New ingredient labelling laws in Japan are posing a daunting challenge for manufacturers of bentos, the hugely popular lunch boxes filled with up to 20 individual products. The legislation will protect consumers susceptible to allergic reactions – but risks putting bento makers out of business. Michael Fitzpatrick reports from Japan.
Japan’s extensive new ingredient labelling laws are facing their first big test from the manufacturers of the nation’s famous O-bento lunch boxes. What has caused such an outcry from these traditionally mom and pop operations is compliance with Japan’s Food Sanitation Law, which from April requires processed food makers to label clearly ingredients that may cause allergic reactions.
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Popular for decades in Japan as a convenience food, bentos account for the biggest slice of the Home Meal Replacement (HMR) market and account for a 
large segment of food sales through Japan’s ubiquitous convenience (Konbini) stores. The top three convenience store chains, Seven Eleven, Family Mart, and Lawson, with over 20,000 outlets throughout Japan reached combined HMR sales of ¥2.2 trillion in 1998.
Each household spends about ¥21,280 per year or 2.08% of its food outgoings on bento products. The trend to bento consumption and the dramatic increase in sales of bentos through convenience stores have driven this sector to new levels of demand and it is now a major component of Japan’s catering industry.
Based on traditional kaiseki or Buddhist meals, a single serving bento lunch box can contain over twenty different morsels, each one created using varied ingredients. Some manufacturers are now complaining that if they were to list all of them, ridiculously large labels would be needed. In fact the whole of the container could be covered in such a label, says the Tokyo-based National Association of Bento Manufacturers (NABM). It complains that the new labelling laws – compounded by the requirement to list 24 food items containing genetically modified organisms – have made life difficult particularly for small-to-medium-sized companies which make up the bulk of its members. The Japanese law also requires ‘quality’ labels on processed foods and ‘place of origin’ labels on perishable foods.
“If one of our members fails to indicate all the ingredients used, no matter how small the amount, allergic reactions might result in the consumer, and the bento maker will be held accountable for such cases. Some bento makers will need until next spring to comply with the regulation,” says a spokesman for the association.
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By GlobalDataTwelve-month grace period
Fortunately for the nation’s bento makers there is a one-year grace period to comply with the new regulation and the government has made some other concessions to this section of the catering industry. The Health Ministry made several changes, allowing the use of shorter kanji (Chinese style) characters instead of the longer phonetic, cursive hiragana characters for some products (not all Japanese can read the more difficult kanji).
An agreement has also been ironed out with NABM to list the presence of the five ingredients most likely to cause a serious allergic reaction – flour, buckwheat flour, eggs, milk and peanuts – for the entire bento rather than for each menu item.
In addition, the government recommends the citing of 19 other ingredients that are also known to cause allergic reactions including abalone and squid. To their credit bento makers say they plan to indicate the presence of all 24 ingredients.
The nation’s larger Bento outlets – the convenience stores, however say they are at a loss as to what all the fuss is about. One of the largest store chains, Lawson, says that HMR including bento boxes, rice balls, and other dishes accounts for about 30% of total sales at their 24- hour outlets.
Major players already complying
“Lawson and its fast foods manufacturers started to comply with JAS Law on April 1, when the law took effect. We changed our labelling – the typeface and
“yet another test of endurance for the ‘little man’ in the face of increased big business competition” |
“Even before the law took effect Lawson had for some time labelled ingredients which potentially cause allergic reactions so it wasn’t necessary for us to enlarge the size of labels.”
It is clear that the majority of back street operations are finding the latest changes to their fragile businesses yet another test of endurance for the ‘little man’ in the face of increased big business competition. But many are still upbeat. After all, in the land of ‘Fires and Earthquakes’ it will take more than a little red tape to put the country’s indomitable small businesses under.
By Michael Fitzpatrick, just-food.com correspondent
