‘More of a marketing stunt’: Japanese expert questions credibility of FFC system and urges revisions to ‘old and complex’ regulations

Currently the Representative Director of the International Society of Sports Nutrition (ISSN), Dr Seiji Aoyagi has more than three decades of experience in research and commercial applications of sports nutrition.

His portfolio includes major firms like Kyowa Hakko Kogyo, Abbott, GSK, and Danone.

Speaking at the ISSN Sports Nutrition Conference 2023 in Shanghai, as part of Hi & Fi Asia-China, Dr Aoyagi made candid observations about food regulations in Japan.

“The law that differentiates food and drugs has been in effect from 1971 till now. Although Japanese companies have asked for revisions to the law, only foreign firms have been able to produce some results so far.​

“There are some ingredients and compounds that cannot be used in food and supplements, as well as product formats that are still listed under the drug category. For example, taurine, L-alanyl-L-glutamine, and products delivered via sublingual (under the tongue) or oral spray format,” ​said Dr Aoyagi.

Specifically, the compounds that were successfully re-categorised are L-carnitine by the efforts of Lonza in 2002, beta-hydroxy beta methylbutyrate (HMB) by Abbott in 2009, and beta-alanine by NAI in 2019.

Dr Aoyagi suggested that pressure from overseas firms, including Chinese nutrition giants, could help to fuel changes.

Health foods, or Foods with Health Claims (FHC), are further subdivided into four categories: Food for Special Dietary Uses (FOSDU), Foods for Specified Health Uses (FOSHU), Foods with Nutrient Function Claims (FNFC), and Foods with Function Claims (FFC).

FOSDU and SOSHU require regulatory approval, FNFC is subject to a self-certification system, while the FFC system enables businesses to label functions on foods by notification — the category that Dr Aoyagi finds most questionable.

“The FFC system introduced in 2015 opened up the market, but it is confusing and sometimes not right. It seems more of a marketing stunt to boost the industry. More than 5,000 products have been notified within eight years — it is not possible for all products to do what they claim, but the public is not aware and not getting the benefits [on the labels],” ​Dr Aoyagi told NutraIngredients-Asia​ after his presentation.

The FFC system had come under scrutiny​ for the way the products are scientifically evaluated. The Consumer Affairs Agency (CAA) has since announced that companies should adhere to PRISMA 2020 when selecting the types of systematic reviews to back up their product claims.  

State of Japan’s sports nutrition market​

The active and wellness market in Japan is valued at USD3.6bn, of which sports-related food and beverage products make up about 17% (approximately USD600m).

“Sports nutrition is not a big market, but it is growing, especially for protein. Among protein products, 72% have sports functions. Furthermore, the pandemic did not affect the segment’s annual growth rate of around 20%,” ​Dr Aoyagi shared.

Other segments that are gaining traction include amino acids for sport consumers, and soy for female consumers.

Notably, research has shown that anabolic response to a combination of essential amino acids (EAAs) and whey protein is greater than whey protein alone in young healthy adults.

In addition, the development of EAAlpha, a patented blend of nine EAAs with the addition of arginine, provides an enhanced alternative for brands looking to create high-performing muscle-growth supplements.

EAAlpha is clinically proven to be more effective than branched-chain amino acids (BCAAs), generic EAA blends, and whey protein in generating muscle protein synthesis, even in small doses.

A product that uses EAAlpha is DNS’s EAA PRO, which comes in 5g sachets and three flavours, and does not require protein shakers.

On the flip side, while jelly products are popular in Japan, only 8% are for sports nutrition.

Similarly, amid the large number of sports drinks and protein bars in the market, most of them are targeted at general public consumption rather than sports performance.
“Unlike in the US, meal replacement products are purchased by Japanese consumers more for weight management and not sports functions,” ​said Dr Aoyagi, who added that these findings could be partly due to the lack of awareness.

As of May 2023, there are only 464 certified sports dietitians in Japan.

The challenges in increasing this figure include the eligibility criteria (must be registered and experienced dietitians) and long course duration (three to five years to complete curriculum).

“Sports nutrition products should be developed based on both theoretical and practical expertise, such as knowledge in biochemistry and nutrient metabolism, and understanding of exercise physiology. The problem is that most products [in Japan] are developed by meal-focused nutritionists, who do not necessarily have the know-how of sports nutrition.” ​

As a partner of ISSN, GPNi (Global Performance Nutrition Institute) — a science-backed certification programme for sports and performance nutrition — is now available in Japan.

With the availability of the ISSN-Sports Nutrition Specialist exam as well, Dr Aoyagi hopes that it would bolster the industry’s development.