1. Why "Pesticide-Free" and "Reduced Pesticides" Words Disappeared from Food Labels
In the past, vegetable bags often had words like "pesticide-free" and "reduced pesticides." If a farmer wrote "pesticide-free" meaning they did not use pesticides while growing, buyers might interpret it to mean there were zero pesticides left in the soil or from neighboring fields [1]. The same word meant different things to the writer and the reader.
"Reduced pesticides" was also a problem. Looking at the bag, you could not tell what it was compared to, how much it was reduced, or whether the number of applications or the amount of residue was reduced [1]. So, guidelines were revised around 2003–2004 to organize labels. Now, "pesticide-free," "reduced pesticides," "chemical-fertilizer-free," and "reduced chemical fertilizers" are words that cannot be used on labels [1].
By the way, the word "organic" can only be used by people who grew crops in fields where pesticides and chemical fertilizers were, in principle, not used for at least 2 years before sowing or planting (3 years for perennial crops like fruit trees) and who received certification from a registered certification body [6]. It is a word that comes with a specific time period and third-party certification.
So, what is written on the bag instead of "pesticide-free"? The answer is in the phrase "half or less."
2. Who Decides What "Normal" Pesticide Use Means in Gunma Prefecture?
Looking at Gunma Prefecture’s certification standards for special cultivation, you find something interesting. The number of pesticide applications for "customary" (normal) cultivation is different for each crop and method. For greenhouse tomatoes, it is 48 times; for greenhouse cucumbers, 36 times; and for ordinary rice, 14 times [4].
The standard for special cultivation is "50% or less" of this customary level [2]. This means tomatoes can use up to 24 applications, and rice up to 7 [4]. If you calculate this, you see that the "half" amount for tomatoes (24) is more than the "normal" amount for rice (14). The word "half" alone does not let you compare the amount of pesticides used.
This "customary level" is set or confirmed by local governments like prefectures [3]. Hyogo Prefecture, for example, sets common numbers for major crops [3]. For crops not on the table, the person responsible for checking creates a standard based on local usage and gets confirmation from the municipality [1]. So, even for the same "half," the original number is different depending on the land and method.
So, how exactly are these "times" counted?
3. How Pesticide Applications and Fertilizer Are Counted Under the Rules
There are rules for counting. The number of pesticide applications is not counted by the number of days sprayed, but by each active ingredient used [1]. If you spray a medicine containing 2 ingredients once, it counts as 2 times. This is why Gunma’s table calls it "cumulative ingredient usage count" [4].
The range of what is counted is not just herbicides, fungicides, and insecticides used during cultivation. It also includes soil disinfectants before planting and seed disinfectants [1]. Pesticides used on seedlings you bought are also counted from the earliest stage available [1].
Fertilizers are compared only by the amount of nitrogen in chemical fertilizers. Phosphoric acid and potash are not part of the comparison [1].
Some pesticides are not counted. In a revision in March 2007, sulfur agents, vinegar, baking soda, sex pheromones, and copper agents that are allowed under organic JAS standards were excluded from the "pesticides to be reduced" [1][3]. Pesticides to be reduced are chemical synthetic pesticides, excluding those allowed under organic JAS.
The "half" on the bag is a result achieved on two different rulers: the count of "pesticides to be counted" for pesticides, and the amount of nitrogen for fertilizers [2]. Reducing only one side does not make it special cultivation. So, what is written on the bag for vegetables grown this way?
4. How to Read Cultivation Phrases on Bags and Tags, Such as "Not Used" and "X% Less Than Local"
There are set phrases for writing cultivation methods on bags and tags. If no pesticides were used during the cultivation period, it says "Pesticides: Not used during cultivation period." If only pesticides that are not "pesticides to be reduced" (like those allowed in organic JAS) were used, it says "Pesticides to be reduced: Not used during cultivation period" [1]. They look similar, but the first means no pesticides were used during the growing period, while the second means no counted pesticides were used.
If the amount was reduced, the label must show a percentage, like "Pesticides to be reduced: X% less than local" [1]. In Saitama Prefecture, examples are "Pesticides to be reduced: X% less than Saitama Prefecture regional standard" and "Chemical fertilizer (nitrogen): X% less than Saitama Prefecture regional standard" [5]. "During the cultivation period" for annual crops means the time from after harvesting the previous crop until harvesting and processing this crop [1].
The label includes the name, address, and contact information of the person responsible for cultivation and the person responsible for verification. If the general names, uses, and counts of pesticides used cannot fit on the package, the method to obtain this information (like a website) must be written [5].
Special cultivation, unlike organic, may use pesticides and chemical fertilizers [6]. Instead of "pesticide-free," the comparison target and percentage are written together. And who is this "person responsible for verification" whose name appears on the bag?
5. Why the Person Who Grows Crops Cannot Be the Same Person Who Verifies Them
A sign is put up at the field. It lists the field number, area, date cultivation methods changed, and the name of the person responsible for cultivation [1]. This lets people know who is growing what, where, and since when, right in front of the field.
The grower (person responsible for cultivation) creates and submits a cultivation plan, records of work and materials (names and amounts), and shipment records [1]. These are received by a different person, the person responsible for verification. The guidelines state that one person cannot hold both roles (though a group can have a representative hold both if roles are clearly divided) [1].
The person responsible for verification must visit the field at least once during the cultivation period and keep records for 3 years [1]. The reason is to track the history of materials used and to answer questions if buyers contact them [1]. The number "half or less" is supported by the eyes of someone other than the grower and 3 years of records.
So, is this labeling required by law?
6. Why the Special Cultivation Guidelines Are Voluntary Rules, Not Laws
Surprisingly, these guidelines do not impose a legal obligation to follow them. They are rules that people involved voluntarily check and follow [1].
However, whether you use the guideline labels or not, if you give false information that misleads consumers, there are responses like instructions and public announcements under other laws. The Ministry of Agriculture, Forestry and Fisheries Q&A from around 2008 explains this using the JAS Law, but labeling laws were reorganized after that, so check the current text on the Ministry’s page [1]. Just because it is a voluntary rule does not mean you can write anything.
The scope of what is covered is also set. Processed foods, wild herbs, mushrooms, and hydroponics (growing without soil) are not covered. Business use and direct sales where producers and consumers agree directly are also not covered [1].
7. How to Compare Cultivation Words on Rice and Vegetable Bags at the Store
What you can do at home: Look at rice bags or vegetable bags in your house. Search for words like "special cultivation," "X% less than local," or "not used during cultivation period," and names of growers. Also check that words like "pesticide-free" do not appear on the bag.
What you can do when out: At the store, pick two bags with special cultivation labels. Compare the "X% less" numbers and see which region they are comparing to. On the bag, you can compare region names and crops. The original "normal" numbers are not on the bag, so look them up in the customary level tables on the prefecture’s website.
Official Information: Look for the Ministry of Agriculture, Forestry and Fisheries page for the "Guidelines for Labeling of Special Cultivation Agricultural Products" and the customary level tables for your prefecture. Some prefectures, like Gunma, publish tables for each crop.