Table 1. Global comparison of clean label definitions, regulations, and market characteristics

Category USA EU Japan Korea
Definition / concept No legal definition. Generally understood as No artificial, No preservatives, and Simple ingredients No legal definition. Based on the Food Information Regulation (FIR), emphasizing intuitive labeling No legal definition. Market centered on “No additives” and “naturally derived” concepts No legal definition. The term “No additives” is conditionally permitted under the Food Labeling Standards
Regulation / policy CFR Title 21 and A Food Labeling Guide revisions encourage clear indication of artificial colors, sweeteners, and preservatives FIR revision strengthens labeling of ingredient origins and additive use; initiative to reduce E-numbers Guidelines for “No additive” labeling in operation; certification mainly for traditional fermented foods Introduction of “Green Food Certification” (low-impact, eco-friendly standards) and “Smart Food QR” system
Market characteristics Led by major corporations such as General Mills, Kellogg’s, and Nestlé; large-scale clean label product lines launched Demand for additive-free and natural ingredient products growing rapidly, especially in France, Germany, and the UK Expansion of additive-free products based on fermented foods (soy sauce, miso, etc.) Early-stage market led by large companies such as CJ CheilJedang, Pulmuone, and Orion
Consumer perception Preference for “simple ingredient labels”; emphasis on safety and health image Strong demand for clear ingredient information; strong aversion to E-numbers “No additives” associated with health and premium quality Increasing interest in ingredient transparency; preference for additive-free ready meals and snacks, expanding among MZ generation
Limitations / challenges Lack of legal definition → reliance on company-driven marketing Inconsistent regulations among member states; need for EU-wide harmonization Insufficient international standardization → trade barriers in export markets Ambiguity in the regulation of “No additives” terminology; limited response to global certification standards
Future tasks Need to establish legal framework beyond voluntary standards Establishment of unified international standards (linked to CODEX) Regulatory alignment for global market competitiveness Integration with international standards, IP-based technology development, and institutional framework establishment