On June 5, 2026, Japan's Consumer Affairs Agency (CAA) issued an administrative notice partially revising its "Questions and Answers on the Positive List System for Apparatus, Containers, and Packaging." Issued by the Food Sanitation Standards Evaluation Division, the revision replaces the previous Q&A notice of December 26, 2025, which was abolished the same day. CAA released both a new-old comparison table and the revised Q&A, and asked prefectural and municipal food sanitation authorities to circulate the update to relevant businesses.
Background
The positive list (PL) system for synthetic resins used in food utensils, containers and packaging has been fully effective since June 1, 2025, following the end of its transition period. Under the system, only monomers, additives and other substances that have been individually evaluated and listed may be used in the base materials of such products. The supporting Q&A converts these technical requirements into practical guidance and comprises 44 questions across four sections: the scope of the PL, the base materials listed in Appended Table 1 (21 grouped polymer substances), the additives listed in Appended Table 2, and an "Others" section covering topics such as transition measures and new substances.
Key changes in this revision
The accompanying comparison table shows that this is largely an alignment and maintenance revision rather than an expansion of the list itself. The principal changes are as follows:
- Recycling question relocated. The question on how recycled materials are handled under the PL (former Q40) was removed from this Q&A and moved to the separately issued "Questions & Answers on the Recycling Guidelines," published the same day as a Joint Notice between CAA and the Ministry of Health, Labour and Welfare's Department of Food Safety. Businesses working with recycled plastics should now refer to that dedicated Q&A.
- Notification references updated throughout. The Q&A's shorthand references were aligned with the current titles of the underlying instruments: "Monomer Notification" was changed to "Monomers, etc. Notification" (the MHLW notification of November 30, 2023 that lists the monomers and other components of each of the 21 base materials), and references to the food specification standards (MHLW Notice No. 370) were updated to the current title "食品、添加物等の規格基準" (Specifications and Standards for Food, and Food Additives, etc.). The updated names now run through the relevant answers.
- Clarifications to existing answers. Other answers were adjusted for clarity — for example, a cross-reference in the scope section was broadened from specific question numbers to a general reference to Section 1, and minor wording in the scope examples was updated. The revision does not change the positive list tables themselves.
What companies should do
Manufacturers and importers of synthetic-resin food contact products should download the revised Q&A and the comparison table from the CAA website, check that any answer they depend on — particularly the notification references — reflects the updated wording, and route recycled-material questions to the new Recycling Guidelines Q&A. Substances not yet listed continue to require either an amendment to Appended Table 1 or the Monomers, etc. Notification, or a published safety review, before they may be used in a listed base material.
