Guide to Japanese Labeling Requirements for Post Harvest Fungicide

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In Japan, post harvest fungicides (PHF) are uniquely classified as food additives under the Food Sanitation Law due to their function as food preservers. The Ministry of Health, Labor, and Welfare (MHLW) administers food additive policy according to the Food Sanitation Law. For more information on this policy, please consult the latest "Standards Applying Generally to Food Additives." PHF are listed in the table of standards for use as anti-molding agents on the first page of the list along with information on target foods and maximum residue limits.
Currently, there are six substances approved for use as PHFs in Japan. These include: Diphenyl, Imazalil, o-Phenylphenol (OPP), Sodium o-Phenylphenate (OPP-NA), Tiabendazole (TBZ) and the recently approved Fludioxonil. For more information on Japan’s approval of Fludioxonil, please refer to the GAIN report JA0021 “Designation of Fludioxonil as a new Food Additive.” In addition, only the following products are allowed to be treated with PHFs, namely, apples, apricots, bananas, cherries, citrus fruits, Japanese plums, kiwifruits, loquats, nectarines, peaches, pears, pomegranates, and quinces. All export packages containing produce treated with PHFs must have PHF labeling at the time of entry into Japan. Generally, packers include PHF information on their export packages when designing carton boxes for Japan. As the Japanese government does not require PHF labeling for treated produce to clear customs, it is technically possible for importers to pass treated produce through customs without the PHF information on the cartons. However, Japanese importers generally request packers to lithograph or include stickers detailing PHF information on cartons before shipping in order to avoid having to apply labels at Japanese ports. Nonetheless, Under Cabinet Office Ordinance (No. 45 1-2: August 31, 2011 Reference in Japanese,) importers are required to display PHF information on cartons of imported produce when they sell fruits to distributors or retailers immediately after customs clearance.

Yuichi Hayashi