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The positive list of Japanese food contact materials is about to be updated, and manufacturers and sales of synthetic resin need to pay close attention!


Time:

2023-10-23

The positive list of Japanese food contact materials is about to be updated, and manufacturers and sales of synthetic resin need to pay close attention!

The positive list of synthetic resins for food utensils, containers, and packaging in Japan is expected to be fully implemented from June 1, 2025.

Remind relevant manufacturers to ensure that all synthetic resins produced and sold meet the requirements of the positive list after the full implementation of the positive list.

 

 

Positive list review in progress

The Food Hygiene Subcommittee of the Pharmaceutical and Food Hygiene Committee under the Ministry of Health, Labour and Welfare (MHLW) in Japan is currently reviewing the comments received.

In addition, the Japan Center for Food Contact Material Safety (FCMSC) held a meeting on August 23, 2023 to inform stakeholders of its ongoing update and implementation status of the positive list process.

 

Update content of the positive list

At this year's FCMSC meeting, officials from the Japanese Ministry of Health, Labour and the National Institute of Health Sciences (NIHS) explained that the 'secondary monomer' rule will still apply to the final positive list.

 

Front List Table 1 (Base Resin)

Secondary monomers refer to monomers that are not included in the list but are actually used less than 2% wt of the overall polymer. For such monomers, even if not listed in the front list, they can still be used.

This rule is likely to be elaborated on in the official version of Table 1 (Basic Resin) of the front list, possibly in the form of footnotes.

In addition, regarding synthetic resins involving high-temperature applications, it is the responsibility of the enterprise to determine the maximum temperature at which the resin can be safely used.

 

Front List Table 2 (Additives)

Regarding Table 2 of the positive list (additives), FCMSC officials pointed out that certain categories of polymerization processing aids, such as defoamers and surfactants, are only used in the polymerization process and do

not have a technical effect on the final product. These substances are not within the scope of the positive list and therefore do not need to be listed.

However, if the same substance is intended to have a technical effect in the final product, it needs to be included in the positive list. In addition, certain additives are still under review and will be included in Table 2 when finalized and promulgated.

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