Japan's Consumer Affairs Agency recently issued a notice on the Revision of Specifications and Standards for Foods, Additives, etc. (Arrangement of Individual Specifications for Utensils, Containers and Packaging), announcing significant adjustments to the transitional measures related to the Positive List system for food contact materials introduced in 2025.
The main changes are as follows:
- Extension of the Transition Period
Originally, the regulations were scheduled to take effect from June 1, 2025, with provisions concerning changes to specifications or testing methods taking effect from June 1, 2026. Utensils, containers, and packaging that had been sold, manufactured or imported for sale, or used before June 1, 2027, could continue to comply with the previous regulations. The deadline for using the original regulations has now been extended to June 1, 2030, providing an additional three-year buffer period.
- Expansion of Scope of Application
In addition to the original applicable items (utensils, containers, and packaging that have been sold, manufactured, imported, or used), the phrase "and similar items thereto" has been added. "Similar items thereto" refers to utensils, containers, and packaging manufactured or imported using substances that were used in utensils, containers, or packaging that were sold, manufactured or imported for sale, or used commercially, either before June 1, 2025, or during the transitional measures, provided they are used within the scope of use of those substances. This means that similar products manufactured using the same substances during the transition period can also continue to use the old standards.
- Addition of Precautionary Clause
New precautionary notes have been added following the revision. It clarifies that during the transitional measures period, if institutions such as local public health institutes or quarantine stations need to conduct specification testing using test methods specified in a separate notification, and if the performance evaluation based on the Notification concerning the handling of test methods, etc. for specifications and standards for utensils, containers and packaging has not been completed, each testing institution may appropriately manage tasks related to precision control to ensure the normal conduct of testing work.
This revision provides companies with a more ample transition period and further clarifies the scope of applicable products during the transition, ensuring a smooth transition and implementation of the Positive List system.
