In Japan, post harvest fungicides (PHF) are classified as food additives.
THIS REPORT CONTAINS ASSESSMENTS OF COMMODITY AND TRADE ISSUES MADE BY
USDA STAFF AND NOT NECESSARILY STATEMENTS OF OFFICIAL U.S. GOVERNMENT
GAIN Report Number: JA2021
Guide to Japanese Labeling Requirements for Post Harvest
Food and Agricultural Import Regulations and
Standards - Narrative
In Japan, post harvest fungicides (PHF) are classified as food additives. As such, Japan requires
exporters to label produce treated with (PHF) and detail their usage. This report explains the purpose
of PHF labeling and provides examples of Japan’s labeling requirements for export packages and
display requirements at the retail point of sale.
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.
The pictures below are examples of current PHF labeling on imported cartons.
Photo 1: U.S. Export packages of citrus products at Tokyo Ohta wholesale market. PHF information
(Product-Orange, Fungicide - Tiabendazole ( TBZ) and Imazalil) are identified with stickers on each
Photo 2: U.S. Export packages of citrus products at Tokyo Ohta wholesale market. PHF information
(Commodity/Name – Minneola Tangelo, Fungicide – Imazalil, Tiabendazole used) is lithographed on
According to the Japanese Government, the purpose of the label on export packages is to convey PHF
information down to retailers as retailers who sell imported fruits individually are required by
administrative guidelines to prepare in-store signs/label to display PHF information at the retail point of
sale. This information is usually displayed on a small sign next to unpackaged fruit which detail each
chemical used and their respective purpose.
Photo 3: Fungicide – Example of in-store signs of PHF for grapefruits from South Africa.
Left photo: Fungicides: Thiabendazole (T.B.Z.) and Imazalil
Right photo: Fungicides: Sodium o-Phenylphenate (OPP-NA), Thiabendazole (TBZ), Imazalil
Photo 4: Example of label on individual packages for lemon from the U.S.A.
Left photo: Individual package at a retail store.
Right photo: American product, lemon, fungicides (Thiabendazole, Imazalil and Fludioxonil) are used, 2
In instances where retailers sell fruit in individual packaging, labeling should be used on each package.
This information should include: country of origin, product name, PHF information and number/volume.
Usually this packing process is conducted in Japan. If U.S. packers make their own individual packing
or individual wrapping of their products, importers will most likely ask for the PHF label to be displayed
on both the outside of the export package as well as the individual packages in the box.
Please note that this report is written based on general labeling rules and current empirical practices.
Packers may get various requests from importers regarding PHF labeling. Hence, this report is meant to
clarify between what it is actually required by the Japanese government and what might be simply
importer preferences/requests. For more information on labeling practices, please contact the
FAS/Office of Agricultural Affairs’ labeling analyst at firstname.lastname@example.org .