Lot Codes and Decoded Products

Committee:
Liquor
status:
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. The EBC has called on the Japanese Government since 2010 to take more proactive measures to resolve the issue and protect the safety of Japanese consumers. The EBC thus welcomes the NTAs intent to issue regulation to address the issue as expressed in meetings with the JWSIA and other sector associations this April and stands ready to work with the NTA on such draft regulation. We have been informed by the JWSIA that, in a meeting with the NTA, the agency shared their intention to take action to solve this issue. We believe that this opens up a window of opportunity to address this long-standing issue. This was then followed by another meeting with the NTA on 21 April 2023. During this meeting, the NTA indicated that it would like to exchange opinions with industry (JWSIA and other industry associations in the alcoholic beverages sector) toward the enactment of a system as an administrative measure limited (including the necessity of the system). JWSIA have agreed with that proposal and believe that we could gain a foothold and make real progress in resolving the lot-code issue in Japan. The EBC’s Liquor Committee members are supportive of the introduction of regulation by the nta, which stipulates that a prepacked food product should feature an identification number or mark (like a lot number, batch number or serial number) that identifies the producing factory and production lot of the food. Ensuring traceability in the supply chain is critical towards safeguarding Japan’s food safety and security. The EBC supports the NTAs intent to establish notice under Article 86 of the Liquor Trade Association Acts to eradicate the distribution of imported liquor without production lot codes. The EBC hopes to see clear progress on this issue in 2025.

Recommendations

To ensure the effective and efficient recall of prepacked food, we recommend putting in place regulation at the NTA level that:
  • Make it mandatory for alcoholic beverages to have a traceability mechanism (e.g. lot/batch codes);
  • 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 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 the identification of the ‘producing factory’ contained within the identification number or mark be allowed to be in ‘alpha numerical’ form, without the ‘producing factory’ needing to be specifically spelled out.