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Dear Dr. Robert Francis Kennedy, Jr.
Request to not treat Japanese agricultural products as "non-tariff barriers"
Japan has established rules for post-harvest pesticide use on imported agricultural products, removal of dangerous parts of beef, and year-round import of raw potatoes to protect Japanese consumers from danger.
Japanese citizen, consumer, cooperative, and farmer groups object to the report of the U.S. Trade Representative that calls these rules "non-tariff barriers."
I. Regarding the labeling of U.S. oranges and lemons According to a 2024 report from the U.S. Trade Representative, Japan has designated fungicides used after harvest as food additives and made labeling mandatory. U.S. agricultural products exported to Japan are required to be labeled because fungicides are used after harvest.
Because U.S. agricultural products are labeled with fungicides, Japanese consumers may have a wrong impression and have a negative impact on U.S. agricultural products, which constitutes a non-tariff barrier.
Rebuttal Japanese consumers say that the claim that labeling is a non-tariff barrier is wrong.
This time, the Liaison Committee Against Irradiated Foods investigated U.S. citrus fruits.
The results showed that six types of fungicides were listed on oranges (Photo 1).
In addition, navel oranges, which U.S. producers were asked to refrain from using fungicides, were sold with two types, TBZ and imazalil (Photo 2).
Three types of fungicides were listed on U.S. lemons (Photo 3).
No fungicides are used on domestically grown lemons (Photo 4).
Even now, efforts are continuing in Japan to import citrus fruits with reduced fungicides.
Japanese consumers appreciate the efforts of producers to reduce pesticide use. The U.S. Trade Representative's report concludes that labeling is a non-tariff barrier without any effort to reduce these pesticides.
Japanese consumers oppose the decision to determine that it is a non-tariff barrier without any effort to reduce such fungicides.
Japanese consumers are concerned that the negotiations between the US and Japanese governments will result in a change to the labeling of "fungicides" and "fungicides" as a single entity.
When this change occurs, Japanese consumers will respond by boycotting the product.
We request that Japanese consumers, especially US citrus producers and the US Trade Representative, seriously consider reducing the use of pesticides in citrus.
Photo1 Imazalil, Thiabendazole (TBZ), Azoxystrobin, Fludioxonil, Propiconazole, :pyrimethanil
Photo 2 Thiabendazole (TBZ), Imazalil,
Photo 3 Thiabendazole (TBZ), Imazalil, Fludioxonil,
Photo 4 ０
Progress
The reason for the increase in fungicides was external pressure． Imports of lemons and grapefruit were liberalized in 1971. At that time, the US government requested permission for three types of fungicides (biphenyl, OPP, TBZ).
In Japan, it was prohibited to add pesticides to food. However, under pressure from the United States, biphenyl was approved as a food additive. However, American companies had been using OPP and TBZ knowingly, illegally (1975).
This violation became a major social issue in Japan. The United States sent then Vice President Mondale to Japan, asking if they wanted to turn the Pacific Ocean into Tom Collins, to request that their use be allowed. In response to this pressure, then Prime Minister Fukuda approved three types of pesticides as food additives. Naturally, as they are food additives, they were required to be labeled. Japanese consumers have been campaigning against OPP due to reports of its bladder cancer and genotoxicity. The fact that the labeling of the increasing number of fungicides is a non-tariff barrier is the result of the US government and the US Potato Association calling for the use of more fungicides to be increased.
Japanese consumers have concluded that the unilateral criticism that the labeling is a non-tariff barrier is an unreasonable demand. In addition, since there are no total quantity restrictions on the types of fungicides, Japanese consumers are very worried that if the number of approvals increases, they will ingest many chemicals and bear the risk.
U． Issue of year-round import of raw potatoes According to the 2024 report of the Office of the United States Trade Representative, exports of U.S. potatoes to Japan are limited to potatoes for processing into chips. In March 2020, the United States made a formal request to Japan for market access for edible potatoes, and in September 2023, Japan submitted a final list of pests for edible potatoes. In a bilateral meeting on plant protection in September 2024, Japan informed the United States that it was making progress toward completing a pest risk assessment. It notes that it has been preparing for year-round import of raw potatoes for a long time and that conditions are being met with Japan. Japanese consumers are opposed to the U.S. and Japanese governments' lifting of the ban on year-round import of raw potatoes. At present, there is enough raw potatoes produced domestically. Imports of potatoes for chips have already been lifted for a limited period of time and for frozen chips. Japanese consumers are concerned about the risk of potato white cyst nematodes and viral diseases spreading within the country due to raw potatoes being used as seed potatoes. In addition, the Japanese government has approved the use of the potato fungicide difenoconazole (fungicide) at the request of the United States, but difenoconazole has been shown to cause liver cancer, cataracts, and neurotoxicity in animal experiments. The Japanese government will approve 4 ppm, which is 16 times higher than the acceptable daily intake (ADI) of 0.25 ppm. Japanese consumers will not accept this 4 ppm, and Japanese consumers oppose this unscientific standard value.
V．The issue of removing dangerous parts of beef for spongiform encephalopathy as a non-tariff barrier Removing dangerous parts of beef (mad cow disease prions) is an important test that gives Japanese consumers peace of mind when consuming imported beef. A report from the U.S. Trade Representative stating that removing dangerous parts is a non-tariff barrier has made Japanese consumers distrustful of imports of U.S. beef. This group campaigns to encourage Japanese consumers to ensure the safety of beef bowl chain restaurants, which consume large amounts of imported beef in Japan.
W. Japanese consumers oppose rice imports for reasons different from those of the Japanese government The report of the Office of the United States Trade Representative on Japan's rice policy pointed out that "Japan's rice import and distribution system is highly regulated and has low transparency, limiting U.S. exporters' effective access to Japanese consumers," and called it a non-tariff barrier. This criticism points out the contradictions in Japan's rice policy. However, it is different from the position of Japanese consumers. Japanese consumers believe that self-sufficiency in food is the basis for protecting the survival of the people. The wars of aggression and armed conflicts occurring in the world today are spreading in a chain reaction, forcing the people of conflicting countries into a situation where they cannot even secure food to live. In this situation, Japanese consumers are reminded that they are not even self-sufficient in the food they need to live. For Japan, rice is a production system that has been built up over thousands of years. However, after the Pacific War, Japan came to rely on food imports from the United States. Although the food supply-demand ratio has declined, efforts have been made to maintain self-sufficiency in rice, the staple food of the Japanese people. Japanese consumers will not accept the contents of the US Trade Representative's report, which ignores this social background and treats them in the same way as regular food ingredients. President Trump's decision on reciprocal tariffs has made Japanese consumers realize just how fragile Japan's social system is. With the US forcing change at such a rapid pace, Japanese consumers have no choice but to launch a movement to protect their own survival. To avoid this, we urge you to advance discussions through mutual cooperation.
Sincerely yours,
Hiroshi Satomi.DPH
Former professor Hiroko Kubota
Anti-Irradiated Food Liaison Committee: Formed in 2006 by 54 organizations and individuals.
Members：The Japan Housewives' Federation, Japan Consumers' Federation, Food Safety and Surveillance Citizens' Committee, Tokyo Regional Women's Organizations Federation, Japan Organic Agriculture Research Association, Food Irradiation Network, Health Information Research Center, Consumers' Cooperative Pal System Tokyo, All Japan Farmers' Union Federation, and other individuals．
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