Lot Codes and Decoded Products

Committee:
Liquor
status:
Good progress
Published:
In Japan, the display of producer lot codes (traceability information) on liquor products is not mandatory, although it is recommended in the administrative guidelines of the Ministry of Health, Labour and Welfare (MHLW). The importance of traceability information has been recognized by regulators in key regions and countries of the European Union, the United States, Australia and Great Britain amongst others such as Singapore. 31 out of 34 OECD countries mandate the use of lot codes on the labels or containers of alcoholic beverages and prohibit the removal, tampering with and covering up of lot codes.

Recommendations

To ensure the effective and efficient recall of prepacked food, we recommend putting in place regulation at the NTA level that:
  • Specify that the lot identification system be based on the brand manufacturer’s original lot code, which should be determined in each case by the producer, manufacturer or packager of the prepacked food. This specification is critical to ensuring that an importer, reseller or retailer cannot add a sticker with their own “lot identification” to cover the one originally put on the bottle during the production process, thereby nullifying the use of such an identification system for traceability purposes.
  • Specify that tampering with / removing lot identification is illegal and that strict sanctions are foreseen to restrict the import, distribution, and sale of products without original lot identifications or with removed/tampered lot identification at the point of importation, as well as restricting the sale of products whose original lot code was in any way defaced or covered.
Moreover, to ensure that all businesses are able to fully comply with the proposed amendments, we would like to seek clarity on the following points:
  • That lot codes are not required to be placed only on labels, but instead can be permanently affixed or displayed in other manners, including being embossed, laser-etched on bottles or applied by other means
  • That if a system for registering lot codes with the authorities is established, the associated administrative requirements be kept to a minimum, in order to reduce burden and ensure efficiency for both the authorities and industry.