Hidden Allergens on Japanese Food Labels: Sauces, Additives

Japanese food labels are well made. As a rule, the 9 mandatory allergens are shown even when they are inside a sauce or used to make an additive (with a few exceptions, such as flavorings). But the 20 recommended items, outside that group, are a different story. Under some labeling rules, contents are folded into one name, and you may not be able to read them from the label. When I ran a bento business, this was what scared me most.

What is a compound ingredient?

A compound ingredient is an ingredient made from two or more ingredients. In a bento, examples are the sauce on a hamburger steak, the mayonnaise in potato salad, ham and soy sauce. On the label, its contents are written in brackets after its name, in order of weight, heaviest first.

Sauce (sugar, soy sauce, tomato ketchup, brewed vinegar, other)

When can the contents be left off the label?

Under the Food Labeling Standards, the contents of a compound ingredient can be left out in these cases.

Additives have similar rules.

• Group names: emulsifiers, seasoning (amino acids etc.), flavoring, leavening agents, pH adjusters and others can be listed by a group name, without saying exactly what was used.
• No listing needed: “processing aids” and “carry-over” additives do not need to be listed as additives.

What are carry-over additives?

A carry-over additive is an additive used to make an ingredient, which comes into the food along with that ingredient. It does not need to be listed if it is not used in making the final food, and the amount left is clearly less than what would have an effect in that food.

• Examples of carry-over: rice crackers flavored with soy sauce that contains a preservative (benzoic acid). The preservative has no effect in the crackers, so it does not need to be listed.
• Not carry-over: melon sauce with a coloring, used on ice cream (you can still see the color in the ice cream). Ham made with a color fixative, mixed into potato salad (the ham stays in pieces). If an additive’s color, taste or aroma still has an effect in the final food, it is not carry-over.

What are processing aids?

A processing aid is an additive used while making a food, which is almost gone from the finished food. It does not need to be listed if one of these applies.

• It is removed before the food is finished (for example, hexane, a solvent used to extract oil).
• It turns into something the food already contains, and does not clearly increase that amount (for example, magnesium carbonate used to adjust the water for brewing beer).
• Only a tiny amount is left, with no effect on the food (for example, silicone resin used to stop foaming when making tofu).

Neither type is listed as an additive. But as the next section explains, if it comes from one of the 9 mandatory allergens, the allergen must be labeled.

The 9 mandatory allergens, as a rule, do not hide

Here, the label is fairly reliable. Allergen labeling follows a separate rule from the ingredient list. Even when the contents of a compound ingredient are left out, additives are listed by group name, or an additive is a processing aid or carry-over, the 9 mandatory allergens (shrimp, crab, walnut, wheat, buckwheat, egg, milk, peanut, cashew) must be labeled if present. There are exceptions with no labeling duty: flavorings (the aroma compounds) made from a mandatory allergen, and substances with no recognized allergenicity, meaning they are not recognized as causing allergies, such as fully refined lactose. Alcoholic drinks also have no labeling duty, even when they are made from a mandatory allergen.

For additives, the source is written after the name, as in “emulsifier (from milk).”

The 20 recommended items can hide inside a name

The problem is the 20 recommended items. Makers are only asked to “label them where possible.” If a maker does not label them, this can happen.

Each of these labels follows the rules. None is a violation. But a person allergic to sesame, soy or gelatin cannot tell that it is there.

There is one clue. Makers are asked to write, outside the label box, whether the label covers “the 9 specified ingredients” or “29 items, including the 20 items equivalent to specified ingredients.” A product that says “29 items” labels the recommended items too. The full list of 29 is in the Japan allergen list.

Why is it so hard to see?

Allergen information passes on paper: from ingredient makers to processed food makers, and from processed food makers to the people who make bento. The Consumer Affairs Agency also asks businesses to check in writing whether specified ingredients are present, and to keep records.

When we ran our bento business, checking the recommended items meant asking every maker of the processed products we used. Each of those makers then had to check with its own suppliers. Large makers knew exactly what was in their products. Smaller makers were sometimes unclear. Documents are made by people, so we once found a mistake in one.

WE TABLE’s registered dietitian used to work at a large food maker, where they were also involved in checking labels like these. I learned a lot from them. But in my view, very few cooks know this much. Many people may not even know that some things become invisible on a label.

How to deal with what you cannot see

• If you are allergic to a recommended item: choose products that say “29 items” outside the label box, or contact the maker’s customer service. Foods with few ingredients, where you can see what is inside, are easier to check.
• When you eat out: cooks do not always know everything inside the processed products they buy. If you hear “it’s not in it,” ask how they checked (see how to explain food allergies at restaurants in Japan).
• If you cook for others: you cannot see the recommended items in processed products from the label alone. Ask suppliers for detailed ingredient documents, and check whether they cover the recommended items too.

For the difference between mandatory and recommended allergens, and which food has to be labeled at all, see Japan’s allergen labeling rules.