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Update: June 25, 2025：
On June 25, 2025, Japan officially published the "Safety Review Procedures for the Content of Substances in Raw Materials of Utensils, Containers, and Packaging (Cabinet Office Notification No. 102)," which took effect immediately.For details, please refer here.
Update: April 28, 2025：
On April 23, 2025, Japan's Consumer Affairs Agency (CAA) officially launched the public consultation for the draft safety review procedures. The public comment period will close on May 23, 2025. The final version is scheduled to be published within this year and will take effect on the date of publication. For details, please refer here.
On March 27, 2025, Japan's Consumer Affairs Agency (CAA) disclosed a draft of the safety review procedures for the Positive List of food contact materials during an internal meeting.
The Positive List system for food contact materials in Japan will officially come into effect on June 1, 2025, marking the end of a five-year transitional period. From that date onward, in principle, all synthetic resins used in food contact materials must be included in the Positive List, which covers both base materials and additives. Materials such as metals, glass, plant fibers, and thermoset elastomers (rubber, etc.) are not subject to regulation under the Positive List.
To ensure the continual update of the Positive List, the CAA plans to classify the update procedures into the following three types:
| Process Type | Main Target |
|---|---|
| Revision of Additives | Modifications of existing specifications and additions of new substances to Table 2 (Additives) of APPENDED TABLE 1 |
| Safety Review of Additives | Risk management methods differing from those in APPENDED TABLE 1, including use restrictions for new substances |
| Revision of Monomers | Revisions to monomers used in base materials |
The currently disclosed Draft Safety Review Procedures correspond to the "Safety Review of Additives" in the table above. The guidance for the "Revision of Additives" was already published in May 2020.
Compared to the Revision of Additives, the Safety Review of Additives follows a shorter official review process. The Revision of Additives requires one round of hearings and a public comment period each at the Food Safety Commission and the CAA. In contrast, the Safety Review of Additives only requires one round of hearings and public comments at the CAA. Clearly, when applying for substances not yet listed in the Positive List, the Safety Review of Additives offers a more efficient option for companies.
It is important to note that substances approved through the Safety Review of Additives will not be included in APPENDED TABLE 1 but will instead be announced separately by the authorities.
In addition, a draft outlining the documentation requirements for applications under all three process types was also released at the same time.
It should be noted that this draft has only been released as meeting materials, and the official public consultation is expected to begin by the end of April.
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