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On April 28, 2025, Japan’s Consumer Affairs Agency (CAA) announced the results of the public consultation (Jan 20 ~ Feb 20, 2025) regarding the proposed prohibition on the use of Class I Specified Chemical Substances, as designated under the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. (CSCL), as raw materials for food utensils, containers, and packaging. No revisions were made to the proposal based on the submitted comments.
Under the proposal, a new provision will be added to the "Standards for Food, Additives, etc." (Notification No. 370 of the Ministry of Health and Welfare, 1959), stipulating that "Class I Specified Chemical Substances must not be used as raw materials." The final version is expected to be promulgated within this year.
In Japan, chemical substances that exhibit persistence, high bioaccumulation, long-term toxicity, or chronic toxicity to higher trophic level organisms, including PFAS, are designated as Class I Specified Chemical Substances under Article 2, Paragraph 2 of the CSCL. In principle, the manufacture, import, and use of these substances for the production of articles are prohibited.
Meanwhile, the standards for food utensils, containers, and packaging are established under the "Standards for Food, Additives, etc." (Notification No. 370 of the Ministry of Health and Welfare, 1959). These standards include regulations based on negative lists for different material types and a positive list system for synthetic resins. Until now, food containers and packaging have been excluded from the application of the CSCL regulations.
However, since food utensils, containers, and packaging are also considered industrial products and often share common raw materials and manufacturing processes with products intended for other uses, it has been deemed inappropriate to allow the use of Class I Specified Chemical Substances in materials for these products.
According to official investigations, there have been no records of Class I Specified Chemical Substances being used in food utensils, containers, and packaging in Japan to date. Therefore, this revision is primarily intended to clarify the regulatory framework, and it is not expected to have a significant impact on companies' actual compliance practices.
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