Japan tightens rules on food-contact packaging with new positive list system

JAPAN – Japan has formally introduced sweeping new rules governing materials used in food-contact packaging, marking a significant shift in the country’s food safety framework.

The updated regulations, which took effect on June 1, 2025, apply to all packaging and containers that come into direct contact with food and beverages, such as bottles, wrappers, cans, disposable cups, and carton linings.

At the heart of the reform is the “positive list” system, which specifies which substances, including polymers, monomers, and additives, are permitted in food-contact packaging.

Each approved substance is listed with its chemical name, CAS registry number, and conditions for use.

The approach mirrors systems already in place in the European Union, signaling Japan’s intent to harmonize its standards with international best practices.

A five-year transition period will run until June 1, 2030, allowing manufacturers and importers to adjust. During this period, packaging made or sold before enforcement can still follow previous regulations.

Alongside the positive list, Japan has revised its long-standing Specifications and Standards for Food, Additives, etc., first issued in 1959. The updated framework introduces:

• New testing methods for chemical migration and heavy metals, including Atomic Absorption Spectroscopy (AAS) and Inductively Coupled Plasma Mass Spectrometry (ICP-MS).
• Revised requirements for packaging materials made from glass, ceramics, rubber, metals, and synthetic resins.
• Stricter migration limits, including a 0.1 mg/cm² cap for overall migration in synthetic resins.

Mandatory total migration testing for synthetic packaging materials without individual specifications will begin in June 2026, with a one-year grace period. Materials already covered by specific standards, such as PET, PLA, and polyethylene, are exempt.

On May 28, 2025, the government also introduced a formal application process for adding new substances to the positive list.

Companies must submit safety data, migration testing results, and intended use details. Draft proposals issued mid-2025 outline additional reforms, including greater public disclosure of approved substances, more flexible review procedures, and reassessment when new scientific evidence emerges.

Analysts say the reforms will strengthen consumer protection and improve regulatory clarity, while also easing trade with partners in regions like the EU.

For businesses, the changes demand significant compliance investments but also open opportunities to showcase safer, globally aligned packaging solutions.

The ultimate goal, officials say, is improved oversight, transparency, and consumer trust in the safety of food packaging materials in Japan.

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