Japan – Positive Lists for Plastic Food Contact Materials Published

Vol. 1152 | 08 May 2020

The Ministry of Health, Labour and Welfare (MHLW) of Japan has published the positive lists for plastic food contact articles and packaging, which will be implemented from 1 June 2020.

Contrary to the existing heavy metal content and leachable substance restrictions in the Specifications and Standards for Foods, Food Additives, etc. under the Food Sanitation Law, the positive list system is a new regulatory approach which focuses on the raw materials used. This means all plastic food contact articles and packaging can only be made of the listed substances.

The four positive lists published by the MHLW are:

• List of substances allowed in food contact base polymers
• List of substances allowed in food contact coatings
• List of monomers allowed for use in polymerization of base polymers
• List of allowed additives

Substances that are not in the positive lists can only be used in materials that are not in direct contact with food. In the event that these substances accidentally come into contact with food, they shall not migrate into food at concentration exceeding 0.01 mg/kg.

The Specifications and Standards for Foods, Food Additives, etc. will still be in force after 1 June 2020, but with the removal of any redundant clauses which overlap with the new positive list legislation.

The Ministry has laid down some transitional measures, allowing plastic food contact articles and packaging that are placed on the market, manufactured, imported or used in business before 1 June 2020 to be consumed until stocks are exhausted. Moreover, products can be manufactured or imported according to the previous provisions until 31 May 2025.

For additional information please contact:

Laureen Leung
laureen.leung@intertek.com 
+852 3760 6361