Over the last several years, Japan has been overhauling its regulatory system covering food utensils, containers, and packaging. The country is switching to a streamlined positive list system for chemicals used in ‘synthetic resins’, i.e., plastics and other polymers. Starting June 2025, only substances included in the ‘positive list’ of approved substances can be used when manufacturing synthetic resin for food contact materials (FCMs).
In November 2023, the Ministry of Health Labor and Welfare (MHLW) published the finalized structure that the positive list will take. Namely, Table 1 with base materials defining the polymer-types manufacturers can use, plus a related list of monomers that can be used to form said polymers, and a separate Table 2 with approved additives.
Japan’s Food Sanitation Act was amended in 2018 to create the positive list system (FPF reported), and the first draft was published in 2020 (FPF reported). This recently revised version comes after feedback received over the years since then. Japan’s positive list essentially covers the same materials as that of the EU’s plastics regulation (Commission Regulation (EU) No 10/2011).
Since publishing the final version of the positive list in late 2023, MHLW has revised the usage limits and the exact list of additives following industry feedback. Work is ongoing and there is currently a consultation open for including additional additives, but at this time the positive list contains 21 base materials and 827 additives.
To track consultations on the additions to the positive list, or other open public policy processes, bookmark the Food Packaging Forum’s consultations page.
References
MHLW. “Regarding the positive list system for food utensils, containers and packaging (from June 1, 2025).”
MHLW. “Table 1 (Base materials).”
MHLW. “Table 2 (additives).”
MHLW. “Monomers, etc.”
Rose Hong (May 31, 2024). “Japan Proposes to Update the Positive List of Food Contact Materials.” ChemLinked
Sok-Han Ng (April 11, 2024). “What are the next steps for Japan’s positive list system for food contact materials?” Chemical Watch News & Insight
Read more
Lam Lye Ching (December 11, 2023). “Japan publishes positive list of FCMs.” Chemical Watch News & Insight
Lam Lye Ching (January 8, 2024). “Japan publishes positive list for food contact materials in English.” Chemical Watch News & Insight
Lam Lye Ching (March 25, 2024). “Japan proposes updates to positive list for food contact materials.” Chemical Watch News & Insight
Lam Lye Ching (April 17, 2024). “Japan details manufacturers of food contact materials that must submit FSA notifications.” Chemical Watch News & Insight
Rose Hong (May 20, 2024). “[Updated] Keeping Pace with Legislative Progress: Discussions on Utensils, Containers, and Packaging in Japan.” ChemLinked
Lam Lye Ching (May 29, 2024). “Japan clarifies scope and requirements for food contact materials positive list.” Chemical Watch News & Insight
Keller & Heckman (May 30, 2024). “Japan Announces Comment Period on Amendment to Table 2 of Positive List.” Packaginglaw.com
Rose Hong (May 31, 2024). “Japan Proposes to Update the Positive List of Food Contact Materials.” ChemLinked
Lam Lye Ching (June 3, 2024). “Japan proposes amendments to food contact materials positive list.” Chemical Watch News & Insight
