"Japan’s Positive List System for Utensils, Containers, and Packaging Intended for Food Use (Effective from June 1, 2025)"

Japan’s Positive List System for Utensils, Containers, and Packaging Intended for Food Use (Effective from June 1, 2025)

Following the amendment of the Food Sanitation Act in 2018, the so-called Positive List System was introduced to regulate utensils, containers, and packaging intended for food use. This system, which came into force on June 1, 2020, allows the use of only those substances that have been evaluated as safe to use. Pursuant to Article 18, Paragraph 3 of the Act, synthetic resins used in such products must consist solely of substances listed in the Positive List. In principle, the use of substances not included in the list is prohibited.

This system applies to all businesses engaged in food-related operations, regardless of their scale. Violations are subject to penalties meaning the system has a significant impact within the industry . Additional attention will be required after June 1, 2025, as this marks the expiration of the transitional period and a revision of the Positive List itself.

This newsletter outlines the framework of the Positive List System, including the transitional measures, and introduces the scope of materials covered under the system - highlighting changes made to the Positive List. Unless otherwise stated, all legal provisions cited herein are current as of the time of writing.
 

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