Of Japan’s three health-claim systems, Foods with Nutrient Function Claims is the simplest — and the one brands most often overlook because it needs no filing at all. If your product’s active ingredient is one of a fixed list of vitamins and minerals, Japan already tells you exactly what you may say about it.
This guide sets out which nutrients the system covers, why the wording is fixed rather than written by the brand, how the lower and upper intake limits work, and why no notification is needed.
Health supplements are foods, not medicines, and are not a substitute for medical treatment.
💬 Wondering if your formula already qualifies for a Nutrient Function Claim? We check it against the current list before you plan packaging copy. See Japan-made supplement OEM.
What Foods with Nutrient Function Claims is
It is the only one of Japan’s three health-claim systems that needs neither a government approval nor a pre-sale notification, because the nutrients, wording and limits are already fixed by law.
Foods with Nutrient Function Claims (栄養機能食品) covers a fixed list of vitamins, minerals and one fatty acid category that Japan’s government has already judged to have an established function and a settled safety margin. If a product’s daily intake amount of one of these nutrients falls within the government-set range, the manufacturer may state that nutrient’s function using the exact wording the law provides — without notifying the CAA and without an approval process.
The nutrients the system covers
Twenty nutrients qualify: one fatty acid category, six minerals and thirteen vitamins.
| Category | Nutrients |
|---|---|
| Fatty acid | n-3 fatty acids |
| Minerals (6) | Zinc, potassium, calcium, iron, copper, magnesium |
| Vitamins (13) | Vitamin A, vitamin B1, vitamin B2, vitamin B6, vitamin B12, vitamin C, vitamin D, vitamin E, vitamin K, niacin, pantothenic acid, biotin, folic acid |
This list has changed over time as nutrients have been added, so a brand should confirm the current version of Japan’s Food Labelling Standards (食品表示基準) rather than assume a past list still applies. Sunsho already has dedicated guides on several of these nutrients: see our vitamin A guide, vitamin B complex guide, vitamin C guide, vitamin D guide, vitamin E guide, vitamin K2 guide, folic acid guide, biotin guide, zinc guide, iron guide, magnesium guide, calcium guide, copper guide, potassium guide, omega-3 fish oil guide and our multivitamin guide.
💬 Combining several of these nutrients in one formula? Tell us the nutrients and amounts and we will check the combination against the current limits.
Why the wording is fixed, not written by the brand
Unlike Foods with Function Claims, a business using this system cannot phrase the function in its own words — it must use the government’s prescribed statement.
Because the CAA and Ministry of Health, Labour and Welfare have already settled the evidence behind each of these twenty nutrients, the law also settles how a package may describe the function, rather than leaving that to the seller. A product must carry the prescribed function wording for that nutrient, together with a required caution statement (for example, that the product should not be taken to excess, and that a varied diet across staple, main and side dishes is the basis of good nutrition) and a statement that it has not been individually reviewed by the CAA Commissioner. When a product carries more than one nutrient function claim or caution statement, identical statements may be combined rather than repeated.
| Nutrient Function Claims | Foods with Function Claims | |
|---|---|---|
| Wording | Fixed by law, cannot be reworded | Written by the notifying business, within its evidence |
| Filing before sale | None | Notification to CAA required |
| Scope | Fixed list of 20 nutrients only | Any ingredient the business can evidence |
How the lower and upper limits work
A product may only carry the nutrient function claim if its daily intake amount for that nutrient falls between a government-set lower and upper limit.
Japan’s Food Labelling Standards set a lower limit (roughly tracking a meaningful contribution to the nutrient’s dietary reference intake) and an upper limit (a safety ceiling) for each of the twenty nutrients, based on the amount contained in the product’s stated daily serving. Below the lower limit, the claim is not permitted because the amount is not considered functionally meaningful; above the upper limit, the claim is not permitted because the government has not judged that intake level safe for the general population under this self-certifying system. These limit values are revised from time to time, so a specification should reference the current Food Labelling Standards table rather than an older figure.
No notification needed
Because the nutrient, its function wording and its safe range are all fixed in advance, a business can put a Nutrient Function Claim on pack the moment its product meets the criteria, with nothing to file and no waiting period.
This is the main practical advantage over Foods with Function Claims: no evidence dossier to prepare, no CAA notification, and no health-damage reporting duty of the kind that now applies to FFC. The trade-off is equally practical — the brand cannot make any claim beyond the fixed wording, and the system only ever covers these twenty nutrients, never a botanical, amino acid or other ingredient outside the list.
Before you ask for a quotation
Confirming the current limit values and exact required wording before formulation avoids a relabel later.
- Which of the twenty nutrients your formula contains, and at what daily serving amount
- Whether that amount currently falls within the published lower and upper limits
- The current prescribed function wording and caution statement for each nutrient you intend to claim
- Whether any other ingredient in the formula needs a different Japanese health-claim route instead
💬 Ready to check your nutrient amounts against the current Japanese limits? Send us your formula and we will confirm what can go on the label.
Frequently asked questions
1. Do I need to notify the Japanese government to use a Nutrient Function Claim?
No. Unlike Foods with Function Claims, this system needs no pre-sale notification and no CAA approval — only that the nutrient amount falls within the published range.
2. Can I write my own wording for the nutrient’s function?
No. The wording is fixed by law for each of the twenty nutrients. A business can combine identical statements when a product carries more than one, but cannot change the wording itself.
3. What happens if my product’s nutrient amount is above the upper limit?
It cannot carry the Nutrient Function Claim for that nutrient at that serving size. The formula would need a lower daily amount, or a different claim route entirely.
4. Which nutrients are covered?
Twenty in total: n-3 fatty acids; the minerals zinc, potassium, calcium, iron, copper and magnesium; and the vitamins A, B1, B2, B6, B12, C, D, E, K, niacin, pantothenic acid, biotin and folic acid.
5. Can a multivitamin product use this system for several nutrients at once?
Yes, provided every nutrient claimed is on the list and each one’s amount falls within its own lower and upper limit; see our multivitamin guide for how a combined formula is typically specified.
Sources: Consumer Affairs Agency, “栄養や保健機能に関する表示制度とは” and “保健機能食品について” (caa.go.jp/policies/policy/food_labeling/health_and_nutrition_labelling/, caa.go.jp/policies/policy/food_labeling/foods_with_health_claims); Consumer Affairs Agency, food labelling training material on Nutrient Function Foods (caa.go.jp/policies/policy/food_labeling/health_promotion/pdf/food_labeling_cms206_20200730_02.pdf, food_labeling_cms206_20200730_03.pdf); Consumer Affairs Agency, current lower/upper limit table for Nutrient Function Foods, Appended Table 11 of the Food Labelling Standards (caa.go.jp/policies/policy/food_labeling/meeting_materials/assets/food_labeling_cms206_260120_17.pdf); Japan Health and Nutrition Food Association, “栄養機能食品の表示について” (jhnfa.org/eiyou4.html). Checked on 25 September 2026.