2025-07-28 Reference source : e-GOV Public Comment Portal-Japan
Amendment Food contact materials MHLW Japan
On 28 July 2025, Japan’s Ministry of Health, Labour and Welfare (MHLW) published draft ordinance for public solicitation to amend provisions under Food Sanitation Act. MHLW published the draft ordinance on the Japan’s e-Gov Public Comment Portal. This time MHLW emphasized on the repeated import notification for food, food additives, apparatus, or food containers/packaging.
Regulatory Background
Article 27 of the Food Sanitation Act (Japan) stipulates that any person intending to import food, food additives, apparatus, or food containers/packaging for the purpose of sale or commercial use must submit an import notification to the Ministry of Health, Labour and Welfare (MHLW) each time. This requirement ensures that imported products comply with Japan’s safety standards before they enter the domestic market. The purpose is to prevent health hazards by allowing the authorities to monitor and control the safety of imported food-related items.
Key Insights from the Draft Ordinance
MHLW has provided the amendments in the draft ordinance and which have been tabulated below:
Particulars |
Current Situation (Before Amendment) |
Situation After Amendment (Effective Oct 12, 2025) |
Electronic submission of import notifications |
Allowed for individual notifications under Article 27. |
Still allowed. No change. |
Planned Import Notification (for repeated imports) |
Allowed only if submitted in paper form. Electronic submission not accepted due to restriction in Article 32(9). |
Electronic submission of planned import notifications will be allowed, following system updates. |
Regulation Article Affected |
Article 32(9) prohibited the use of planned notifications via electronic means. |
Article 32(9) will be deleted, removing this prohibition. |
System capability for electronic planned submissions |
Not compatible; importers had to submit via traditional means for planned imports. |
System updated; fully compatible with electronic planned notifications. |
Comment Period and Enforcement Dates
Stakeholders are allowed to submit comments till 26 August 2025. While this draft ordinance will be promulgated in early October 2025 and is scheduled to be enforced from 12 October 2025.
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