Additional Outline for Japan’s Guideline on Cultivated Foods — Key Points Listed

At the “FY2025, 5th Subcommittee on Newly Developed Foods of the Food Sanitation Standards Council,” held on February 5, 2026, a draft table of contents and outline for Japan’s guideline on cultivated foods was released.

At this meeting, as part of the review of cultivated foods, the following related documents were presented:

📑Reference 2-1: Key Points for Safety Confirmation (revised based on the previous subcommittee meeting)

📑Reference 2-2: Draft Guideline Outline, etc.

Source: https://www.caa.go.jp/policies/council/fssc/meeting_materials/review_meeting_004/044980.html

Compared with the previous meeting on December 25, 2025（https://jaca.jp/2025/12/10967/）, there were no major additions of detailed items. However, because there were updates that could influence future operations and regulatory design, I would like to share two points.


【Two updates】

1) Handling of “changes to the manufacturing method” is explicitly stated in the draft guideline outline as an “item that should be included” 📝

First, a positive point is that how to respond when the manufacturing method changes is explicitly stated in the draft guideline outline as an “item that should be included.”

This was also something JACA clearly requested when we met with the Consumer Affairs Agency in November 2025: we asked for an initial view on what criteria would determine whether a change—such as scale-up—would require “re-application.”


2) An important indication regarding the scope of application of the Food Sanitation Act 👮‍♀️

In addition, the subcommittee secretariat stated that the scope of application of the Food Sanitation Act is “from the food-processing stage onward,” and that before that stage there is, in their view, no applicable law (※this understanding is based on oral explanations during the meeting).
 
This way of thinking aligns with the proposals made by JACA in 2022, and it is also a point we have raised in the request shared with the Consumer Affairs Agency on November 12, 2025.

 
JACA strongly supports this approach.

If we recognize cultured cells as a food ingredient and the cultivation process as ingredient production (not food processing), and conduct risk management at the stage of harvested cultured cells, we can avoid AUTOMATICALLY APPLY FOOD SANITATION LAW to the cultivated process, whose law doesn’t take into account the current cultivated food, and allow the government to conduct case-by-case approach for checking the food safety.

 
The avobe interpretation of Food Sanitation Law application let Japan have a mechanism where the entity that produced the cultured cells—the party that directly created the material—can carry out the application procedures, which could increase the speed of information exchange between the public and private sectors.
 
In Japan, there are some food companies that are considering purchasing cultured cells as a food ingredient and then producing processed foods from them. Thus, if the framework becomes fixed such that safety confirmation is required for each final product (not based on harvested cells), the burden of application procedures could fall on downstream food companies in Japan.

When cultured cells become a stable source of protein, enabling food companies to use that ingredient easily is important. (Of course, in the early stages, decisions will likely still need to be made on a case-by-case basis depending on product form.)

[Important Notes] ⏰
This content includes understandings based on oral explanations and discussions from the meeting livestream (video and audio). However, the livestream is not an official record; the official record (minutes) will be posted later on the Consumer Affairs Agency website.
Therefore, the translated and summarized content based on today’s meeting may be subject to change depending on officially published materials. For official information, please be sure to refer to the Consumer Affairs Agency’s published documents.