On March 6, 2023, the Ministry of Health, Labor and Welfare of Japan (MHLW) released a revised draft of the Positive List of Substances Allowed for Food Contact Utensils, Containers and Packaging. The draft includes two lists – base materials and additives for food contact materials.
The new draft expands the definition of cross-linked polymer and introduces new classifications for polymers with adsorptive or ion exchange ability and for polymers used for coatings that involve chemical reactions during the coating process. The changes to the list also included removing some substances and limiting the usage of others. Dibutyl phthalate (CAS 84-74-2), for example, was previously banned in food contact articles that directly contact raw meat but is now restricted from all articles that directly contact any foodstuff.
For all polymers and additives not included in the list the migration limit is 0.01 mg/kg food. Producers must prove compliance with this limit either through migration studies with food simulants or by computer modeling (FPF reported).
References
Rose Hong (March 28, 2023). “Japan updates the positive list of food contact materials.” ChemLinked.
Ministry of Health, Labor and Welfare of Japan (March 6, 2023). “About the positive list system for food utensils, containers and packaging.” (in Japanese).
