Japan releases revised positive list for food contact materials

On 6 March 2023, Japan’s Ministry of Health, Labour and Welfare (MHLW) published a draft of its latest revised positive list for food contact materials (FCMs) which includes substances for listing requested by companies, and revised use requirements for some substances under table 1 and 2. Table 1 consist of base materials like dichloromethylphenylsilane, 2,4,6-trimethyl-2,4,6-tris(3,3,3-trifluoropropyl)cyclotrisiloxane, [n-2-(aminoethyl)-3-aminopropyl]dimethoxy methylsilane, etc. and Table 2 consists of for example triallyl isocyanurate, triester of benzoic acid and 2-ethylhexanoic acid with trimethylolpropane.

The first draft of the positive list for FCMs was published in August 2019 under the amended Food Sanitation Act. Currently, the positive list consists of:

• Approximately 300 base polymer resins
• 750 additives
• 180 base polymer resin additives
• 50 trace monomers

The revision follows a consultation phase from 26 April 2022 to 15 July 2022, where businesses were asked to provide comments and list suggestions to the MHLW. Enforcement of the new revision is expected to begin on 1 June 2025.

The Japan Food Contact Material Safety Centre gave companies advice at the end of March to review the list of compounds, the Ministry's policies based on company comments, and the revised use restrictions for some substances.