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Japan’s Transition to Positive List System for Food-Contact Materials

Japan’s Ministry of Health, Labour, and Welfare (MHLW) recently released GMP guidelines as part of the country’s move to a positive list system for regulating food-contact materials.* The GMP guidelines include a proposed positive list of 32 resins that are based on the existing positive lists developed by the Japan Hygienic PVC Association (JHPA) and the Japan Hygienic Olefin and Styrene Plastics Association (JHOSPA).  Masakazu Isurugi, Managing Director of JHPA, reported this development to attendees at Keller and Heckman’s inaugural Food Packaging Law Seminar, held in Tokyo, Japan, on November 14-15, 2017.

Speaking on the regulation of food-contact materials in Japan, Mr. Isurugi, discussed the history of positive lists for food-contact material in Japan. JHPA published the first edition of its positive list in 1970. That initial list was developed as a joint project between JHPA and the Japanese Government. In 1972, the JHPA positive list was recognized by the Japanese Government as a guidance. While not legally binding, voluntary standards developed by JHPA and other industry association are widely respected in Japan.

In July 2015, MHLW announced the possibility of transitioning to a positive list system for regulating food-contact materials. A report was prepared by MHLW’s Committee on the Regulation of Food Utensils, Containers and Packaging that recommended a process for developing and implementing a positive list system. That report was published on June 16, 2017. (See the article, Japan Finalizes Report on Positive List System for Food-Contact Materials, for more details on the recommendations.)

Mr. Isurugi concluded by stating that JHPA will continue to cooperate with the Japanese government to establish a legal positive list system. 

*Since this article was published the Japanese government announced that the positive list system for regulating food-contact materials will be implemented on April 1, 2020.