Japanese Food on the EU Market
What the law actually requires

Japan has long been associated in Europe with quality, precision and a culture of longevity — associations that sell well in functional food and dietary supplement categories. The EU–Japan Economic Partnership Agreement has further facilitated trade by eliminating or reducing duties on most goods. All this means more and more operators are considering placing Japanese food products on the EU market. It is essential, however, to understand that origin in a country with high standards does not exempt from the obligation to meet European standards. And those can be quite different from Japanese ones.

The starting point is Regulation (EC) No 178/2002, laying down the general principles of food law. It establishes a fundamental rule: food placed on the EU market must be safe, and responsibility lies with the operator acting within the EU — typically the importer. It is the importer, not the Japanese manufacturer, who is accountable to the authorities for product compliance. This principle governs everything that follows: the importer must know exactly what is being brought in, what it contains and whether it may legally be sold in that form in Europe.

Radiation controls — a chapter now closed

For over a decade, food imports from Japan were subject to additional radiation controls introduced after the Fukushima plant accident in 2011. They required certificates and radionuclide testing for certain products. It is worth knowing that this chapter has been formally closed: Implementing Regulation (EU) 2023/1453 repealed those special requirements with effect from 3 August 2023. This means Japanese food is no longer subject to EU radiation controls or to any obligation to attach radiation certificates. A significant simplification — though it does not exempt from any of the other requirements described below.

Novel food — the most common pitfall

This is where most Japanese projects fail. Regulation (EU) 2015/2283 on novel foods provides that any ingredient not significantly consumed in the EU before 15 May 1997 requires prior authorisation before it may be legally placed on the market. The problem is that many ingredients popular in Japan have a long history of consumption there — but not in Europe. From the EU perspective, they remain “novel” regardless of how long they have been on the Asian market.

This covers a whole range of trending ingredients: certain postbiotics and metabiotics, exotic plant extracts, selected forms of fucoidan (authorisation covers specific algal sources and intake limits), as well as molecules positioned around the longevity theme, such as NMN — which is currently not authorised in the EU as a novel food (despite a positive EFSA safety opinion from May 2026, proposing a level of approximately 300 mg/day, Commission authorisation is still pending). This is even more evident for products based on cutting-edge technologies, such as drinks containing exosomes or polynucleotides, which in their current form have virtually no route to market without their own authorisation.

flowchart TD
    A[Product from Japan] --> B{Contains novel\nfood ingredient?}
    B -->|Yes| C{Authorised in EU?}
    B -->|No| D{Supplement or\nregular food?}
    C -->|Yes| D
    C -->|No| E[STOP: Novel Food\nauthorisation required]
    D -->|Food supplement| F{Animal origin?}
    D -->|Regular food| G{Animal origin?}
    F -->|Yes| H[Veterinary control\n+ supplement notification]
    F -->|No| I[Supplement notification\nin Member State]
    G -->|Yes| J[Approved establishment\n+ TRACES + CHED-P]
    G -->|No| K[Standard customs\nclearance]

Food supplements — national frameworks still diverge

If the product qualifies as a food supplement, it falls within the scope of Directive 2002/46/EC. This harmonises the lists of permitted vitamins and minerals and their chemical forms, but many issues — above all maximum levels and the admissibility of botanical ingredients — remain at Member State level. As a result, the same Japanese supplement may be lawful in one EU country while exceeding a national limit or containing a plant on a national prohibited or restricted list in another. It is therefore wiser to choose one or two entry markets and adapt the product to them, rather than assuming uniformity across the entire Union.

Products of animal origin — a separate border pathway

A significant part of the Japanese health offering relies on marine and animal raw materials: fish collagen, squalene, fish oils. This triggers a distinct veterinary control regime. Importing such products from Japan requires that they originate from establishments approved for EU export, that appropriate official certificates accompany them, and that the consignment has been pre-notified in the TRACES system and enters through a designated border control post (CHED-P document). This is a completely different track from purely plant-based or vitamin products, which pass through ordinary customs channels.

flowchart LR
    subgraph SUP[Supplement pathway]
        direction TB
        S1[Composition\nverification] --> S2[Notification in\nMember State]
        S2 --> S3[National supplement\nauthority]
        S3 --> S4[Label + claims per\nReg. 1924/2006]
    end
    subgraph ANI[Animal-origin pathway]
        direction TB
        Z1[Approved establishment\nin Japan] --> Z2[Official certificate]
        Z2 --> Z3[TRACES notification\n+ CHED-P document]
        Z3 --> Z4[Border Control\nPost BCP]
    end
    A[Product from Japan] --> SUP
    A --> ANI

Contaminants, additives, hygiene

Regardless of category, all food must meet EU requirements on maximum contaminant levels, permitted additives and production hygiene. This is an area where Japanese and European standards can diverge in ways that are easy to overlook: a colourant or preservative routinely used in Japan may not appear on the EU list of permitted substances, and limits for certain heavy metals or other contaminants can be set differently and more strictly in the EU. Verifying composition from this angle is as important as assessing novel food status — and this is precisely where the most surprises arise when analysing real formulations.

Labelling and claims — where editorial work begins

Regulation (EU) No 1169/2011 specifies mandatory label information: name, list of ingredients, allergens, nutrition values, responsible operator details, storage conditions and much more — all in a language understandable to consumers in the given state. A Japanese label, however carefully prepared, virtually never meets these requirements directly and needs restructuring, not merely translation.

A separate and often underestimated challenge is claims. Regulation (EC) No 1924/2006 permits only nutrition and health claims from approved lists, while absolutely prohibiting the attribution of disease-prevention or treatment properties to food. Meanwhile, Japanese health marketing tends to be considerably bolder — product names or categories suggesting “calorie blocking”, “cancer protection” or prevention of specific conditions are unsustainable in the EU legal environment and must be redrafted before the product reaches the market.

Customs and logistics — here the news is actually good

Against the backdrop of the above requirements, customs matters are favourable. Thanks to the EU–Japan Economic Partnership Agreement, most goods of Japanese origin benefit — with a valid proof of origin — from preferential tariff treatment, often at a zero duty rate, which materially improves import economics. The VAT rate and clearance method depend on the product’s tariff classification (CN code), so establishing it correctly at an early stage removes most uncertainty at the border.

It must be remembered, however, that the tariff preference concerns customs duties only — it does not waive any sanitary or veterinary (SPS) requirements described above; a zero duty rate will still not allow a product that does not comply with food law to cross the border.

Conclusions

Placing Japanese food on the EU market is entirely feasible — provided it is treated as a regulatory project, not merely a logistics one. A significant part of a typical Japanese portfolio (collagen peptides, isoflavones, omega-3, liposomal vitamin C) has a relatively simpler route to market — though even these “easier” products usually require label and claims adaptation, confirmation that the given chemical form of a vitamin or mineral is permitted, and verification of limits applicable in the chosen national market.

The problematic items are usually flagship products based on novel ingredients, and it is precisely these that require early, clear-eyed assessment. The best initial investment is screening the entire range for novel food status and permitted ingredient levels — because this determines what can be sold immediately, what needs reformulation and what currently cannot be placed on the market at all.

Disclaimer: Tomasz Krawczyk — legal counsel specialising in EU and Polish food law and dietary supplements. supplemental.pl · foodlaw.ai. This material is for general information only and does not constitute legal advice in any individual matter.