Food contact

Materials that come in contact with food, such as wrapping, packaging, plates, cups etc have to fulfil the rules set out by the Food Sanitation Act. Japan already introduced a list of materials that would allowed to be used for the above-mentioned purpose. Several other markets are also using positive lists. MHLW has for this purpose asked for public comments and for industry to submit substances that they want to include on the list. This has also been done through the WTO notification procedure. However, the list does not contain all substances used in existing (from before June 2020) yet. Japan government should revise and open the list swiftly and accept if there are requests to add new substances. Moreover, Japan government should create route to accept direct application from suppliers in other countries. If there is no harmonisation as well as a procedure of exemptions as is the case in the EU and the US, European suppliers and Japanese buyers run the risk of not being able to import the products to Japan.


  • Japan should allow resins allowed in the EU and the US.
  • Japan should make it possible for overseas producers to apply directly in regard to having compounds approved.
  • Japan should also introduce a system where materials can still be used without being on the positive list, similar to the EU and the US. Japan should make use of ISO standards as tests methods, as to avoid specific testing for the Japan market.