In an article published on February 25, 2019, law firm Keller and Heckman LLP informed about newly proposed evaluation procedures for food contact substances within Japan that are not currently on the country’s positive list. The article explained that Japan’s current food packaging regulations are based largely on standards that have been set by industry trade associations. These proposed procedures are part of ongoing effort to develop and implement a positive list within Japan (FPF reported) that “will require the substances to be used in food-contact materials to be cleared by the government and not solely an industry trade group.” The Food Safety Commission of Japan (FSCJ) opened the proposal for public comment until today.

The Japanese Ministry of Health, Labor, and Welfare (MHLW) is currently reviewing substances to create the positive list for plastic food-contact materials, and the efforts began with a focus placed on plastic resins. Feedback on the list from companies outside of Japan are requested to be channeled through relevant embassies or local government agencies. Nominations are still being considered for the list, however “it is uncertain how much longer these submissions will be accepted by the Japanese authorities.” MHLW is reported to be planning the submission of an updated draft of the list to the World Trade Organization (WTO) in June 2019. The new positive list system is set to come into force in June 2020.

Read more

Keller and Heckman LLP (February 25, 2019). “Japan’s Regulation of Food Contact Materials – A Step Closer to the New Positive List System.

FSCJ (February 25, 2019). “Opinion and information recruitment concerning deliberation result (draft) on food health effects evaluation guidelines on food equipment and containers and packaging.(in Japanese)