On April 28, 2020, the Japanese Ministry of Health, Labor, and Welfare (MHLW) published a revised version of its positive list of substances for use in food contact materials (FCMs). In August 2019, MHLW published the draft version of the list and notified it to the World Trade Organization (WTO) (FPF reported). Following completion of a comment period allowing companies to request additional substances be added, Chemical Watch reports that the revised list now includes an additional “300 base polymer resins, 180 base polymer resin additives of a polymeric nature (for example, coating materials), 50 trace monomers, and 750 additives.” As introduced in an earlier version, the agency has confirmed that it will set a migration limit of 0.01 mg/kg food for all other polymer resins and additives not on the list, allowing producers to use them so long as compliance with this limit can be proven through either migration studies with food simulants or computer modeling.

Despite a delay in releasing this updated version, MHLW has said it still plans to enforce the list as originally planned on June 1, 2020. This will apply immediately for new products, and existing products on the market will be allowed a five-year transition period to either substitute unapproved substances or request their addition onto the list. New products containing substances not on the list will need to be notified to MHLW. Further amendments to the positive list are expected to be published in March 2021.

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Chemical Watch (May 4, 2020). “Japan publishes revised positive list for food contact materials.”

Andrew Jackson (March 12, 2020). “Japan’s positive list for plastic FCMs delayed.”

SGS (June 22, 2020). “Japan Publishes Positive List for Food Contact Synthetic Resin Materials and Articles.”


MHLW (April 28, 2020). “About the positive list system for food utensils and containers and packaging.” (in Japanese)