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Japan Finalizes Report on Positive List System for Food-Contact Materials

Japan’s Ministry of Health, Labour and Welfare (MHLW) has issued a final report that details the steps that should be taken to develop and implement a positive list system for regulating food-contact materials. The Report, prepared by the Committee on the Regulation of Food Utensils, Containers and Packaging, was published on June 16, 2017, and an English version was posted on MHLW’s website on Aug. 7, 2017.

The Committee’s Report states that Japan’s food utensils, containers and packaging (UPC) system should be “founded on the policy of essentially banning all substances except those that have been approved for use by way of safety assessment (Positive List system) to secure and improve the safety of UCP.”

The Report directs the authorities to commence by introducing the Positive List system for synthetic resins and include monomers, base polymers, additives, and other substances.  Further, the system should apply to inner layers of multi-layered materials, as components of such layers are most likely to migrate into the food. Once a positive list is developed for resins, MHLW will discuss whether to apply the system to other materials (e.g., metals, paper, etc.).

The Committee also recommends that a risk assessment scheme be established that is “rational, scientific, and globally consistent.” Noting that the U.S. Food Contact Notification (FCN) system is proprietary (i.e., it limits the use of cleared substances to the notifier for each product), the committee suggested that Japan should likewise consider such mechanisms.

The Report also touches on the manner in which information should be shared among business operators, and the need for UCP manufacturers to adopt good manufacturing practice (GMP). For more background information, see the PackagingLaw.com article, Japan Poised to Adopt Positive List System for Food-Contact Materials.

© 2020 Keller and Heckman LLPNational Law Review, Volume VII, Number 230


About this Author

PackagingLaw.com is the premier online resource for the global packaging industry. It provides a wide range of information on laws and regulations—both in the U.S. and other countries throughout the world—that affect packages and packaging materials. PackagingLaw.com features news articles on current issues affecting the packaging industry, in-depth features, an Ask an Attorney section, links to packaging industry and government websites, and detailed information on the U.S. Food and Drug Administration (FDA) Food Contact Notification system.