Japan releases English version of Food Contact Material Positive List

Japan's Ministry of Health, Labour and Welfare (MHLW) has taken a significant step towards improving transparency and accessibility by releasing an English version of its positive list of substances assessed for safety in food contact materials (FCMs). The information made available on 25 December 2023, aims to provide clarity on permitted substances and additives used in food packaging.

Components of the published material

The English publication of the list is structured into three parts:

1. Table 1 - Polymers: This list categorizes polymers into five categories and explains the characteristics (i.e. glass transition temperature and melting point) of the five categories.

2. Table 2 – Additives: A comprehensive list of 827 additives. For each additive, the table includes its substance names in Japanese and English, CAS numbers, use limits according to polymer group, and associated requirements.

3. Essential Monomers: A detailed list comprising 21 Annexes for different types of essential monomers, their CAS numbers and requirements.

Additional resources and upcoming publications

In an effort to further assist stakeholders and the public, the MHLW is set to publish a list of frequently asked questions (FAQs) on its official website. These FAQs are intended to provide additional clarification on the requirements associated with the Positive List.

The Japanese version of the Positive List was initially published on 30 November 2023. However, in recognition of the global significance and the diverse audiences affected by these regulations, the English version is intended to facilitate a broader understanding and compliance.

Enforcement and legal amendments

Enforcement of the Positive List is scheduled to commence on 1 June 2025. This follows the MHLW’s earlier publication in April 2020 of the first draft positive list of substances assessed for safety in contact with utensils, containers, and packaging. The amendments to Article 18(3) of the Food Sanitation Act came into effect on 1 June 2020.