Japan amends the positive list of Food Contact Materials: Adds new additives

On 27 September 2024, Japan’s Ministry of Health, Labour and Welfare (MHLW) approved amendments to the Standards and Criteria for Foods, Food Additives. This amendment revises the positive list of food contact materials (FCMs) under the Food Sanitation Act. 

This amendment will revise the usage provisions of 4 polymers in Table 1 and add 13 new additives to Table 2 of the FCM positive list. There are now 840 entries on the list.    

Public Consultation in May 2024 

Before approving the amendment, the MHLW held a public consultation from 24 May 2024 to 22 June 2024 to gather feedback on the proposed changes to the FCM positive list. This consultation specifically addressed revisions to the polymer use provisions and the addition of new additives, which were included in the final amendment. 

Standards and Criteria for Foods, Food Additives 

The Standards and Criteria for Foods, Food Additives contain requirements and guidelines for foods, milk and milk products, food additives, apparatus, and containers and packaging regulated by the Food Sanitation Act and other laws. The MHLW regularly revises these standards to keep them up to date and to protect human health and the environment. 

Japan’s Positive List of FCMs 

For synthetic resins used as primary materials in food utensils, containers, and packaging, the amended Food Sanitation Act introduced a positive list system on 1 June 2020. Only materials deemed safe and specifically included in the Positive List are permitted for use, which by default forbids the use of synthetic resin materials. 

The MHLW released the Japanese version of FCM Positive List (containing 827 entries) on 30 November 2023, followed by the English version on 25 December 2023. Details can be found here.  

Enforcement Date 

The amendment came into effect on promulgation. The revised FCM positive list will be enforceable from 1 June 2025, although existing materials may continue to be used until the end of the five-year transition period, which is 31 May 2025.