Allergen Labelling: the April 2026 Revision — 9 Specified Raw Materials, 20 Equivalent Items

What changed on 1 April 2026

In an administrative notice dated 1 April 2026 (Reiwa 8), the Consumer Affairs Agency amended the Food Labelling Standards to add cashew nut as a specified raw material. The same notice amended the Director-General notification “Concerning the Food Labelling Standards” to add pistachio to the items equivalent to specified raw materials. The amendment added two items, giving nine mandatory and twenty recommended — twenty-nine in total.

• Cashew nut — added to specified raw materials (mandatory). A two-year transitional period applies
• Pistachio — added to items equivalent to specified raw materials (recommended). This sits outside the transitional framework; the notice asks operators to label “as promptly as possible”

These are not two unrelated changes. Regarding pistachio, the notice asks operators to label promptly “taking into account cross-reactivity with cashew nut, newly added as a specified raw material”. For a line that handles tree nuts, checking only one of the two does not close the matter.

The current lists (as of April 2026)

Specified raw materials — mandatory, 9 items. The legal basis is the Food Labelling Standards (Cabinet Office Ordinance No. 10 of 2015) under Article 4(1) of the Food Labelling Act (Act No. 70 of 2013).

Shrimp/prawn, cashew nut, crab, walnut, wheat, buckwheat, egg, milk, peanut

Items equivalent to specified raw materials — recommended, 20 items. The basis is the Director-General notification “Concerning the Food Labelling Standards” (Shoku-Hyo No. 139, 30 March 2015).

Almond, abalone, squid, salmon roe, orange, kiwifruit, beef, sesame, salmon, mackerel, soybean, chicken, banana, pistachio, pork, macadamia nut, peach, yam, apple, gelatin

What matters in practice is that the two lists rest on different instruments. The mandatory list sits in a Cabinet Office Ordinance; the recommended list sits in a Director-General notification. They are amended and announced through different channels, so watching only one of them means missing amendments to the other.

Why cashew nut — the prevalence survey

Specified raw materials are designated on the basis of case numbers and severity from a nationwide survey conducted roughly every three years. In the FY2024 (Reiwa 6) “Nationwide Survey of Health Damage Caused by Immediate-Type Food Allergy” (N = 6,033), the breakdown of causative foods was:

• Hen’s egg 26.7% / walnut 15.2% / cow’s milk 13.4%
• Wheat 8.1% / peanut 7.0% / salmon roe 5.7%
• Cashew nut 4.6% / kiwi 3.0% / buckwheat 0.4%

Cashew nut sits at 4.6%. The figure to read alongside it is walnut: made mandatory in 2023, it now ranks second at 15.2%. The weight of tree nuts keeps rising, and the next survey may well move further items. A specification template hard-coded to “the current twenty-nine” will need rebuilding every few years.

Amendment history — items are removed, not only added

• 1 April 2026 — cashew nut added as a specified raw material; pistachio added to the recommended list the same day
• 28 March 2024 — macadamia nut added to the recommended list and matsutake mushroom removed
• 9 March 2023 — walnut added as a specified raw material
• 19 September 2019 — almond added to the recommended list

Removals are the part that gets missed. Matsutake left the recommended list in 2024. Where an old specification template or internal material master is still in use, a company keeps managing an item that no longer applies while the newly added ones stay absent. Any process that only appends “additions” at each amendment ends up in exactly this state.

What to move first on the procurement side

• The allergen field in your specification template — update to the twenty-nine items (9 mandatory + 20 recommended). When asking suppliers for revised documents, state the template version; otherwise they come back on the old form
• Cross-contact on production lines — cashew nut and pistachio are cross-reactive. Where a contract manufacturer handles tree nuts, confirm both together
• “May contain” is not permitted — a bare possibility statement is not accepted. Where cross-contact cannot be excluded, a precautionary statement is used instead (e.g. “This product is made in a factory that also produces items containing ○○.”)
• Alternative notations — a notation recognised as identical to the specified raw material may be used in its place; in Japanese, the several ways of writing “egg” are the standard example
• Labelling format — individual labelling is the rule, with collective labelling permitted as an exception. Check that the information you hold from the raw material side supports either format

A transitional period is time to switch the printed label, not time to defer the checking. Changing packaging has upstream steps, and none of them can be scheduled backwards from a deadline until the raw-material information is in hand.

FONTIA materials and the specified raw materials

Among the materials we handle, the following may fall within the specified raw materials or the recommended list. Each can be confirmed in the allergen field of the specification.

• Gelatin (recommended) — Porcine Skin Gelatin P100, P250, P280, P300
• Salmon / mackerel (recommended) — fish collagen and the fish oil range. The source species differs by product, so confirm individually
• Soybean (recommended) — soybean extract
• Pork (recommended) — chondroitin sulfate (porcine origin), 70% and 20%

Where the question is switching a capsule shell from animal to plant origin, HPMC capsules are the alternative. We cover the comparison with gelatin capsules separately.

For specifications, samples or a quotation, please use the contact form. If you require a particular allergen-field format, tell us at the time of the request and we will prepare it on that form.