Japan to Implement Positive List System for Food Contact Materials

Takehome - Japan will introduce a positive list to regulate FCM instead of the negative list currently in use. The implementation date is still uncertain and no positive list has been published yet. In the interim synthetic resin will be a high priority regulatory target.

On Jun 13th, 2018, Japan published the revised Food Sanitation Law. In the amended version, Japan introduced the positive list system for food contact material to replace the current negative list. Recently on October 15th, 2018 Japan held technical seminars related to the development of the positive list. The positive list is unlikely to be published in 2018 according to the timeline.

Currently Japan implements a negative list to regulate use of chemicals/materials in FCM which deviates from global best practices and often leads to a situation in which materials and products banned in one country can be sold in Japan.  

The enforcement date remains uncertain but shall be no later than Jun 13th, 2020, depending on the promulgation of support guidelines, implementations rules and other regulations. In the interim synthetic resin will be regulated as a high priority target.

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