In April 2011, Japan’s Consumer Affairs Agency (CAA) revised Volume 2 of the Q & A book in order to clarify the issues of “use by date” and “best before date” which are often misunderstood by consumer
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: JA1048
Consumer Affairs Agency Defines “Used By Date” and “Best
FAIRS Subject Report
In April 2011, Japan’s Consumer Affairs Agency (CAA) revised Volume 2 of the Q & A book in order to clarify the
issues of “use by date” and “best before date” which are often misunderstood by consumers. CAA also defined
the “one third rule” as a voluntary business practice and stated that abolishing this rule could help reduce food
The Q & A book is used as an operational guideline and serves as a reference for processed foods manufactures
and importers. As there was no regulatory change due to these revisions, U.S. importers of processed foods
may continue to use current labels and use the Q & A book as a source of information when creating a new
In April 2011, Japan’s CAA officially published a revised Volume 2 of the Q & A for labeling of processed foods.
The major contents of this revision were previously reported by GAIN report JA0036 “Consumer affairs Agency
Reviews Product Expiration Labeling Policy” written in December, 2010. The Q & A book focuses on the issues
of “use by date” and “best before date”. The revised Q & A clearly defines date marking and provides examples
of easy-to-understand optional explanations on labels. There was no regulatory change due to this revision.
Usually labeling for imported processed foods is prepared by Japanese importers who attach a sticker on each
package of products. As there was no regulatory change, importers may continue to use the same label as
before or revise their labels based on the new Q and A. As such, this revised document will have little impact
on imported processed foods from the United States.
To gather information for this revision, CAA solicited opinions by public comment and through opinion
There are five major issues in this revision.
1. Clarifying the meaning of “used by date” and “best before date”:
Under current Japanese law there are two types of date marking for processed foods in Japan. The first
type of date marking requires a “use by date”, intended for foods that are deemed to have a relatively
short shelf life (five days or shorter). This includes foods found at delicatessens, boxed lunches
(bentos), sandwiches and other prepared foods and meals. The date is labeled on the package in a
year-month-date format. Some manufactures choose to add a “use by time” and list the conditions
under which the date marking is applicable. This kind of date marking implies that the product should
not be eaten after the date indicated on the label.
The second type is the “best before” date, which is applied to products with a long shelf-life such as
processed foods, including frozen foods and snacks. The best before date indicates the date or month
that the initial quality of the product can be expected to be maintained if stored under the conditions
specified on the package. The year-month-date format is used for durations of three months or less,
and, if the expected duration is longer than three months, the product must bear a best before date in
the year-month format. The implication of this kind of date marking is that even if the product date
marking expires, the food can be expected to remain edible. The CAA recommends the use of phrases
indicating that the product remains edible even beyond the “before date”. Most U.S. products are
labeled “best before date” because of its long shelf life (longer than five days).
Of course, both the best before and use by date marking systems are only good prior to opening the
package. Once the package is opened, CAA recommends that the food be consumed as soon as
Examples of optional explanations:
- Use by date “Do not eat after the date“: yyyy-mm-dd
- Use by date: “Please finish by”: yyyy-mm-dd”
- Best before date “You can eat deliciously by the deadline“ yyyy-mm-dd
- Best before date “It does not mean immediately non-edible even after the date“: yyyy-mm-dd
- Best before date: “You can enjoy the food until around”: yyyy-mm.
2. Promoting the listing of information for storage condition of products:
- CAA encourages manufactures to provide information to consumers by including instructions in each
package to advise quick consumption after breaking the package seal.
- It is appropriate to inform consumers that the best by date is valid until opening an air-sealed
Examples of optional explanation:
- Best before date: yyyy-mm-dd (The date is good with the condition of an intact air-sealed package)
- Manufactures are recommended to provide additional information to indicate quality deterioration of
products such as the color of food, change in flavor, and expansion of package.
3. Manufactures/distributors cannot extend a date marking once set, even if it is scientifically rational:
There were several incidents that occurred related to this issue. This is a clear message from CAA that it
is illegal to extend a date marking once it is set.
4. CAA clarifies the concept of setting the date mark by manufactures:
CAA states that manufactures do not have to examine all indicators such as a microbial test, laboratory
test, and organoleptic test, in order to set date marking for their products. Manufacturers can use
industry guidelines when choosing to test items. CAA recommends making the methodology to set
date marking available to consumers on a website.
5. Clarifying the “one third rule” is a voluntary business practice and is not required by CAA:
CAA is trying to weaken this rule in order to reduce food waste. The “one third rule” is widely used in
the distribution of processed foods and is a tacit agreement to share the risk of having unsalable stock
among manufactures/distributors, wholesalers/retailers and consumers. The first third of a timeframe,
between the production and best before dates, is for the delivery of a product to retailers. The second
third is for sales, with the final third as recommended time for use by consumers. Some retailers
return unsold products to manufactures/distributers after the second third period ends, with returned
products then being disposed. Please see the figure on page 2 of the linked document below.
MAFF explanation of one third rule (in Japanese)
As importers of U.S. processed foods can continue to use current labels, Post expects little impact on exports. It
is up to importer to change their label based on the new Q & A book.
Link to GAIN JA0036
Sources of information:
News release on April 8, 2011: counter measures to improve date marking system of processed foods
Date marking (Used by date, Best before date) chart (Japanese)
Q & A book about date marking of processed food revised in April 2011 (Japanese)
Quality labeling standard of processed foods as of September 30, 2011 (Japanese)
English translation of standards is not up to date but January 31, 2008 edition is available.