Food contact

Committee:
Food & Agriculture
status:
Some progress
Published:
Materials that come into contact with food—such as wrapping, packaging, plates, and cups—must comply with the requirements set out in Japan’s Food Sanitation Act. Japan has introduced a positive list of materials permitted for such use. However, this framework has posed challenges for foreign organizations, primarily due to the lack of timely and comprehensive information available in English. One particular area of concern is mechanically recycled food contact materials, for which there appears to be no international harmonisation. According to the guidelines notified on 28 March 2024, mechanically recycled resins must comply with Japan’s positive list. As a result, food products packaged in mechanically recycled synthetic resin cannot be exported to Japan unless the exporter can demonstrate that the source of the waste resin aligns with the Japanese positive list. Although the positive list is now finalised, delays in publishing the amendments in English have caused many foreign packaging manufacturers to postpone their compliance assessments. Consequently, food manufacturers and importers face uncertainty regarding whether their products meet Japanese regulatory requirements.

Recommendations

  • Japan should allow resins allowed in the EU and the US.
  • Japan should urgently that all legislation and official guidance is available in English. This would avoid any misunderstandings.
  • Japan should provide guidance on how to know which polymer group a specific compound belongs to. Currently some compounds are classified differently in Japan.
  • Japan should make it possible for overseas producers to apply directly in regard to having compounds approved, as this would deal with the issue of confidentiality.
  • Japan should make use of ISO standards as tests methods, as to avoid specific testing for the Japan market.
  • Considering current sustainability conscious circumstances, Japan should develop a scheme to accept mechanically recycled synthetic resin from waste resin in EU as food contact material. This would also be in line with sustainability goals.