New labeling standards for hams and sausages regarding meat origin

The Japan Fair Trade Commission (JFTC) and the Consumer Affairs Agency (CAA) have approved partial amendments to the Fair Competition Code concerning the Labeling of Hams and Sausages, and announced them in the Official Gazette on October 19, 2026, as JFTC Notification No. 7. The amendments come into effect on the same day as the notification of approval. The target entities are manufacturers, processors, and importers/sellers of hams and sausages, and the revision of labeling rules extends to both the emphasized labeling of raw materials and advertising methods.

Positioning of Industry Self-Regulatory Rules Based on the Premiums and Representations Act

The basis for the notification is Article 36, Paragraph 1 of the Act against Unjustifiable Premiums and Misleading Representations (Act No. 134 of 1962), and the details of the approval were published based on the provisions of Paragraph 4 of the same article. The subject of the amendment is the Fair Competition Code concerning the Labeling of Hams and Sausages (JFTC Notification No. 35 of 1992).

The application was submitted by the Fair Competition Council for Hams and Sausages (Chairman Nobuhisa Igawa), and the Japan Fair Trade Commission approved the partial amendments on September 14, 2026. The notification explicitly states that the reason for approval is that the contents of the amendments are recognized as conforming to the approval requirements set forth in each item of Article 36, Paragraph 2 of the said Act. The notification was signed by Eiji Chaya, Chairman of the Japan Fair Trade Commission, and Natsuko Horii, Commissioner of the Consumer Affairs Agency.

Unification of Emphasized Labeling of Raw Meats with Enforcement Regulation Standards

The core of the amendment is the reorganization of provisions regarding “labeling that emphasizes the raw meat used” in Article 4 of the Code (Labeling Standards for Specific Matters).

• Emphasized labels such as “All [Meat Type]” or “[Meat Type] 100%” must now be displayed according to the standards defined in the Enforcement Regulations.
• When displaying that raw meat has “distinctive characteristics,” it is similarly required to follow the standards of the Enforcement Regulations.
• The definition of raw meat (raw livestock meat or raw organ meat) has been moved to the provisions for emphasized labeling, clarifying the application relationship between the two.

Additionally, the wording of Article 1 (Purpose) and Article 3 (Required Labeling Items) has been revised to organize the relationship with labeling obligations based on the Food Labeling Standards (Cabinet Office Ordinance No. 10 of 2015).

Explicitly Defining Stealth Marketing as Unjustifiable Representation

A new item has been added to Article 5 of the Code (Prohibition of Unjustifiable Representations), positioning “stealth marketing”—representations made by a business operator regarding the trade of hams and sausages they supply, which are difficult for general consumers to identify as such representations—as a prohibited act. This measure can be interpreted as a response to the fact that promotions via SNS and influencers can influence product selection.

Effective Date and Transitional Measures

• The effective date is the date of the public notice of certification by the Japan Fair Trade Commission and the Commissioner of the Consumer Affairs Agency (October 19, 2026).
• Transitional measures have been established such that labeling performed by business operators prior to the effective date shall continue to follow previous examples.

Manufacturers and importers/distributors need to re-examine the supporting documentation for package labeling that emphasizes the origin or composition of raw materials. For consumers, the transparency of information used for judgment will increase both for labeling that claims the type or composition of meat and for promotions where it is difficult to discern that they are advertisements.

Source: Published in the Official Gazette (October 19, 2026), Japan Fair Trade Commission Notice No. 7 (Matter regarding the certification of partial amendments to the Fair Competition Code concerning the labeling of hams and sausages). The legal basis is Article 36 of the Act against Unjustifiable Premiums and Misleading Representations (Act No. 134 of 1962), and the subject of the amendment is Japan Fair Trade Commission Notice No. 35 of 1992.