Japan's Positive List System for Food Additives
Japan uses a 'positive list' system under the Food Sanitation Act, which means only additives specifically designated as safe by regulatory bodies are permitted. This process involves a risk assessment by the Food Safety Commission of Japan (FSCJ).
Food additives fall into four categories: designated additives (synthetically derived or natural, specifically approved), existing food additives (natural substances with a history of use before 1995), natural flavoring agents (exempt if used for flavor in small amounts), and ordinary foods used as additives (substances like agar or red cabbage).
Approved Food Dyes in Japan
Many food dyes found in the US and Europe are approved in Japan, often with varying regulations. Designated colorings include Food Blue No. 1, Food Blue No. 2, Food Red No. 3, Food Red No. 40, Food Yellow No. 4, and Food Yellow No. 5. Natural colors like kuchinashi shikiso (gardenia pigment) and caramel coloring are also widely used. There's a growing preference for natural options, with some products labeled mutenka (無添加), meaning additive-free.
Comparison of Japanese, US, and EU Food Dye Regulations
Here is a comparison of food dye regulations in Japan, the United States, and the European Union:
| Feature | Japan (CAA/MHLW) | United States (FDA) | European Union (EFSA) |
|---|---|---|---|
| Regulatory System | Positive list (only pre-approved additives are allowed). | Positive list (additives are approved based on the Delaney Clause). | Positive list (E-numbers are approved based on scientific data). |
| Key Colorant Example | Food Red No. 3 (Erythrosine) is still permitted. | Food Red No. 3 was banned in 2025 based on animal studies. | Allura Red AC (Food Red No. 40) is permitted but requires warning labels on products. |
| Natural Dyes | Categorized as existing additives or ordinary food, widely used. | Approved alongside artificial dyes, also widely used. | Widely used; no E-number required for some natural extracts used solely for coloring. |
| Labeling | Additives must be listed separately from other ingredients, with clear names or collective categories. | Requires listing the specific certified color name (e.g., FD&C Red No. 40). | Additives are labeled with their E-number (e.g., E129 for Allura Red AC). |
How to Identify and Avoid Dyes in Japan
To identify food dyes in Japan, look for 着色料 (chakushokuryō) on labels. Additives are often listed separately or after a / symbol, followed by the dye's specific name, such as 赤色102号 (aka-iro 102-gō, Red No. 102). Products labeled 無添加 (mutenka) are additive-free. Common foods containing dyes include kamaboko (fish cakes) and pickles (often with Red No. 3), and various sweets and snacks.
The Ongoing Evolution of Japanese Food Dye Regulations
Japanese food additive regulations are continuously reviewed by the CAA and FSCJ. Reviews, like the one for Red No. 3 following the US ban, demonstrate a proactive approach to safety based on new scientific data. These ongoing evaluations ensure regulations adapt to new findings, impacting both consumers and manufacturers.
Conclusion
Food dyes are permitted in Japan under a strict positive list system, not a blanket ban. Both synthetic and natural colorings are approved following safety evaluations and have clear labeling requirements. Japan's regulations can differ from other countries, as seen with Red No. 3. Understanding Japanese labeling and the regulatory context is crucial for consumers.
Further Reading: For the official and comprehensive list of permitted food additives in Japan, including food colorings, refer to the resources provided by the Ministry of Health, Labour and Welfare (MHLW) and the Consumer Affairs Agency (CAA).
