Requirements for the Use of Colorants in FCMs in Japan
Requirements for the Use of Colorants in FCMs in Japan
With the entry into force of the new Positive List (PL) system in Japan for food contact materials, effective from June 1, 2025, coloring pigments remain excluded. However, are they are required to be included in the JCII (Japan Chemical Industry Association) positive lists as voluntary standards? Furthermore, are there any other positive lists governing coloring pigments for food contact applications in Japan?
The standards and specifications for colorants used in food contact materials (FCMs) in Japan is established in Article A.5 in Chapter III of MHW Notification No. 370 as follows:
Apparatus, containers and packaging must NOT contain any chemically synthesized colorant other than those listed in Appended Table 1, the Ordinance for Enforcement of the Food Sanitation Act (Ordinance of the Ministry of Health and Welfare No. 23, 1948). Note that this requirement shall NOT apply to the case where the apparatus, container, or packaging is made to prevent artificial colorant from being eluted or seeping into food.
The policy related to colorants in FCM is further explained in Q17 and Q18 of Q&A on Japan’s National Positive List, published by the Consumer Affairs Agency (CAA). As explained therein, the pigment (and any surface treatment that remains on the surface of pigments) are exempt from Japan’s PL scheme. However, if a component in the surface treatment may potentially migrate to food, it would need to be listed in Table 2 (“Additives”).
Listing on JCII’s voluntary PL for colorant is not required by Japanese law. That said, some companies find that a JCII Certificate is a useful tool for businesses marketing FCM in Japan, as many Japanese companies will expect to receive from its supplier(s) a written certification of compliance with A.5., Chapter III of MHW Notification No. 370.