The Japan Health Industry Promotion Association (JHIPA) has published an article outlining what businesses should review as the transition period for the revised GMP and labeling requirements under Japan’s Foods with Function Claims system ends on August 31, 2026.
This article introduces JHIPA’s guidance and adds a practical perspective from the Japan Institute of Science and Health (JSH), including points related to contract manufacturing, packaging changes, digital sales pages, and products intended for overseas markets.
JHIPA article: Foods with Function Claims: The GMP and Labeling Transition Period Ends on August 31, 2026
Key points in the regulatory transition
Japan’s Consumer Affairs Agency has stated that the revised labeling provisions and GMP standards will apply to relevant foods manufactured on or after September 1, 2026.
The mandatory GMP requirements apply to notified Foods with Function Claims in tablet, capsule, and similar forms that use natural extracts and other applicable materials. Revised labeling rules include displaying the words identifying the product as a Food with Function Claims in a framed area at the top of the package, with the notification number placed nearby.
Foods manufactured, processed, or imported by August 31, 2026 may remain eligible for the previous labeling treatment under the transition measures. Businesses should therefore avoid judging all products with older labels solely by their presence in the market after September 1. Manufacturing, processing, or import dates and batch records must be reviewed.
Three practical checks highlighted by JSH
1. Do not treat outsourcing to an OEM facility as the end of compliance work
Compliance with GMP standards is not solely a matter for the manufacturing facility. The notifying business is expected to verify the relevant implementation status. When using an OEM or ODM partner, businesses should confirm the product’s regulatory scope, the facility’s management system, batch traceability from incoming materials through release, and escalation procedures for deviations, out-of-specification results, complaints, and health-related information.
Manufacturing agreements and quality agreements should clearly address change control, reporting deadlines, record retention, audits, and emergency communication.
2. Align packaging with e-commerce and sales materials
Updating the physical package is not sufficient if an e-commerce page, landing page, advertisement, or sales document continues to display outdated information.
The notified claim, notification number, recommended daily intake, directions for use, and caution statements should be checked across both the package and all consumer-facing sales content. When creating multilingual materials, businesses should also verify that translations do not broaden the meaning beyond the approved Japanese source.
3. Review destination-market rules separately for exported products
Compliance with Japan’s Foods with Function Claims system does not automatically mean that a product may be sold overseas with the same claims and labeling.
For Taiwan and other international markets, the eligibility of ingredients, specifications and certificates of analysis, local-language labels, functional claims, and import procedures must be reviewed under the destination market’s rules. If Japanese and export packaging are revised at the same time, artwork, production batches, and shipping destinations must also be strictly controlled.
August 31 should not be treated as the end of compliance
Regulatory compliance does not end with a one-time packaging update. Businesses need an operating system that continuously manages:
- confirmation of products and applicable requirements;
- ingredient specifications and manufacturing processes;
- GMP implementation and records;
- consistency across packaging, e-commerce, advertising, and sales materials;
- collection and escalation of complaints and health-related information after launch; and
- notification and document updates when ingredients, processes, or labeling change.
Where the notifying business, OEM facility, ingredient supplier, packaging vendor, and sales company are separate entities, responsibilities and change-notification routes should be agreed in advance.
Frequently asked questions
Do the new GMP requirements apply to all supplements?
No. They do not apply uniformly to every supplement. The requirements apply to relevant notified Foods with Function Claims in tablet, capsule, and similar forms using natural extracts and other applicable materials. Each product’s classification and notification should be reviewed individually.
Can products with older labels still be sold after September 1, 2026?
This cannot be determined from the label or inventory date alone. Transition measures may allow the previous labeling for foods manufactured, processed, or imported by August 31, 2026. The relevant dates and batch records should be verified.
Can a product compliant in Japan be sold overseas without further review?
No. Ingredient eligibility, labeling, advertising claims, and import documentation must be reviewed for each destination market.
Original article and official information
- JHIPA: Foods with Function Claims—Transition Period Ends on August 31, 2026
- Consumer Affairs Agency: Commissioner’s Press Conference, August 27, 2026
- Consumer Affairs Agency: Choosing Foods with Confidence
- Consumer Affairs Agency: Foods with Function Claims
This article introduces JHIPA’s publication and provides general business information. For individual products, please review the latest laws, notices, notification details, and destination-market requirements.