q&A (23rd amendment, 消食表第750号) were updated the same day to operationalize the new names.
| Dressing type | Before (改正前) | After (改正後) |
|---|---|---|
| Mayonnaise (マヨネーズ) | "マヨネーズ" | "マヨネーズ" (unchanged) |
| Salad cream dressing (サラダクリーミードレッシング) | "サラダクリーミードレッシング" or "ドレッシング" | "サラダクリーミードレッシング" (generic option removed) |
| Semi-solid dressing, excluding mayonnaise and salad cream | "半固体状ドレッシング" or "ドレッシング" | unchanged |
| Emulsified liquid dressing (乳化液状ドレッシング) | "乳化液状ドレッシング" or "ドレッシング" | unchanged |
| Separated liquid dressing (分離液状ドレッシング) | "分離液状ドレッシング" or "ドレッシング" | unchanged |
| Dressing-type seasoning (ドレッシングタイプ調味料) | "ドレッシング" | "ドレッシングタイプ調味料" (specific name required) |
| Non-oil dressing (ノンオイルドレッシング) | "ドレッシング" and "ノンオイルドレッシング" | "ドレッシングタイプ調味料" and "ノンオイルドレッシング" |
What changed for Foods with Nutrient Function Claims
The order revises the FNFC regime in Appended Table 4: the daily-intake lower limits (下限値), upper limits (上限値), authorized function-claim wording (機能), and precautionary statements (摂取をする上での注意事項) for the nutrients permitted to carry FNFC claims. The affected nutrients span n-3 fatty acids, iron, calcium, potassium, zinc, niacin, magnesium, copper, vitamin A, biotin, pantothenic acid, vitamins B1, B2, B6, B12, C, D, E and K, and folate. FNFC products whose current formulations or labels rely on the previous limits or claim wording must move to the amended values and wording for products placed on the market from October 1, 2026.
Who must comply, and by when
The amendment binds manufacturers and importers of dressings (mayonnaise, salad cream dressings, semi-solid, emulsified and separated dressings, dressing-type seasonings and non-oil dressings) and of FNFC fortified foods and supplements that place products on the Japanese market, by market exposure rather than headquarter location. Domestic producers and foreign exporters shipping into Japan both carry the relabelling obligation.
The operative date is October 1, 2026: the order takes effect from its publication date (附則第一条), so products placed on the market from that date must meet the amended Standards. The transitional measure (附則第二条, 経過措置) lets processed foods already manufactured, processed or imported by the transitional deadline retain the previous labelling, giving the trade a sell-through window for existing stock.
What happens otherwise
Non-compliance is mislabelling under the Food Labelling Act, exposing the business to administrative corrective orders from the CAA and the Act's penalties, with non-conforming labels refused at market placement. The CAA enforces the Standards through prefectural cooperation and labelling inspections. Continuous, per-jurisdiction monitoring surfaces this kind of amendment the moment the CAA publishes, before a mislabelled batch reaches the Japanese trade.
Next, verify each product's current dressing category name against the table above, audit FNFC formulations and claim wording against the amended Appended Table 4, re-plan packaging artwork to the new names and limits, and confirm which existing stock qualifies for the transitional measure before the sell-through window closes.
