Food additives, enzymes and processing aids

Differences in the lists of additives and enzymes approved by Japan and other major markets are still common. While the EBC has seen progress in Japan’s approval of additives, the approval process still remains an obstacle, and an overall lack of transparency. EU and Japan should use the EPA to further strengthen the work in this field. Despite announcements that the EPA would result in faster approval times, this has not been realised.


  • Japan should harmonise its definition of food additives to exclude processing aids which as per its definition do not remain in the product after it has been produced. The same should apply for nutrition fortifiers. Japan should ensure that standards of use in Japan are not in conflict with international standards of use.
  • Japan should also harmonise the specifications of food additives, such as purity, definition of specific food additives and size of molecules.
  • The Ministry of Health, Labour and Welfare (MHLW) should put the same focus on enzymes as it has on food additives and actively approve enzymes that are well established in other major markets.
  • Japan should explicitly communicate why commonly used additives are not approved for use in Japan. Japan should make certain that approval times are decreased as discussed in the EPA. Currently, the consultation period can be very long.