The Ministry of Agriculture, Forestry and Fisheries accepting public comments on the "Proposed Japanese Agricultural Standards for Processed Foods Suitable for Vegetarians or Vegans"
The Ministry of Agriculture, Forestry, and Fisheries (MAFF) is currently inviting public comments on the ‘Draft Japanese Agricultural and Forestry Standards for Processed Foods Suitable for Vegetarians or Vegans’ and ‘Draft Japanese Agricultural and Forestry Regulations on Management Methods for Restaurants and Other Establishments Serving Vegetarian or Vegan Foods.’.
Tokyo Vegan is not a part of the JAS project team, however, as a member of the Vege Council, we have had the opportunity to make some suggestions and provide feedback at informal opinion exchange meetings. Although some of our suggestions have been adopted we feel the final draft standard still has some questionable provisions.
We are sure that everyone also has their own opinions. We invite you to send them your public comments (in JAPANESE) in your own words. Or, you are welcome to copy and paste our comments (In Japanese above). The deadline is Friday 10 June at 11:59 pm. The English version of our Tokyo Vegan public comment on the Vegetarian & Vegan JAS proposals is below:
(Please note that the English translation of the VEGETARIAN & VEGAN JAPAN AGRICULTURAL STANDARD PROPOSAL is an unofficial translation.)
Tokyo Vegan Comments On the Vegetarian & Vegan JAS Proposals for Products and Restaurants:
(Please note that the English translation of the VEGETARIAN & VEGAN JAPAN AGRICULTURAL STANDARD PROPOSAL is an unofficial translation.)
ベジタリアン又はヴィーガンに適した加工食品の日本農林規格案についての意見・情報の募集について
ベジタリアン又はヴィーガン料理を提供する飲食店等の管理方法の日本農林規格案についての意見・情報の募集について
Proposed Japanese Agricultural Standards for processed foods suitable for vegetarians or vegans.
1 Scope of application
Comment: Delete the words: “(complete( strict) vegetarians)” and replace with just “vegan”.
Reason: The description “complete (strict) vegetarian) is open to various interpretations. It`s a mistranslation and possible that it will misrepresent veganism.
4.5 Food suitable for vegans
a) “Ingredients and additives of animal origin shall not be used as primary ingredients. In addition, raw materials and additives of animal origin (excluding processing aids) shall not be used as secondary raw materials. Also, primary raw materials and additives of animal origin (excluding processing aids) and chitosan from animal bone charcoal and crustaceans as processing aids must not be used as secondary raw materials.”
Comment: Change to “No raw materials, additives or processing aids of animal origin shall be used at any stage of production.”
Reason: Vegan products are commonly considered to be products that are free from animal ingredients, additives, and processing aids of animal origin at any stage of production, regardless of the primary ingredient. Tertiary ingredients often contain ingredients of animal origin (e.g. beef tallow as a tertiary ingredient in shortening, which is a secondary ingredient). The use of beef tallow, in this case, would not be covered by the present criteria and the product could be certified as ‘vegan’.
Also with regard to processing aids, a product is not suitable for vegan use if processing aids of animal origin are used at any stage of production. There are a variety of processing aids of animal origin, not only bone char and chitosan (e.g. icing lath (from fish) as a clarifying agent, casein (from cattle), albumin (from eggs)). By limiting the criteria for processing aids to bone charcoal and chitosan, it is possible that items not suitable for vegans could also be included.
4.5 a) “It should be noted that whether an ingredient is of animal origin is determined from the name of the ingredient or additive concerned.”
Comment: Delete. This cannot be judged from the name alone but should be thoroughly (reasonably in writing, etc.) examined by the certification body.
Reason: There are many substances that cannot be judged from their names. For example, in the case of shortenings, emulsifiers, margarine, amino acids, protein hydrolysates, etc., it cannot be judged whether they are of animal origin from the name alone.
4.5 b) “Operators under a) and b) of bullet 1 shall not have any animal tests on dishes suitable for vegans carried out by manufacturers etc., except where there is a mandatory and regulatory requirement.”
Comment: Delete “except where there is a mandatory and regulatory requirement to do so”.
Reason: No exception should be made as animal testing is not suitable for vegans for any reason.
6 Labelling
a) “on the containers and packaging of processed food products“
Comment : Change to: “on the containers and packaging of processed food approved to this standard (with the JAS Mark)”.
Reason: Ambiguity in the wording of this item should avoid a situation where, later on, only JAS Marked food products can be labeled with vegan-related terms or a mark indicating that they are vegan. Therefore, it should be clearly stated that “vegan products that do not carry the JAS Mark can continue to use terms such as ‘vegan’ and vegan certification on a voluntary basis”. If this provision were to apply to all food products other than those approved under the VegJAS standard (bearing the JAS Mark), it could become a stumbling block to the promotion of veganism which would be a complete reversal of the original intent.
Proposed Japanese Agricultural and Forestry Regulations on Management Methods for Restaurants and Other Establishments Serving Vegetarian or Vegan Foods.
1 Scope of application
a)
Comment: Delete the words: “(complete(strict) vegetarians)” and replace with just “vegan”.
Reason: The description “complete (strict) vegetarian) is open to various interpretations. It’s possible that it will misrepresent veganism.
4.5 Food suitable for vegans
a) “Ingredients and additives of animal origin shall not be used as primary ingredients. In addition, raw materials and additives of animal origin (excluding processing aids) shall not be used as secondary raw materials. Also, primary raw materials and additives of animal origin (excluding processing aids) and chitosan from animal bone charcoal and crustaceans as processing aids must not be used as secondary raw materials.”
Comment: Change to “No raw materials, additives or processing aids of animal origin shall be used at any stage of production.”
Reason: Vegan products are commonly considered to be products that are free from animal ingredients, additives, and processing aids of animal origin at any stage of production, regardless of the primary ingredient. Tertiary ingredients often contain ingredients of animal origin (e.g. beef tallow as a tertiary ingredient in shortening, which is a secondary ingredient). The use of beef tallow, in this case, would not be covered by the present criteria and the product could be certified as ‘vegan’.
Also with regard to processing aids, a product is not suitable for vegan use if processing aids of animal origin are used at any stage of production. There are a variety of processing aids of animal origin, not only bone char and chitosan (e.g. icing lath (from fish), casein (from cattle), albumin (from eggs)as clarifying agents). By limiting the criteria for processing aids to bone charcoal and chitosan, it is possible that items not suitable for vegans could also be included.
4.5 a) “It should be noted that whether an ingredient is of animal origin is determined from the name of the ingredient or additive concerned.”
Comment: Delete. This cannot be judged from the name alone but should be thoroughly ( reasonably in writing, etc.) examined by the certification body.
Reason: There are many substances that cannot be judged from their names. For example, in the case of shortenings, emulsifiers, margarine, amino acids, protein hydrolysates, etc., it cannot be judged whether they are of animal origin from the name alone.
4.5 b) “Operators under a) and b) of bullet 1 shall not have any animal tests on dishes suitable for vegans carried out by manufacturers etc., except where there is a mandatory and regulatory requirement.”
Comment: Delete “except where there is a mandatory and regulatory requirement to do so”.
Reason: No exception should be made as animal testing is not suitable for vegans for any reason.
5.6.3 Informative labelling
b) “Ingredients not suitable for vegetarians.”
Comment: “ Add “vegan”. Ingredients not suitable for vegetarians and vegans
