Japan Releases English Translation of Q&A on Positive List for Food Contact Materials

On May 9, 2025, Japan’s Consumer Affairs Agency (CAA) published the official English translation of its “Q&A on the Positive List System for Apparatus, Containers and Packaging.” This translation is based on the Japanese version originally released on February 6, 2025.

The Q&A document is designed to support stakeholders—both domestic and international—in understanding the scope, application, and regulatory interpretation of Japan’s Positive List (PL) system for synthetic resins used in food-contact materials. It is structured into five main sections and contains a total of 42 questions and answers.

Overview of the Q&A Structure

Clarification on Excluded Substances

One of the most notable aspects of the Q&A is the detailed clarification of substances excluded from the Positive List. The Q&A clearly outlines the following categories as outside the scope of the PL system:

1. Substances that do not fall under raw materials of synthetic resins;

2. Substances used for the purpose of being released from apparatus, containers, and packaging; migrating into food; and acting on that food;

3. Liquid or powdered substances to be adhered to the surface of raw materials of apparatus, containers, and packaging for the purpose of antistatic, antifog, etc.;

4. Substances generated by chemical changes of the substances contained in raw materials;

5. Substances that are not intended to remain in the final product.

These clarifications are crucial for manufacturers to avoid misinterpretation and ensure compliance without unnecessarily submitting materials for inclusion in the list.

Future Revisions Anticipated

This Q&A is expected to be periodically updated to reflect practical challenges and new regulatory developments. Areas such as the treatment of new substances and evolving interpretations of material scope are likely to see expansion in future editions.